# Presentation: 538289

## Equal Opportunity for Transgender People 

**September 12, 2007**
**2007 National Equal Opportunity Professional Development Forum**
- Presenter: Lisa Mottet (lmottet@thetaskforce.org)

**Notes:**
WSHRC Executive Director does a welcome

Must figure out that everyone can hear us and everyone has the powerpoint and the exercise worksheets

Must figure out how many different places people are calling in from

When ready: “Lets go to our first slide”

## Presenter

Lisa Mottet, Esq.
Legislative Lawyer, Transgender Civil Rights Project
National Gay and Lesbian Task Force
202.639.6308  
lmottet@thetaskforce.org

**Lisa Mottet, Esq.**
- Legislative Lawyer, Transgender Civil Rights Project
- National Gay and Lesbian Task Force
- 202.639.6308
- lmottet@thetaskforce.org

**Notes:**
Each give our own bio. Say we are happy to be here and thank you for inviting us. Being thoughtful about implementing these laws is very good – something that not every state does.

Lisa Mottet is the Legislative Lawyer for the Transgender Civil Rights Project of the National Gay and Lesbian Task Force (“the Task Force”) based in Washington, DC. She has spent five years working to pass non-discrimination laws on the local, state and national level that prohibit discrimination on the basis of gender identity or expression. She has also assisted numerous jurisdictions with interpretation and implementation of these laws. She co-wrote “Transition Our Shelters: A Guide to Making Homeless Shelters Safe for Transgender People,” a joint publication of the Task Force and the National Coalition for the Homeless. 

Cole Thaler is a staff attorney for transgender rights at Lambda Legal, a national organization devoted to securing equal rights and protections for lesbian, gay, bisexual and transgender people under the law. Cole works in Lambda’s Atlanta, GA office, but works on litigation and policy in all regions of the country. 

## Agenda

**Welcome and Overview**
**Transgender 101 in the Workplace **
**Nondiscrimination Laws**
**Nondiscriminatory Workplace Policies**
**Questions/Comments**

**Notes:**
Just go through this. 
We do have a lot of cover today so we ask your help with staying on track.
The exercises are fun and we hope they will make up at least half of the training. 

## Overview

***Session Objectives***
*Understand what issues you may face as and EO professional working with transgender employees, applicants, and trainees*
*Understand the law with regard to transgender people in the workplace*
*Understand policies that will ensure that transgender people are treated in a nondiscriminatory manner*

**Notes:**
Logistics
Seems everyone has the materials. Please don’t look ahead for them.
We plan to do a bathroom/stretching break about halfway through.
For the exercises, we are going to have different places respond to different scenarios, and folks who have people with them at their location should work in pairs or groups of 3.
As far as questions, to stay on track, please interrupt us only with clarifying questions. For substantive questions or comments, lets hold them until the end of each section.

Today’s objective:
New law has gone into effect. Washington is part of the 31% of the country that has a transgender-inclusive non-discrimination law. Good news – has gone very well.
However, enforcing this new law will not entirely the same as enforcing the law protecting other characteristics.
Generally, the same principles one uses to handle other complaints can be used, but there are some complexities with sexual orientation and gender expression and identity and this training is geared to prepare you to deal with these. Specifically, we find that the transgender aspect of the law is most unfamiliar, and we are focusing on this aspect.
Note that we know a lot about statutory and judicial protections for transgender people, but we are not experts in investigation procedures, so we may not know the exact procedure to be followed in every situation. Our goal is to provide the principles that people can follow in complex factual situations.

NOT COVERING TODAY
Not covering who lesbian, gay, bisexual and transgender people are – Marsha Botzer covered this in a previous training, and we provide resources at the end. We will give the shortest of reviews, but that is all.
Not going into detail about which areas (e.g. employment, public accommodations, real estate transactions, credit transactions, and insurance transactions) are covered by the law – we will assume that you know how to recognize them.
Not covering how to deal with classic discrimination – “You are fired because you are gay or transgender,” or “You cannot eat at this restaurant because you are gay or transgender.”  We can think of those as “smoking gun” discrimination – where there is evidence that a person’s sexual orientation or gender identity or gender expression caused the discriminatory conduct. We think you will not have difficulty in applying the law in those cases. 

## Defining Terms

**Transgender **is an “umbrella” term used to describe a wide range of identities and experiences, and is used to refer to many types of people, including transsexual people; crossdressers; androgynous people; genderqueers; and other gender non-conforming people whose appearance or characteristics are perceived to be gender atypical.
- In its broadest sense, “transgender” encompasses anyone whose identity or behavior falls outside stereotypical gender expectations.

