“With respect to pregnancy specifically, the EEOC has indicated that a pregnancy-related impairment that substantially limits a major life activity is a disability ....” Saah v. Thumel, No. CV RDB-15-2425, 2017 WL 491221, at *6 (D. Md. Feb. 7, 2017) (citation omitted).

Courts have generally treated these claims as coextensive with their federal counterparts, and the parties have not provided any authority to the contrary. See Bynum v. Martin, Civ. No. GJH-16-2067, 2016 WL 7468050, at *6 (D. Md. Dec. 27, 2016) (citation omitted) ("Plaintiff also raises an identical state law claim under FEPA, which other judges in this district have held to be interpreted consistently with Title VII."); Saah v. Thumel, Civ. No. RDB-15-2425, at *7 (D. Md. Feb. 7, 2017) (quoting Peninsula Reg'l Med. Ctr. v. Adkins, 448 Md. 197, 218 (2016)) ("The Court of Appeals of Maryland has held that the definitions of 'disability' under the ADA and Maryland law are 'nearly identical'

Courts have continued to apply this requirement in analyzing whether pregnancy-related complications constitute disabilities. See, e.g., Brown-Wicks v. PPE Casino Resort Maryland, LLC, No. GJH-18-2576, 2019 WL 3778677, at *3 (D. Md. Aug. 9, 2019); Saah v. Thumel, No. CV RDB-15-2425, 2017 WL 491221, at *6 (D. Md. Feb. 7, 2017). In this case, the record is undisputed that Cpl. Hamilton was not "substantially limited" in any major life activity.

Additionally, an employer's challenge to Title VII punitive damages may be considered at the summary judgment stage. e.g., Saah v. Thumel, No. CV RDB-15-2425, 2017 WL 491221, at *13 (D. Md. Feb. 7, 2017) (granting the defendant's motion for summary judgment as to the plaintiff's prayer for punitive damages in Title VII discrimination and retaliation matter). In her Report, the Magistrate Judge acknowledges that the court would be better equipped to make a punitive damages determination either just before or during trial.

"To establish a causal connection between a protected activity and an adverse action, a plaintiff must prove that . . . the employer knew the employee engaged in a protected activity." Saah v.Thumel, No. RDB-15-2425, 2017 WL 491221, at *12 (D. Md. Feb. 7, 2017) (internal quotation marks omitted) (brackets in original) (quoting Gibson v. Marjack Co., 718 F. Supp. 2d 649, 655 (D. Md. 2010)). In Hinton v Va. Union Univ., 185 F. Supp. 3d 807, 825-831 (4th Cir. 2016), the Court of Appeals for the Fourth Circuit makes clear that a "'materially adverse action,' not 'adverse employment action,' is the proper articulation of the adversity element in retaliation claims."