11th Circuit Finds Title VII Does Not Protect Against Sexual Orientation Bias

The 11th Circuit in Evans v. Georgia Regional Hospital, Case No. 4:15-cv-00103-JRH-GRS (March 10, 2017) finds that Title VII doesn’t protect sexual orientation bias. This is in contrast to the EEOC’s interpretation, which is stated on its website as: “While Title VII of the Civil Rights Act of 1964 does not explicitly include sexual orientation or gender identity in its list of protected bases, the Commission, consistent with Supreme Court case law holding that employment actions motivated by gender stereotyping are unlawful sex discrimination and other court decisions, interprets the statute’s sex discrimination provision as prohibiting discrimination against employees on the basis of sexual orientation and gender identity.”