## Gender Identity or Expression

- Gender identity
- One’s internal feeling of being male or female or something along those lines
- Gender expression
- social and behavioral characteristics culturally associated with maleness and femaleness

## Gender Transition

**Gender transition is the process by which transgender people move towards living in the gender they identify as.**
- Some have medical treatment, most do not
- Identification documents are not always changed
**Gender transition at work happens in different ways.**
- Common to tell one’s supervisor first and develop a timeline
- Others start presenting in a more masculine or feminine way and coworkers notice
**Transgender experiences are different, but often very difficult.**
- Depending on a person’s economic and other resources, discrimination against them can cause a spiral of other problems.

**Notes:**
Simply put, gender transition is the process by which transgender people move towards living in their correct gender identity. 
Some people undergo medical treatments, like hormone therapy and one or more surgeries, but others do not – either because they can’t, don’t want to, or they can’t afford it.  Some transgender people are diagnosed with Gender Identity Disorder, a mental health condition that is listed in the DSM-IV.  However, whether or not someone has been diagnosed with GID does not have any bearing on whether or not they are “actually” transgender.  The same is true about medical treatments.
Many transgender people try to change their name and sex on documentation like driver’s licenses, but they are not always able to do that based on the standards (such as surgery completion) for doing that, or lack of economic resources. Even those who have surgeries can find it difficult, or impossible, to get all of one’s documentation up to date. 
And, there is always a historical record of the person’s old name and gender. 
Gender transition at work – One common process is to tell one’s supervisor and set a timeline for telling coworkers, and when the employee will begin to present in the new gender. Sometimes supportive employers will bring in trainers. 
However, transition at work is not always done this way. Sometimes a person will start presenting in a more masculine or feminine manner, and then coworkers notice changes.  
***Regardless of how the gender identity or expression of a person is discovered, people are still covered by the law
The last point we want to make is that discrimination throughout a person’s life often causes a spiral of different problems: lack of health care, poverty, homelessness, increased risk of incarceration. For people who start out life with less economic resources, or deal with discrimination because of race, or they speak English as a second language, have a physical disability, etc., the world seems stacked against them meeting their basic needs: food and shelter.

## Sexual Orientation and Gender Identity/Expression are Different

- Sexual orientation refers to the relative genders of the partners
- heterosexual
- gay or lesbian
- bisexual
- Transgender people can have any sexual orientation
- Transgender is not a sexual orientation, it is a gender identity

## Relevant Discrimination Laws

**Case law**
- Federal: Title VII’s and Title IX’s sex discrimination prohibitions
- State: sex and disability discrimination prohibitions
**Clear statues with gender identity/expression****:**
- State: 13 states and the District of Columbia
- Local: 92 cities and counties
- Overall, 37% of the population of the US lives in a jurisdiction with clear statutory protections for transgender people

## Federal Laws

- Title VII of the Civil Rights Act of 1964
- Title IX of the Education Amendments of 1972
-     Case law interpreting “sex” is primarily under Title VII, however, courts import Title VII analysis into Title IX, therefore it is wise to assume the same interpretations will apply under Title IX

## Title VII Case Law

- Courts rejected claims by transgender plaintiffs in the 1970s and 1980s
- Price Waterhouse v. Hopkins (1989 Supreme Court case) recognized “sex stereotyping” claims; and Oncale v. Sundowner Offshore Services recognized a plain language interpretation of sex discrimination
- Gradually, federal courts have recognized that transgender people can bring complaints either as “sex stereotyping” claims or as plain sex discrimination
- Federal courts are now mixed, but there have been two strong wins in the last couple of years

## Title VII Case Law, continued

**Smith v. City of Salem**
-   	A firefighter living as a male (but intending to transition to female imminently) was harassed by coworkers for her increasingly feminine appearance. After speaking with a supervisor about the harassment and her intention to transition, she was suspended from work. Relying on *Price Waterhouse*, the 6th Circuit held that discrimination on the basis of Smith’s feminine appearance was illegal sex stereotyping. The court, referring to cases in the 70s and 80s that interpreted Title VII less inclusively, explained that the approach taken in those cases “has been eviscerated by *Price Waterhouse.” 378 F.3d 566 (6th Cir. 2004)*

## Title VII Case Law, continued

**Schroer** **v. Billington**
- 	Diane Schroer was offered a job as a terrorism analyst at the Library of Congress. She interviewed as Dave because she hadn’t formally transitioned from male-to-female. After getting the offer, she asked her new boss if she could start work as a woman to make a clean transition. The job offer was revoked, with the employer saying she wasn’t a “good fit” and she sued. The D.C. Circuit denied a motion to dismiss explaining that she may be the victim of sex discrimination. 424 F. Supp. 2d 203 (D.D.C. 2006).

