Background:

In Christiansen v. Omnicom Group, Inc., a gay male employee alleged that his supervisor described him as “effeminate” to others and depicted him as a “submissive sissy,” among other things. In Evans v. Georgia Regional Hospital, a lesbian employee alleged that, because she presented herself in a masculine manner through her dress and grooming, she was denied equal pay and promotion, harassed, assaulted and forced to resign. Each of them sued their employer, claiming sexual orientation discrimination under Title VII.