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Keywords

statutediscriminationdue processlegislative intent

willdue process

Related Cases

Holloway v. Arthur Andersen & Co., 566 F.2d 659, 16 Fair Empl.Prac.Cas. (BNA) 689, 15 Empl. Prac. Dec. P 8059

Facts

Ramona Holloway was employed by Arthur Andersen since 1969, initially as Robert Holloway. In 1970, she began hormone treatments and was promoted in 1974, during which she informed her supervisor about her transition. Despite receiving a pay raise, she was terminated shortly after her records were updated to reflect her new name in November 1974. After exhausting administrative remedies, Holloway filed a complaint alleging discrimination based on her transsexuality.

Holloway was first employed by Arthur Andersen in 1969 and was then known as Robert Holloway.

Issue

Whether an employee may be discharged, consistent with Title VII, for initiating the process of sex transformation.

The sole issue before us is whether an employee may be discharged, consistent with Title VII, for initiating the process of sex transformation.

Rule

Title VII does not encompass discrimination based on transsexuality, as the term 'sex' is interpreted to refer only to traditional anatomical characteristics, and transsexuals are not classified as a suspect class under the Fourteenth Amendment.

Therefore, this court will not expand Title VII's application in the absence of Congressional mandate.

Analysis

The court applied the rule by examining the legislative intent behind Title VII, concluding that Congress did not intend for the statute to cover transsexual discrimination. The court noted that the definition of 'sex' in Title VII is limited to traditional notions and that transsexuals do not meet the criteria for suspect classification, thus failing to establish a violation of equal protection or due process.

This court cannot conclude that transsexuals are a suspect class.

Conclusion

The court affirmed the district court's dismissal of Holloway's action, holding that her claim of discrimination based on transsexuality was not actionable under Title VII.

Therefore, the judgment of the district court dismissing Holloway's action for failure to state a claim is AFFIRMED.

Who won?

Arthur Andersen & Co. prevailed in the case because the court found that Title VII does not protect against discrimination based on transsexuality, and the discharge did not violate constitutional protections.

The court concluded that the discharge did not violate due process or equal protection principles.

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