## State Case and Administrative Law

- A New York court held that transsexuals were protected under New York State laws banning sex discrimination. Rentos v. Oce-Office Systems, 1996 W.L. 737125 (S.D.N.Y. 1996)
- The Connecticut Commission on Human Rights and Opportunities made a declaratory ruling that Connecticut state laws banning sex discrimination also protect transgender individuals. Commission on Human Rights and Opportunities: Declaratory ruling on behalf of John/Jane Doe.

**Courts or administrative agencies in several states have now ruled that existing state laws banning sex or disability discrimination protect transgender people:**

**Notes:**
A New York case held that transsexuals were protected under New York State laws banning sex discrimination. Rentos v. Oce-Office Systems, 1996 W.L. 737125 (S.D.N.Y. 1996)  
The Connecticut Commission on Human Rights and Opportunities made a declaratory ruling that Connecticut state laws banning sex discrimination also protect transgender individuals. Commission on Human Rights and Opportunities: Declaratory ruling on behalf of John/Jane Doe.

## State Case and Admin. Law, continued

- In Massachusetts, a trial court issued an injunction against a school, ordering the school to allow a male-to-female transgender youth to dress in female attire. Doe v. Yunits, 2000 Mass. Super. LEXIS 491, 18. In an administrative ruling, the Massachusetts Commission Against Discrimination held that, unlike the federal ADA, the Massachusetts law on disability discrimination does not exclude transsexuality from coverage. Jette v. Honey Farms Mini Market, 2001 Mass. Comm. Discrim. Lexis 50.
- In Florida, an administrative agency ruled that a transgender corrections officer was protected under the state’s disability anti-discrimination law and that the absence of transsexualism was not a bona fide occupational qualification for a corrections officer. Smith v. Jacksonville Correctional Institution, 1991 Fla. Div. Adm. Hear. LEXIS 5990.

**Notes:**
Jette v. Honey Farms Mini Market, 2001 Mass. Comm. Discrim. Lexis 50 (holding that unlike the federal Americans with Disabilities Act, the Massachusetts law on disability discrimination does not exclude transsexuality from coverage); 
Smith v. Jacksonville Correctional Institution, 1991 Fla. Div. Adm. Hear. LEXIS 5990 (holding that a transgender corrections officer was protected under the state’s disability anti-discrimination law and that the absence of transsexualism was not a bona fide occupational qualification for a corrections officer).

## Clear Statutory Provisions: States

**California**
**Colorado** **
**D.C**
**Hawaii****# **
**Illinois**
**Iowa****
**Maine**
**Minnesota**
**New Jersey**

** ****New Mexico**
** ****Oregon****
** ****Rhode Island**
** ****Vermont** **
** ****Washington**

- ** Protections added in 2007. Oregon’s goes into effect in 2008.

- # Hawaii’s law covers housing and public accommodations only

## Examples of State Statutory Language

- Rhode Island Gen. Laws § 11-24-2.1(l): The term “gender identity or expression” includes a person’s actual or perceived gender, as well as a person’s gender identity, gender-related self image, gender-related appearance, or gender-related expression; whether or not that gender identity, gender-related self image, gender-related appearance, or gender-related expression is different from that traditionally associated with the person’s sex at birth.
- D.C. Code § 2-1401.02(12A)"Gender identity or expression" means a gender-related identity, appearance, expression, or behavior of an individual, regardless of the individual's assigned sex at birth.
- Maine ST T. 5 § 4553(9-C): “Sexual orientation” means a person’s actual or perceived heterosexuality, bisexuality, homosexuality or gender identity or expression.

