The 11th U.S. Circuit Court of Appeals has upheld a lower court’s ruling that a Georgia county discriminated against a sheriff’s deputy by failing to pay for her gender-affirming surgery. The court determined that a health insurance provider can be held liable under the Civil Rights Act of 1964 for denying coverage for a procedure because an employee is transgender. Sgt. Anna Lange, an investigator for the Houston County sheriff’s office, sued Sheriff Cullen Talton and the county in 2019 after being denied coverage. Lange expressed her disappointment in the county’s actions, stating that it has been painful to have valuable resources used to deny her basic health care. She was represented by the Transgender Legal Defense and Education Fund.
U.S. District Court Judge Marc Treadwell ruled in 2022 that the county’s refusal to cover Lange’s prescribed gender-affirmation surgery constituted illegal sex discrimination under the Civil Rights Act of 1964. This decision was based on the U.S. Supreme Court’s 2020 ruling that a Michigan funeral home could not fire an employee for being transgender. Treadwell ordered the county’s insurance plan to pay for the surgery, which Lange eventually underwent. In 2022, a jury awarded Lange $60,000 in damages as a result of the discrimination she faced. The county attempted to reverse Treadwell’s order and the damage award, but the appeals court upheld the lower court’s ruling.
Title VII of the Civil Rights Act of 1964 prohibits employers from discriminating against individuals based on factors such as race, color, religion, sex, or national origin. The 11th Circuit opinion referenced the Supreme Court’s clarification in a Georgia case that discrimination against someone for being transgender inherently involves discrimination based on sex. This legal precedent played a significant role in the appeals court’s decision to support the lower court’s ruling in Lange’s case. The outcome of this case sets a precedent for future instances where individuals are denied coverage for gender-affirming procedures due to their transgender identity.
The legal battle surrounding Sgt. Anna Lange’s gender-affirming surgery sheds light on the importance of protecting the rights of transgender individuals in the workplace. By affirming that denying coverage for such procedures constitutes illegal sex discrimination, the courts are sending a clear message that employees should not face discrimination based on their gender identity. The ruling in this case highlights the ongoing need for greater awareness and understanding of the rights of transgender individuals and the importance of ensuring that they are treated fairly and equally in all aspects of society, including access to healthcare.
The decision by the 11th U.S. Circuit Court of Appeals to uphold the lower court’s ruling in favor of Sgt. Anna Lange represents a significant victory for the rights of transgender individuals in the workplace. By holding the county accountable for discriminating against Lange based on her gender identity, the court has sent a strong message that such actions are not permissible under the law. This ruling serves as a beacon of hope for other transgender individuals who may face similar challenges in seeking gender-affirming healthcare and reinforces the importance of upholding the civil rights of all individuals, regardless of their gender identity.
Overall, the outcome of this case underscores the need for continued progress in advancing equality and protecting the rights of transgender individuals. By upholding the principle that denying coverage for gender-affirming procedures constitutes sex discrimination under the Civil Rights Act of 1964, the courts have taken a significant step forward in ensuring that all individuals are afforded equal opportunities and rights in the workplace. This ruling sets a precedent for future cases involving discrimination against transgender individuals and underscores the importance of upholding the principles of equality and fairness for all members of society.
