Title VII & Transsexuals: Recent Cases
Citation Decision Quote
Smith v. City of Salem, 378 F.3d 566 (6th Cir. 2004) Dismissal of firefighter's Price Waterhouse claim reversed on appeal. "[A] label, such as 'transsexual,' is not fatal to a sex discrimination claim where the victim has suffered discrimination because of his or her gender non-conformity."
Barnes v. City of Cincinnati, 401 F.3d 729 (6th Cir. 2005) Jury award to police officer on Price Waterhouse claim affirmed on appeal. "Barnes produced evidence at trial that tended to show that the City’s proffered reason for demoting Barnes was false and that the real reason for his demotion was unlawful discrimination."
Etsitty v. Utah Transit Authority (Dist. of Utah 2005) Summary judgment granted to defense on bus driver's Price Waterhouse claim. "There is a huge difference between a woman who does not behave as femininely as her employer thinks she should, and a man who is attempting to change his sex and appearance to be a woman."
Mitchell v. Axcan Scandipharm (Dist. of Western Pennsylvania 2006) Motion to dismiss Price Waterhouse claim denied. Plaintiff pleaded sufficient facts "showing that his failure to conform to sex stereotypes of how a man should look and behave was the catalyst behind defendant's actions."
Schroer v. Billington (Dist. of D.C. 2006) Motion to dismiss Title VII claim denied. "There are facts that Schroer could prove which would support her claim that the Library refused to hire her solely because of her sexual identity."