## Clear Statutory Provisions: Local

- 92 cities and counties, including:
- Toledo, OH
- Covington, KY
- New Orleans, LA
- Baltimore, MD
- Dallas, TX
- Lansing, MI
- Scranton, PA

**Notes:**
Albany, NY
Allentown, PA
Ann Arbor, MI 
Atlanta, GA
Austin, TX
Baltimore, MD
Beaverton, OR
Bend, OR
Benton County, OR 
Bloomington, IN
Boston, MA
Boulder, CO 
Buffalo, NY
Burien, WA
Cambridge, MA 
Carbondale, IL
Champaign, IL
Chicago, IL
Cook County, IL
Cincinnati, OH
Covington, KY
Dallas, TX
Decatur, IL
Decorah, IADeKalb, IL 
Denver, CO 
East Lansing, MI
Easton, PA
El Paso, TX
Erie County, PA
Evanston, IL 
Ferndale, MI
Grand Rapids, MI
Gulfport, FL
Harrisburg, PA
Hillsboro, OR
Huntington Woods, MI
Iowa City, IA
Indianapolis, IN
Ithaca, NY
Jefferson County, KY
Johnson County, IA
Key West, FL
King County, WA
Lake Oswego, OR
Lake Worth, FL
Lansdowne, PALansing, MI
Lexington-Fayette County, KY
Lincoln City, OR
Los Angeles, CA
Louisville, KY
Madison, WI 
Miami Beach, FL
Minneapolis, MN
Monroe County, FL
Multnomah County, OR
New Hope, PA
New Orleans, LA 
New York, NY
Northampton, MA
Oakland, CA
Olympia, WA 
Peoria, IL
Philadelphia, PA 
Pittsburgh, PA 
Portland, OR
Rochester, NY 
St. Paul, MN
Salem, OR
San Diego, CA
Santa Cruz County, CA
Santa Cruz, CA
Saugatuck, MI
Scranton, PA
Seattle, WA
Springfield, IL
Suffolk County, NY 
Swarthmore, PA
Tacoma, WA
Toledo, OH
Tompkins County, NY
Tucson, AZ
Urbana, IL
University City, MO
Toledo, OH
West Chester, PA 
West Palm Beach, FL 
West Hollywood, CA York, PA
Ypsilanti, MI 

## So, it is the law...	

- Now what?

## Next step: Design Nondiscriminatory Policies

- This is easier done than most think it would be
- Regardless of whether there is clear statute requiring a program/workplace to be transgender friendly, there are other reasons to adopt these policies:
- Recruitment/retention of trained workers
- An environment of fairness equals good morale
- Improves productivity of employees in two ways: 1) transgender workers who can focus on work instead of worrying and 2) non-transgender employees can focus on work on not controversy

## Situations Needing Policy Solutions

- Restrooms
- Harassment and Hostile Environment
- Male/Female Boxes, Identification Cards, Background/Credit Checks, and Security Checks
- Gender-Specific Housing
- Showers and Locker Rooms
- Dress Standards

**Notes:**
There are several types of situations in which transgender people have a heightened vulnerability to discrimination. We are going to quickly go through the 6 main areas.

Talking to the investigator in at the SF HRC, 90% of them fit in 1 and 2. He is a great resource by the way.

We are going to go through each of these areas and give an overview of what typically happens and what discrimination looks like in this situation. Then we will take a break and put these concepts into practice by doing scenarios together.  

But first, we are going to go through the principles that will help figure out the answer to our “less blatant situations.”

## Three principles to follow:

- Recognize self identity, regardless of surgery and documentation.
- Ask yourself – **is the person’s gender identity and expression being recognized in this situation?**
- Understand and apply the concept of reasonable accommodation.
- Ask yourself – **is this a situation where the typical policies or procedures are resulting in a transgender person having to unfairly endure difficult or different conditions at work?**
- Biases of customers or coworkers are not a valid reason for discrimination.
- Ask yourself – **is this a situation where an entity is trying to accommodate the biases, or lack of comfort with transgender people, of customers or others?**

**Notes:**
1. Recognize self identity, regardless of surgery and documentation. Not recognizing a person’s gender identity or expression and treating them based on their sex assigned at birth is discrimination. Ask yourself – is the person’s gender identity and expression being recognized in this situation?
2. Understand and apply the concept of reasonable accommodation, which is a helpful concept drawn from disability discrimination law. Especially during transition, reasonable accommodations are sometimes necessary. The principle of reasonable accommodation grew out of the realization by courts that applying the same rules, or providing the same conditions to everyone (like a staircase), sometimes causes discrimination to happen (preventing some people from going to work). Ask yourself, is this a situation where the typical policies or procedures are resulting in a transgender person having to unfairly endure difficult or different conditions at work?
3. Biases of customers or coworkers are not a valid reason for discrimination. In case law with regard to other characteristics, it doesn’t matter if customers prefer to have female flight attendants or white sales clerks. Same is true with LGBT people. Ask yourself, is this a situation where an entity is trying to accommodate the biases, or lack of comfort with transgender people, of customers or others?

