ARGUMENT
The Supreme Court’s decision in Bostock v. Clayton County, Georgia, 590 U.S. ____, S. Ct., 2020 WL 3146686 (June 15, 2020) supports the School Board’s arguments as to why the district court should be reversed. As the School Board has argued throughout this case, separating bathrooms on the basis of biological sex (i.e. the real anatomical differences between men and women) – and nothing more – is constitutionally permissible and authorized by Title IX of the Education Amendments of 1972. Importantly, Adams has not argued that the separation of bathrooms based on sex is impermissible; instead, he disagrees with the manner in which the School Board defines sex. But sex, as the Supreme Court has now held, is a “distinct concept” from transgender status. Id. at *11.
Any argument that Bostock lends support to affirming the district court is foreclosed by Adams’ legal counsel’s representations regarding the impact of Bostock at oral argument. Adams’ legal counsel represented, in pertinent part:
We are not persuaded that anything about Harris will add much to the analysis here, because here...Jackson v. Birmingham tells us that Title IX is a vastly different statute and is much broader in many ways. But this case is about a classification that everybody agrees exists on the face of the policy - so analysis from the Supreme Court about how to ferret out discriminatory intent by a decisionmaker - we don’t think that will add much to the analysis here - and this case really turns on whether the pure speculation and conjecture that has been offered by the School Board is adequate to justify this kind of
The Supreme Court’s decision in Bostock v. Clayton County, Georgia, 590 U.S. ____, S. Ct., 2020 WL 3146686 (June 15, 2020) supports the School Board’s arguments as to why the district court should be reversed. As the School Board has argued throughout this case, separating bathrooms on the basis of biological sex (i.e. the real anatomical differences between men and women) – and nothing more – is constitutionally permissible and authorized by Title IX of the Education Amendments of 1972. Importantly, Adams has not argued that the separation of bathrooms based on sex is impermissible; instead, he disagrees with the manner in which the School Board defines sex. But sex, as the Supreme Court has now held, is a “distinct concept” from transgender status. Id. at *11.
Any argument that Bostock lends support to affirming the district court is foreclosed by Adams’ legal counsel’s representations regarding the impact of Bostock at oral argument. Adams’ legal counsel represented, in pertinent part:
We are not persuaded that anything about Harris will add much to the analysis here, because here...Jackson v. Birmingham tells us that Title IX is a vastly different statute and is much broader in many ways. But this case is about a classification that everybody agrees exists on the face of the policy - so analysis from the Supreme Court about how to ferret out discriminatory intent by a decisionmaker - we don’t think that will add much to the analysis here - and this case really turns on whether the pure speculation and conjecture that has been offered by the School Board is adequate to justify this kind of
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profoundly damaging discrimination against transgender students.
***
...all this case is about is that every student should have the right to use the restroom matching their consistently asserted gender identity, including transgender students. That is the right cisgender students have right now. And the question is whether there is an adequate justification to deny that right to transgender students.
Oral argument at 25:45 through 26:28; 22:38 through 22:57.
Surely, the classification in this case draws lines based on sex. But the
question is not, as the district court posed, whether Adams is a boy and therefore should be able to use the boys’ bathroom. The question is whether classifying individuals for purposes of using the bathroom in schools on a definition of sex founded in the biological and physiological differences between boys and girls is actionable discrimination. Bostock’s recognition that sex is distinct from transgender status warrants reversal of the district court’s order. Unless this Court accepts Adams’ invitation to define the term “sex” in contradiction to Supreme Court precedent, the School Board’s argument carries the day.
I. The Bostock Decision
The Supreme Court in Bostock held that “[a]n employer who fires an individual for being homosexual or transgender fires that person for traits or actions it would not have questioned in members of a different sex.” Bostock at *3.
***
...all this case is about is that every student should have the right to use the restroom matching their consistently asserted gender identity, including transgender students. That is the right cisgender students have right now. And the question is whether there is an adequate justification to deny that right to transgender students.
Oral argument at 25:45 through 26:28; 22:38 through 22:57.
Surely, the classification in this case draws lines based on sex. But the
question is not, as the district court posed, whether Adams is a boy and therefore should be able to use the boys’ bathroom. The question is whether classifying individuals for purposes of using the bathroom in schools on a definition of sex founded in the biological and physiological differences between boys and girls is actionable discrimination. Bostock’s recognition that sex is distinct from transgender status warrants reversal of the district court’s order. Unless this Court accepts Adams’ invitation to define the term “sex” in contradiction to Supreme Court precedent, the School Board’s argument carries the day.
I. The Bostock Decision
The Supreme Court in Bostock held that “[a]n employer who fires an individual for being homosexual or transgender fires that person for traits or actions it would not have questioned in members of a different sex.” Bostock at *3.
