St. John's Law Review

Crossing the Great Sexual Divide: Transsexuals Seeking Redress Under Title VII of the Civil Rights Act of 1964

By: Leah Shams-Molkara

Title VII of the Civil Rights Act of 1964 was meant to address and prevent sex discrimination against males and females in the workplace.  There exists, however, a group of individuals that have been denied the protection of this monumental law.  Those individuals are transsexuals.  Transsexualism is a medically recognized condition where an otherwise physically normal person does not identify with the gender characteristics of their biological sex.  As a result they have a profound desire to become a member of the opposite sex, and many times take the surgical steps to transform themselves physically into their desired sex.

Due to the complex physical and psychological aspects of their medical condition, transsexuals must not only grapple with the symptoms of their disorder, they often become victims of stereotyping, ridicule and dehumanization.  In addition, transsexuals have been denied the full protection of the law.  This is especially true in the area of employment discrimination.

Various federal courts have been reluctant to afford protection specifically to transsexuals under Title VII of the Civil Rights Act for employment discrimination on the basis of sex.  These courts have denied this protection despite recent decisions in yet other courts that have expanded coverage to transsexuals, allowing them legal redress under the less familiar form of “gender discrimination.”  In a recent decision in April 2005, the District of Utah Court stated that transsexualism was a “drastic action” and one that represents a “profound disturbance of the individual’s sense of identity with regard to femaleness and maleness,” thereby marginalizing transsexuals, and denying them protection under the law. 

This Note attempts to tackle the issues faced by transsexuals, and prove that when they are victims of “gender discrimination,” Title VII of the Civil Rights Act is in place to give them the full protection of the law.