## Restrooms

- Sometimes coworkers object to going to the same bathroom with a transgender person.
- People should use the bathroom that matches their gender identity.
- This is significantly less of an issue than people think it is. Employees will take the lead of management: if management declares this policy, people will follow.
- Also helpful is an attitude that indicates that this is “no big deal.”

**Notes:**
The good news is that it isn’t really that hard.  
Sometimes co-workers or other patrons object to sharing the restroom with a transgender person. 
And then the transgender person is told that they must use the bathroom that matches the sex that they were assigned at birth, or they can use the appropriate bathroom only when they have had genital surgery.  Sometimes, a transgender person is asked to use a 3rd bathroom – in one case I know of, a transgender woman is being asked to use a port a john that they installed for her.
The supposed reasoning behind these policies is often that women are in physical danger if a transgender person is in the bathroom with them.  Usually, the fear of is a transgender woman who has not had genital surgery.  This irrational fear is rooted both in sexism (the myth that people socialized as men won’t be able to “control themselves” around women) and heterosexism (the myth that people socialized as men are sexually attracted to women).  It is less common for people to be afraid of transgender men in the bathroom, but transgender men are still vulnerable to hostility, harassment and violence. It is important to remember that it is the transgender person who most often faces the potential of harassment and violence in the bathroom. And, in no places that we are aware of have these laws led to assault of non-transgender people by transgender people in the bathroom. 
The basic rule is this: A transgender person should be granted use of the restroom which corresponds to his or her gender identity.  This rule should apply regardless of the amount of surgery or other medical treatment a person has or has not had. 
Other points on bathrooms:
 - Coworkers may need to be educated or trained on why this rule is appropriate and why it is not a threat to them.
- Nearly all restrooms are constructed so that bodily privacy is not a legitimate concern. If for some reason facilities are not constructed in a way that preserves bodily privacy, this can often be fixed by placing partial or full walls between toilets and partitions between urinals. 
- For example, in cases where understanding cannot be reached with an angry coworker, the coworker could be assigned to a single-use restroom in the building for his or her personal use.
-Sometimes a transgender employee and an employer may agree that it is appropriate for the transgender employee to temporarily use a single-occupancy restroom while they are early in transition.  Even this accommodation might be discriminatory, though, if the transgender employee is pressured into agreeing, and/or the single-occupancy restroom is far away or otherwise has an adverse effect on the terms and conditions of employment. 

## Harassment and Hostile Environment

- Recognize the factors contributing to a hostile environment for a transgender person:
- Refusal to use correct pronouns, or carelessness in never learning to use the correct pronoun
- Refusal to use a person’s preferred name
- Asking excessively personal questions that would be considered inappropriate if asked of non-transgender co-workers
- Discussing coworkers’ personal business behind their backs, including intentionally outing a person

**Notes:**
Transgender people are often subject to harassment by co-workers and managers — much of it direct and overtly vicious – such as name-calling. But there are several ways that co-workers can harass transgender people in a seemingly less direct fashion, which nonetheless results in a hostile work environment.  
These include:
- refusal to use correct pronouns, or carelessness in never learning to use the correct pronoun
- refusal to use a person’s preferred name
- asking excessively personal questions that would be considered inappropriate if asked of non-transgender co-workers, such as questions about surgery, genitals, sexual behavior, etc. (Lisa: I like to say you can ask about other people’s genitals after you have fully described yours and how much you do or do not like them the way they are)
- discussing transgender employees’ personal business behind their backs, including intentionally outing a person as transgender to others to cause them distress 

These things, individually, combined, or combined with other actions can create a hostile work environment. Typically, this should be dealt with like other types of harassment – sexual harassment, religious harassment, etc. 

