“BIRTH AT SEA was a prerequisite for the first fully-aquatic whales, the Basilosauridae (including Dorudon) which evolved from Protocetidae later in the Eocene. Basilosauridae have reduced hind limbs that no longer contact the vertebral column and could not support the weight of the body on land. Hence they could no longer come out of the sea onto land to give birth.”
http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0004366