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The Supreme Court expressly declined to extend its reasoning to other statutes that have similar prohibitions against discrimination based on sex, like Title IX, and other scenarios outside of those presented in the case, including the separation of bathrooms based on sex. Id. at *17.
II. Bostock Supports that the School Board’s Policy Does Not Violate Title IX
Similar to Title VII, which prohibits discrimination in the workplace “because of ... sex,” Title IX prohibits discrimination in educational programs and activities “on the basis of sex.” But, unlike Title VII, Title IX permits educational institutions to separate living facilities on the basis of sex, and its implementing regulations permit educational institutions to separate bathrooms, locker rooms and showering facilities on the basis of sex. 20 U.S.C. § 1686; 34 C.F.R. § 106.33. This key distinction between the statutory schemes at play, and the analysis in Bostock, supports reversal of the district court.
In Bostock, the Supreme Court recognized that transgender status is a distinct concept from sex and proceeded in its analysis on the assumption that “sex” referred “only to biological distinctions between male and female.” Bostock at **4, 11. The entirety of the holding, and the reasoning that flows from it, are built on the premise that a woman who identifies as a man—a transgender man—is a woman. This recognition rejects the entirety of the rationale of the district court’s
II. Bostock Supports that the School Board’s Policy Does Not Violate Title IX
Similar to Title VII, which prohibits discrimination in the workplace “because of ... sex,” Title IX prohibits discrimination in educational programs and activities “on the basis of sex.” But, unlike Title VII, Title IX permits educational institutions to separate living facilities on the basis of sex, and its implementing regulations permit educational institutions to separate bathrooms, locker rooms and showering facilities on the basis of sex. 20 U.S.C. § 1686; 34 C.F.R. § 106.33. This key distinction between the statutory schemes at play, and the analysis in Bostock, supports reversal of the district court.
In Bostock, the Supreme Court recognized that transgender status is a distinct concept from sex and proceeded in its analysis on the assumption that “sex” referred “only to biological distinctions between male and female.” Bostock at **4, 11. The entirety of the holding, and the reasoning that flows from it, are built on the premise that a woman who identifies as a man—a transgender man—is a woman. This recognition rejects the entirety of the rationale of the district court’s
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decision which was built on the foundation that the question to decide was simply whether Adams is a boy and thus should be permitted to use the boys’ bathroom.
The Bostock majority reasoned that firing a transgender female because of her transgender status was sex discrimination. Id. at *15. In reaching this conclusion, the Supreme Court offered the following example:
The Bostock majority reasoned that firing a transgender female because of her transgender status was sex discrimination. Id. at *15. In reaching this conclusion, the Supreme Court offered the following example:
Or take an employer who fires a transgender person who was identified as a male at birth but who now identifies as a female. If the employer retains an otherwise identical employee who was identified as female at birth, the employer intentionally penalizes a person identified as male at birth for traits or actions that it tolerates in an employee identified as female at birth. Again, the individual employee's sex plays an unmistakable and impermissible role in the
discharge decision.
Id. at *7. This conclusion can only be reached on a conception of sex founded in biology and not gender identity. Under Bostock’s analysis, it is because the transgender female was a male that the termination was actionable, as the employer penalized a male for traits it would tolerate in females. Id. at *10.
The Bostock decision is fatal to Adams’ argument [Adams Response Brief at p. 46] (“Defendant’s policy excludes Drew from the boys’ bathroom on his transgender status”) and crumbles the foundation of the district court’s decision. Again, the district court’s decision was founded on the conclusion that Title IX’s use of the term “sex” was ambiguous and that the ambiguity should be resolved in favor of a reading that “sex” includes gender identity. [Doc. 192 at 63]. However,
the term “sex” under Title VII, as interpreted by the Supreme Court, means the 4
The Bostock decision is fatal to Adams’ argument [Adams Response Brief at p. 46] (“Defendant’s policy excludes Drew from the boys’ bathroom on his transgender status”) and crumbles the foundation of the district court’s decision. Again, the district court’s decision was founded on the conclusion that Title IX’s use of the term “sex” was ambiguous and that the ambiguity should be resolved in favor of a reading that “sex” includes gender identity. [Doc. 192 at 63]. However,
the term “sex” under Title VII, as interpreted by the Supreme Court, means the 4
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biological and physiological differences between men and women, which is consistent with the clear and ordinary meaning of the term “sex” when Title IX was enacted a few short years after 1964. [School Board Initial Brief at pp. 34-42].
