Case Summary
**Case Summary: EEOC v. RG and GR Harris Funeral Homes Inc. (Docket No. 6163700)**
**Court:** United States Court of Appeals for the Sixth Circuit
**Date:** The case was decided in 2020.
**Background:**
The Equal Employment Opportunity Commission (EEOC) filed a lawsuit against RG and GR Harris Funeral Homes, Inc., following the termination of Aimee Stephens, a transgender woman who had been employed as a funeral director. Stephens had informed her employer of her intention to transition and asked to dress in accordance with her gender identity. The funeral home, citing its religious beliefs and adherence to traditional gender roles, terminated her employment instead.
**Legal Issues:**
The central issue in this case was whether the termination constituted discrimination based on sex under Title VII of the Civil Rights Act of 1964, which prohibits employment discrimination based on race, color, religion, sex, or national origin. The case primarily explored two legal theories of discrimination:
1. Whether discrimination against an employee because of their gender identity is essentially discrimination "because of sex."
2. The applicability of the Religious Freedom Restoration Act (RFRA) as a defense for the employer's actions.
**Court's Decision:**
The district court ruled in favor of the EEOC, determining that RG and GR Harris Funeral Homes had discriminated against Stephens based on her sex, thus violating Title VII. The court emphasized that discrimination based on gender identity or sexual orientation falls within the ambit of sex discrimination.
On appeal, the Sixth Circuit upheld the lower court's ruling, reaffirming that employment discrimination against transgender individuals is prohibited under federal law. The court also rejected the funeral home’s RFRA defense, concluding that the organization's religious beliefs did not justify the discriminatory treatment of Stephens.
**Significance:**
This case is significant as it established key precedents regarding the interpretation of sex discrimination under Title VII, particularly in the context of gender identity. It underscored the legal protections available for transgender individuals in the workplace and reaffirmed that employment decisions based on gender stereotyping are discriminatory.
**Conclusion:**
The EEOC v. RG and GR Harris Funeral Homes Inc. case highlighted the evolving understanding of workplace discrimination laws in relation to transgender rights, representing a critical development in the protection of LGBTQ+ employees. The ruling confirmed that employers could not invoke religious beliefs as a shield against federal anti-discrimination laws and reinforced the legal framework that seeks to protect individuals from discrimination based on their gender identity.