Employees Gerald Bostock, Donald Zarda, and Aimee Stephens were fired for being homosexual or transgender.
Claims were made under Title VII of the Civil Rights Act of 1964, which prohibits employment discrimination "because of sex."
Circuit Court Decisions:
Eleventh Circuit: Dismissed Bostock's claim, ruling Title VII does not cover sexual orientation.
Second and Sixth Circuits: Allowed Zarda's and Stephens’s claims to proceed, viewing them as sex discrimination.
Supreme Court Holding
The Supreme Court held that firing an individual for being gay or transgender violates Title VII.
Majority Opinion by Justice Gorsuch:
Title VII's reference to discrimination "because of sex" includes sexual orientation and gender identity.
Discrimination based on homosexuality or transgender status requires differential treatment based on sex.
The decision was based on the ordinary public meaning of the statute at the time of enactment.
Intentional discrimination in part due to sex is a violation, regardless of other motivating factors.
Key Legal Reasoning
Title VII Language:
Prohibits discrimination “because of sex,” interpreted to include sexual orientation and gender identity.
Discrimination against homosexual or transgender individuals necessitates a consideration of sex.
Precedents Considered:
Phillips v. Martin Marietta Corp.: Discrimination due to sex plus another factor still violates Title VII.
Los Angeles Dept. of Water and Power v. Manhart: Equal treatment as groups doesn’t negate individual discrimination claims.
Oncale v. Sundowner Offshore Services, Inc.: Same-sex harassment claims are cognizable under Title VII.
Dissenting Opinions
Justice Alito (joined by Justice Thomas):
Criticized the majority for "legislating" from the bench, arguing that "sex" in 1964 referred strictly to biological sex.
Suggested that Congress has repeatedly considered and not passed legislation to explicitly include sexual orientation.
Justice Kavanaugh:
Argued that the majority’s interpretation was against the ordinary public meaning of “because of sex”.
Emphasized that Congress, not the courts, should update Title VII to cover sexual orientation and gender identity.
Implications
The ruling clarifies that Title VII of the Civil Rights Act of 1964 protects employees from discrimination based on sexual orientation and gender identity.
Sets a significant precedent for the interpretation of "sex" in anti-discrimination laws.
Broader Context
This decision reflects ongoing societal changes regarding LGBTQ+ rights and the scope of legal protections against discrimination in the workplace.
The decision and its reasoning could influence interpretations of similar language in other federal or state statutes.
Conclusion
The decision marks a landmark moment in the expansion of civil rights protections for LGBTQ+ individuals in the United States.