This is important in the context of the Title IX claim advanced by Adams, because unlike the employers in Bostock who were not permitted to terminate employees because of their sex by the terms of Title VII, the School Board is expressly authorized under Title IX’s implementing regulations to separate bathrooms on the basis of sex. See 34 C.F.R. § 106.33, which states in pertinent part:
A recipient may provide separate toilet, locker room, and shower facilities on the basis of sex, but such facilities provided for students of one sex shall be comparable to such facilities provided for students of the other sex.
(emphasis added). Adams does not dispute that the School Board is allowed to separate bathrooms on the basis of sex and does not argue that sex-separated bathrooms must be abolished. [Adams Answer Brief at p. 52]. Rather, Adams contends that the School Board’s definition of sex to his exclusion from the boys’ bathroom is discriminatory. Essentially, Adams posits that the School Board misclassified him for purposes of bathroom usage in its schools.
But this is not actionable sex discrimination. Instead, the School Board’s policy of separating student bathrooms on the basis of biological sex is legally permissible, because the School Board is authorized under Title IX and its
This is important in the context of the Title IX claim advanced by Adams, because unlike the employers in Bostock who were not permitted to terminate employees because of their sex by the terms of Title VII, the School Board is expressly authorized under Title IX’s implementing regulations to separate bathrooms on the basis of sex. See 34 C.F.R. § 106.33, which states in pertinent part:
A recipient may provide separate toilet, locker room, and shower facilities on the basis of sex, but such facilities provided for students of one sex shall be comparable to such facilities provided for students of the other sex.
(emphasis added). Adams does not dispute that the School Board is allowed to separate bathrooms on the basis of sex and does not argue that sex-separated bathrooms must be abolished. [Adams Answer Brief at p. 52]. Rather, Adams contends that the School Board’s definition of sex to his exclusion from the boys’ bathroom is discriminatory. Essentially, Adams posits that the School Board misclassified him for purposes of bathroom usage in its schools.
But this is not actionable sex discrimination. Instead, the School Board’s policy of separating student bathrooms on the basis of biological sex is legally permissible, because the School Board is authorized under Title IX and its
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regulations to separate bathrooms in this manner. In light of Bostock, the Supreme Court has now implicitly, if not explicitly recognized, that sex means biological sex.
As already argued at length in the School Board’s Initial Brief, any ambiguities in Title IX must be resolved in favor of a finding that sex means
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biological sex and that the act of separating bathrooms on this criterion is not actionable, because Title IX, unlike Title VII, was enacted pursuant to the Spending Clause. When legislation is adopted pursuant to the spending clause, Congress is required “[to] speak with a clear voice” and “unambiguously” put state funding recipients on notice of the conditions of federal funds. Pennhurst State Sch. & Hosp. v. Halderman, 451 U.S. 1, 17 (1981). Neither the language of Title IX nor the decision in Bostock support that Congress intended for schools to be liable under Title IX for discrimination when it separates bathrooms on the basis of biological sex, a result that is permitted by the statute and its implementing regulations.
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III. Bostock Supports that the School Board’s Definition of Sex is Substantially Related to an Important Governmental Interest
The School Board draws lines for bathroom usage based on the biological and physiological differences between boys and girls. Equal Protection Clause jurisprudence provides that governments may make sex-based classifications in
certain instances so long as its justified. It is justified here, and the claims 6
The School Board draws lines for bathroom usage based on the biological and physiological differences between boys and girls. Equal Protection Clause jurisprudence provides that governments may make sex-based classifications in
certain instances so long as its justified. It is justified here, and the claims 6
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advanced by Adams that the School Board’s definition of sex is in violation of the Constitution is without merit in light of Bostock.
Because the School Board’s policy draws lines based on sex, intermediate scrutiny applies without even considering Adams’ gender identity. Adams’ legal counsel agreed as much at oral argument. See Oral argument at 16:44 through 16:54 (arguing that intermediate scrutiny is triggered because the School Board’s policy makes sex-based classifications). Under intermediate scrutiny, this Court istasked with determining whether the School Board’s policy of separating student bathrooms on the basis of biological sex is substantially related to an important governmental interest. Bostock expressed no intention of resolving claims of sex discrimination under the Constitution, but its reasoning that sex is distinct from transgender status again supports reversal in this case.
