Category: Discrimination

Second Circuit Title VII Sexual Orientation Discrimination

Second Circuit Says Title VII Prohibits Sexual Orientation Discrimination

On February 26, 2018, the U.S. Court of Appeals for the Second Circuit ruled that federal law prohibits employment discrimination based on sexual orientation. Title VII of the Civil Rights Act of 1964 outlaws workplace discrimination because of “race, color, religion, sex, or national origin”. Unlike many state statutes, it does not specifically address sexual orientation discrimination.

In this ruling, the Second Circuit concludes that Title VII’s protection of “sex” encompasses sexual orientation. The decision establishes binding authority throughout New York, Connecticut, and Vermont.  The court overruled its earlier decisions where it held that Title VII did not prohibit sexual orientation discrimination.

What Is Sex?

In reaching its decision, the court assumed that “sex,” as used in Title VII, means “biologically male or female.”

The Second Circuit referenced its earlier stated, and often applied, position that “Title VII should be interpreted broadly to achieve equal employment opportunity”. It noted that Congress’ intent was to make sex irrelevant to employment decisions. And that the Supreme Court has found Title VII to apply not just to sex itself, but also to traits such as life expectancy and non-conformity with gender norms.

According to the court:

“Because one cannot fully define a person’s sexual orientation without identifying his or her sex, sexual orientation is a function of sex. Indeed sexual orientation is doubly delineated by sex because it is a function of both a person’s sex and the sex of those to whom he or she is attracted.”

In sum, the court wrote: “We now conclude that sexual orientation discrimination is motivated, at least in part, by sex and is thus a subset of sex discrimination.”

Other Recent Court Decisions on Sexual Orientation Discrimination

For 50 years, the U.S. Equal Employment Opportunity Commission (EEOC) had not formally enforced Title VII’s reference to “sex” to include “sexual orientation.” During that time, most courts similarly read Title VII to not cover sexual orientation.

In 2015 the EEOC first ruled that “sexual orientation is inherently a ‘sex‐based consideration;’ accordingly an allegation of discrimination based on sexual orientation is necessarily an allegation of sex discrimination under Title VII.” The Second Circuit is the third federal appeals court to consider the question since that EEOC ruling.

In March 2017, the U.S. Court of Appeals for the Eleventh Circuit declined to recognize sexual orientation claims under Title VII. The Eleventh Circuit covers Alabama, Florida, and Georgia.

Then, in April 2017, the U.S. Court of Appeals for the Seventh Circuit reversed its earlier position and found that “discrimination on the basis of sexual orientation is a form of sex discrimination”. The Seventh Circuit covers Illinois, Indiana, and Wisconsin.

Immediate Impact

For now, employers within Connecticut, New York, and Vermont must assume that Title VII prohibits them from discriminating based on sexual orientation. On a day-to-day basis, this should not be a significant development. State law in each of these states already prohibits sexual orientation discrimination in employment. However, the ruling opens up additional procedural options for employees claiming this form of discrimination. And additional remedies may be available to them under Title VII.

Will This Decision Stand?

Probably not.

Even the Executive Branch of the federal Government disagrees about the right outcome. The EEOC continued to support the plaintiff in this case. However, the Justice Department pressed the Second Circuit not to find Title VII to prohibit sexual orientation discrimination. Several other interested constituents submitted third-party briefs.

Notably, the Second Circuit’s decision was not unanimous. Eight judges issued written opinions. Three of the 13 judges dissented to at least some parts of the majority opinion.

As of now, it seems likely that the defendant employer will ask the U.S. Supreme Court to review the Second Circuit’s decision. With competing interpretations between the Circuit Courts, it would not be surprising for the Supreme Court to take this case of high public interest.

With an apparent 5-4 conservative majority, the Supreme Court may well take the historical approach of rejecting claims of sexual orientation discrimination under Title VII.

The Second Circuit’s full decision in Zarda v. Altitude Express, Inc., is available here.

Executive Order 11246 - Affirmative Action

What Is Executive Order 11246?

Executive Order 11246 LBJ
Lyndon B. Johnson,
36th U.S. President

On September 24, 1965, President Lyndon B. Johnson signed Executive Order 11246, which continues to impose anti-discrimination and affirmative action requirements upon federal contractors.

The Executive Order came just a year after Congress enacted (and President Johnson signed into law) the Civil Rights Act of 1964. Title VII of that act created the first national employment discrimination protections based on race, sex, color, national origin, and religion.

Although Johnson’s executive order is the one still cited for its administrative action requirements, its impact isn’t all because of him. A number of U.S. Presidents have contributed to these legal obligations on federal contractors over the year.

What It Does

Executive Order 11246 covers federal contractors who do over $10,000 in government business in a year. It essentially has two basic functions (as amended):

  1. Prohibits discrimination in employment based on race, color, religion, sex, or national origin.
  2. Requires affirmative action to ensure that equal opportunity is provided in all aspects of employment.

