Transgender Discrimination Court Update: Creed
Transworkplace03/19/2008
"A search of the Westlaw database reveals a few interesting developments in transgender discrimination law. In this post, I will discuss Creed v. Family Express Corp, 2007 WL 2265630 (N.D.Ind. 2007), a decision of the federal district court for the Northern District of Indiana, issued August 3, 2007. The decision, unfortunately, portends more confusion for employers, rather than less. This court is in the circuit that handed down the opinion in Ulane v. Eastern Airlines, Inc., 742 F.2d 1081 (7th Cir.1984), which held that Title VII does not cover transsexuals. The continuing vitality of Ulane has been questioned recently by some courts, in light of Supreme Court decisions that have broadened the scope of Title VII sex discrimination."