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Keywords

lawsuittrialdiscriminationcivil rightsoverruled

defendanttrialdiscrimination

Related Cases

Zarda v. Altitude Express, Inc., 883 F.3d 100, 130 Fair Empl.Prac.Cas. (BNA) 1245, 102 Empl. Prac. Dec. P 45,990

Facts

Donald Zarda, a gay man, worked as a skydiving instructor at Altitude Express. He was fired after disclosing his sexual orientation to a female client to alleviate her concerns about being strapped to a male instructor. Following a complaint from the client alleging inappropriate behavior, Zarda was terminated. He claimed that his firing was due to his sexual orientation and failure to conform to gender stereotypes, leading him to file a discrimination charge with the EEOC and subsequently a lawsuit.

In the summer of 2010, Donald Zarda, a gay man, worked as a sky-diving instructor at Altitude Express. … Zarda denied inappropriately touching the client and insisted he was fired solely because of his reference to his sexual orientation.

Issue

Whether Title VII of the Civil Rights Act of 1964 prohibits discrimination based on sexual orientation.

The question of whether Title VII applied to sexual orientation discrimination would not constitute advisory opinion.

Rule

Sexual orientation discrimination is motivated, at least in part, by sex and is thus a subset of sex discrimination for purposes of Title VII.

Analysis

The court analyzed the text of Title VII and concluded that discrimination based on sexual orientation inherently involves considerations of sex. It reasoned that sexual orientation cannot be defined without reference to the sex of the individual and the sex of those to whom they are attracted. The court overruled previous cases that held otherwise, emphasizing that sexual orientation discrimination is a form of sex discrimination.

We now conclude that sexual orientation discrimination is motivated, at least in part, by sex and is thus a subset of sex discrimination.

Conclusion

The court affirmed the district court's judgment in part, vacated it in part regarding Zarda's Title VII claim, and remanded the case for further proceedings consistent with its opinion.

We therefore VACATE the district court's judgment on Zarda's Title VII claim and REMAND for further proceedings consistent with this opinion.

Who won?

The employer prevailed in the initial trial regarding the state law claim, as the jury found no discrimination based on sexual orientation.

Defendants prevailed in the trial regarding Zarda's state law claim, as the jury found that they had not discriminated based on sexual orientation.

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