## Male/Female Boxes, Identification Cards, Background Checks, Security Checks 

- This can come up in many different ways:
- Check-off box for male or female on a job application form
- Filling out an I-9 form, an employer discovers their employee is transgender
- Entering a secure building, a person is asked for identification
- A background check reveals the person’s old name or gender
- A transgender person fills out forms with their current name or gender, even though they may not be “legally changed”
- Solutions:
- Don’t discriminate when transgender status is discovered
- Make allowances for people who earnestly fill out forms or give information that matches their gender identity

**Notes:**
This can come up in many different ways:
Check-off box for male or female on a job application form
Filling out an I-9 form, an employer discovers their employee is transgender
Entering a secure building, a person is asked for identification
A background check reveals the person’s old name or gender
A transgender person fills out forms with their current name or gender, even though they may not be “legally changed”
Solutions: 
1. don’t discriminate when transgender status is discovered, and
2. make allowances for people who earnestly fill out forms or give information that matches their gender identity

## Gender-Specific Housing (possibly issues in Job Corps programs, etc.) 

- Sometimes housing is gender-segregated.
- People should be housed according to their gender identity.
- Harassment should not be tolerated.

**Notes:**
College dorms and homeless shelters generally segregate residents by sex for purposes of sleeping and showering. Domestic violence shelters also generally house only female residents. 

The housing part of this is easy: it is discrimination to house people according to the sex assigned at birth instead of their gender identity. It gets trickier if there are non-private showering options, but that is covered in the next section. 

It is also illegal to tolerate or allow harassment and violence against the transgender resident by other residents. 

## Showers and Locker Rooms

- Reasonable accommodation is the most helpful principle to apply.
- When concerns arise, the best solution is to provide accommodations for private showers and changing areas within the common area.
- There are other options and the inquiry is case-by-case.

**Notes:**
Showers and locker room facilities can be at workplaces, in places of public accommodation like health clubs, or in housing facilities like homeless shelters or dorms.

Facilities with common showers and no private changing areas can be extremely difficult situations for transgender people to negotiate. This is a situation where the reasonable accommodation principle can be very helpful. This means that places should be evaluated on a case-by-case basis to ensure that the transgender person is able to have equal access to the showers/dressing rooms, and ideally, that the trans person is able to use the facility that matches their gender identity.

Usually, trans people are able to negotiate these spaces without causing any discomfort – being undetected.

When concerns arise, the best solution – which works in most places- is to provide accommodations for private showers and changing areas within the common area.  

Other options include:
Staggering shower times to allow a transgender person to use the sex-specific facilities in accordance with his or her gender identity in privacy and safety. 

Sometimes accommodations for private shower and changing area facilities outside of the common area can be made. 

Other points to know with regard to showers:
practically all women’s facilities are designed to allow complete privacy when changing and showering (including in homeless shelters!)
being discovered as transgender in the locker room/when showering can be a very violent situation  [I don’t think we should further the stereotype that men are more violent than women]

## Dress Standards

- Employers would do best to institute dress codes that require neat, clean, well-groomed professional appearance, or gender-neutral uniforms.
- Transgender employees should be permitted to dress in accordance with the gendered dress standard that is appropriate to their gender identity.

**Notes:**
Employers may have written or unwritten gender-based dress standards for their employees.
There have not been court cases that determine how laws prohibiting discrimination on the basis of gender identity and expression affect the application of dress standards to transgender employees.
Dress standards situations should be analyzed following some basic principles:
--Transgender employees should be permitted to dress in accordance with the gendered dress standard that is appropriate to their gender identity.
--Individuals who cross-dress as a malicious prank or joke are not protected under the law.
--Discrimination on the basis of gender expression is prohibited.  While no court has yet analyzed the validity of a gendered dress code in a state with clear gender expression protections, the law does not contain any exception for dress codes.
--Employers who want dress codes would do best to institute dress codes that require neat, clean, well-groomed professional appearance, or gender-neutral uniforms (like khakis and polo shirts).

## Additional Resources

- Feel free to call or email me!
**Cole Thaler**, Transgender Rights Attorney, Lambda Legal, cthaler@lambdalegal.org, (404) 897-1880, ext. 232
**Seth Kirby**, Program Specialist, Washington State Human Rights Commission, _[skirby@hum.wa.gov](mailto:skirby@hum.wa.gov)__, (360) 586-3413_
**Marcus Arana**, Investigator, San Francisco Human Rights Commission, marcus.arana@sfgov.org, (415) 252-2519
_**Transgender Rights**_, edited by Paisley Currah, Richard M. Juang, Shannon Price Minter, University of Minnesota Press, 2006.
**Transitioning Our Shelters: A Guide to Making Homeless Shelters Safe for Transgender People**, National Coalition for the Homeless and National Gay and Lesbian Task Force Policy Institute, 2003, available at http://www.thetaskforce.org/downloads/TransHomeless.pdf