In addition, contractors with over 50 employees and a contract of at least $50,000 must prepare written affirmative action plans. The Office of Federal Contract Compliance (OFCCP) may audit contractors to review compliance with the affirmative action requirements.

Covered contractors who do not satisfy the affirmative action requirements face many possible penalties. These can include pay awards, notices of violations, enhanced government oversight, loss of contracts, and negative publicity.

History Leading to Executive Order 11246

Executive Order 11246 was not the first Presidential action prohibiting employment discrimination.

On June 25, 1941, President Franklin D. Roosevelt outlawed discrimination based on race, color, creed, and national origin in the federal government and defense industries through Executive Order 8802. In 1943, FDR extended Executive Order 8802 to federal contractors in Executive Order 9346.

Later, Presidents Truman and Eisenhower created a Committee on Government Contract Compliance and then the President’s Committee on Government Contracts, respectively. These committees oversaw compliance by federal contractors with the non–discrimination provisions of Executive Order 8802.

On March 6, 1961, President John F. Kennedy signed Executive Order 10925. This Executive Order required government contractors to “take affirmative action to ensure that applicants are employed, and that employees are treated during employment, without regard to their race, creed, color or national origin.” It also created the President’s Committee on Equal Employment Opportunity, which became the Equal Employment Opportunity Commission (EEOC) under the Civil Rights Act of 1964.

Executive Order 10925

Johnson’s Executive Order 11246’s primary contribution was to make the U.S. Secretary of Labor responsible for administering the pre-existing non-discrimination and affirmative action provisions.

Later Modifications

On October 5, 1978, President Jimmy Carter consolidated all affirmative action enforcement actions under the U.S. Department of Labor through Executive Order 12086.

On December 12, 2002, President Bush amended Executive Order 11246 to allow religiously affiliated contractors to prefer individuals of a particular religion when making employment decisions relevant to the work connected with its activities. (Executive Order 13279)

Barack Obama Executive Order 11246 Amendments
Barack Obama,
44th U.S. President

President Obama most recently amended Executive Order 11246 in 2014.

In Executive Order 13665, he prohibited retaliation by federal contractors against employees or applicants who inquire about, discuss, or disclose details of their own or other employees’ or applicants’ compensation.

In Executive Order 13672, President Obama prohibited covered contractors from discriminating based on sexual orientation or gender identity.

Status Under the Trump Administration

With the shift from a Democratic to Republican White House, many questioned the impact on Executive Order 11246. Especially the Obama-era amendments.

On January 31, 2017, President Trump’s administration released a statement that Trump would not rescind Executive Order 13672 (which added sexual orientation and gender identity). However, he did rescind Obama’s companion Executive Order 13673. It had required companies seeking federal contracts to report violations of various federal laws. A federal judge had temporarily enjoined Executive Order 13673. Trump’s action mooted any further challenge to the injunction.

November 2020 Update: A return to a Democratic administration under Joe Biden will likely restore the sexual orientation and gender identity provisions that President Obama added.

Does Executive Order 11246 Cover Your Business?

Employers must know whether they are subject to Executive Order 11246, but many do not. It is a bad day when you receive an audit letter from the OFCCP. It’s much worse when you don’t have the necessary records or an affirmative action plan in place. Businesses with over 50 employees must especially confirm whether they have federal contracts that would trigger affirmative action requirements.

If your organization has any government contracts and hasn’t evaluated the impact on employment practices, now is the time to do so. Whether, and the extent to which, Executive Order 11246 applies is not always an easy question. Employers uncertain of coverage should consult with an attorney experienced with this executive order and other laws that impose affirmative action requirements.

 

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Legal Risks of Social Media in Hiring Webinar Cover

Legal Risks of Social Media in Hiring (Webinar)

On February 15, 2018, I presented a complimentary webinar on Legal Risks of Social Media in Hiring. For those who couldn’t attend the live webinar, I’m happy to make it available for you to watch at your convenience.

In the webinar, I discuss the recent legal challenges to using social media in hiring, such as:

  • Facebook Ad Discrimination
  • Background Check Requirements
  • Federal Contractor Affirmative Action Programs

I also describe employer obligations and best practices related to:

  • How Laws About Genetic Information Apply to Online Research of Job Candidates
  • Recordkeeping Requirements
  • Screening Applicants Through Social Media

Don’t have time to watch the whole webinar right now? Click here to download the slides from the webinar.

Why You Should Watch This Webinar

Social media has become ubiquitous. Just about every organization uses social media in some way in connection with hiring new employees. Either in recruiting candidates in the first place or reviewing applicants under consideration for hire.  However, there is a surprising amount of legal regulations that may affect these practices. Recent lawsuits and compliance efforts by regulatory authorities demonstrate that employers should take appropriate precautions to avoid and be positioned to defend claims by unsuccessful applicants.

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