Court Rules Insurer Doesn't Owe $303,000 in Pregnancy Discrimination Case Because of Paperwork Timing

A federal appeals court ruled on August 11, 2026 that an insurance company doesn't have to pay out a $303,592.20 pregnancy discrimination judgment, because the paperwork trail started two years before the policy existed.

The US Court of Appeals for the First Circuit affirmed a lower court decision letting Travelers Casualty and Surety Company of America off the hook for a judgment against its policyholder, Mammoth Tech, Inc.

In March 2019, a former Mammoth Tech employee filed a complaint with the New Hampshire Commission for Human Rights and the EEOC. She said the company discriminated against her based on sex and retaliated against her during her pregnancy. The commission notified Mammoth Tech that same month.

The commission dismissed her complaint in October 2020. The EEOC then gave her a right-to-sue letter. She filed a federal lawsuit in January 2021 over the same conduct.

Mammoth Tech didn't show up to defend itself. In March 2023, a court entered a default judgment against the company: $303,592.20 in back pay, damages, and attorneys' fees.

The employee died at some point after winning her case. Her estate then went after Mammoth Tech's insurer to actually collect the money.

Mammoth Tech had bought Employment Practices Liability coverage from Travelers. That policy ran from December 4, 2020 to August 5, 2021. The 2021 lawsuit landed squarely inside that window.

But the policy language mattered more than the lawsuit date. The EPL policy covered claims "first made" during the policy period. It also contained a "Related Claims" provision: claims arising from "Related Wrongful Acts" count as a single claim, and that single claim is deemed made on the date of the earliest one.

The 2019 EEOC charge and the 2021 lawsuit covered the same alleged conduct. Under the Related Claims provision, the court found, the whole thing was legally "made" in 2019, back when the employee first filed with the commission. That's roughly 20 months before Travelers' coverage even started.

The estate argued the EPL endorsement should override the Related Claims provision. The First Circuit disagreed, ruling the two provisions worked together rather than conflicting, and affirmed judgment on the pleadings.

This case never tested whether Mammoth Tech actually discriminated against the employee. That question was settled, by default, when the company failed to respond to the lawsuit. The $303,592.20 award stands. What died in this appeal was any chance of Travelers being the one to pay it.

The strongest case for the insurer's position is straightforward: this is exactly what Related Claims provisions exist for. Insurers price EPL policies based on known risk at the time coverage starts. If a company already has an open EEOC charge before it buys a policy, letting a later lawsuit over that same conduct trigger fresh coverage would mean insurers are effectively covering pre-existing claims they never priced in. From the insurer's perspective, this is not a loophole. This is the reason for the "first made" and related-claims language, and courts routinely enforce it as written.

The counterargument, which the estate effectively made and lost, is that an ordinary employee has no way of knowing that filing an EEOC charge in 2019 will quietly wall off insurance coverage on a policy the employer buys more than a year later. The employee did everything the system asked: she filed a timely administrative charge, waited for a right-to-sue letter, then sued. She won. And the company that wronged her apparently had no coverage that reached back far enough to make her whole, through no fault of her own.

Where that leaves things: Mammoth Tech itself is still legally on the hook for $303,592.20. Nothing in this ruling erases that judgment. Whether the estate ever collects from the company directly, separate from any insurance payout, isn't addressed in the court's ruling. For employers, the case is a pointed reminder that Related Claims provisions in EPL policies can reach back years before a policy's start date, and that an early-stage agency complaint, even one that gets dismissed, can determine whether a later lawsuit is covered at all.