The district court’s decision to distill the question to whether Adams is a boy1 misses the point of the classification employed by the School Board and the
1 As the record reflects, Adams was treated differently not because he identified as a boy, but because he is not biologically a boy and lacks the characteristics of biological boys. Undisputed in this case is the fact that the medical documentation submitted by Adams at the time of his enrollment, which required a physical examination conducted by a health professional, demonstrated that he was biologically a female. See [Docs. 161 at Tr. 229-234; 162 at Tr. 50]; F.S. §1003.22 (2009); and F.A.C. Rule 6A-6.024 (1) (2008)(“Any health professional who is licensed in Florida or in the state where the student resided at the time of the health examination and who is authorized to perform a general health examination under
Because the School Board’s policy draws lines based on sex, intermediate scrutiny applies without even considering Adams’ gender identity. Adams’ legal counsel agreed as much at oral argument. See Oral argument at 16:44 through 16:54 (arguing that intermediate scrutiny is triggered because the School Board’s policy makes sex-based classifications). Under intermediate scrutiny, this Court istasked with determining whether the School Board’s policy of separating student bathrooms on the basis of biological sex is substantially related to an important governmental interest. Bostock expressed no intention of resolving claims of sex discrimination under the Constitution, but its reasoning that sex is distinct from transgender status again supports reversal in this case.
The district court’s decision to distill the question to whether Adams is a boy1 misses the point of the classification employed by the School Board and the
1 As the record reflects, Adams was treated differently not because he identified as a boy, but because he is not biologically a boy and lacks the characteristics of biological boys. Undisputed in this case is the fact that the medical documentation submitted by Adams at the time of his enrollment, which required a physical examination conducted by a health professional, demonstrated that he was biologically a female. See [Docs. 161 at Tr. 229-234; 162 at Tr. 50]; F.S. §1003.22 (2009); and F.A.C. Rule 6A-6.024 (1) (2008)(“Any health professional who is licensed in Florida or in the state where the student resided at the time of the health examination and who is authorized to perform a general health examination under
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manner in which it must be tested. Whether the policy is substantially related to an important governmental interest, here the privacy and safety interests of students using the bathroom in schools, must be tested in light of the fact that Adams has never argued that sex-separated bathrooms should be abolished. The parties agree that the School Board may separate bathrooms on the basis of sex, and the lower court recognized that students have a privacy interest when using the bathroom.
The error is the district court’s conclusion that the School Board’s policy is not substantially related to an important governmental interest, because privacy interests are not implicated when Adams uses the bathroom. Accepting this rationale leads to an absurd result; that is, the abolition of sex-separated bathrooms. That is because, if privacy is not implicated given the manner in which Adams uses the bathroom, the same can be said for when any biological girl uses the boys’ bathroom in the same manner as Adams. Adams argues for the permissibility of separating bathrooms on the basis of sex, but his rationale for why the School Board’s policy is not substantially related to an important governmental interest, that privacy is not implicated when he uses the bathroom, undercuts the necessity for that very distinction. So the question is — how can these two positions coexist?
such licensure shall be acceptable to certify that health examinations have been completed”).
The error is the district court’s conclusion that the School Board’s policy is not substantially related to an important governmental interest, because privacy interests are not implicated when Adams uses the bathroom. Accepting this rationale leads to an absurd result; that is, the abolition of sex-separated bathrooms. That is because, if privacy is not implicated given the manner in which Adams uses the bathroom, the same can be said for when any biological girl uses the boys’ bathroom in the same manner as Adams. Adams argues for the permissibility of separating bathrooms on the basis of sex, but his rationale for why the School Board’s policy is not substantially related to an important governmental interest, that privacy is not implicated when he uses the bathroom, undercuts the necessity for that very distinction. So the question is — how can these two positions coexist?
such licensure shall be acceptable to certify that health examinations have been completed”).
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They cannot. The only way to advance the important governmental interest of privacy in the bathroom is through a policy that makes a distinction based on the biological and physiological differences between the sexes.
Adams’ legal counsel’s response to this quandary was the assertion that the “quantum of harm” suffered by a transgender student is greater than the harm a biological girl that identifies as a girl would suffer if she was unable to use the boys’ bathroom because of the policy. See Oral argument at 16:57 through 21:47. But harm is not part of Equal Protection Clause jurisprudence. Once the requirements of standing (including an injury) are established, the question is whether the definition of sex employed by the School Board is substantially related an important governmental interest rendering that injury non-actionable.
Precedent counsels that classifications based on sex for these reasons is constitutionally permissible; that is, where real differences between the biology and physiology of boys and girls necessitate the classification. As the Supreme Court held in Tuan Anh Nguyen v. I.N.S., a classification built on a stereotype is one built on a “frame of mind resulting from irrational or uncritical analysis.” 533 U.S. 53, 68 (2001). According to the Supreme Court:
[t]o fail to acknowledge even our most basic biological differences ... risks making the guarantee of equal protection superficial, and so disserving it. Mechanistic classification of all our differences as stereotypes would operate to obscure those misconceptions and prejudices that are real.
Adams’ legal counsel’s response to this quandary was the assertion that the “quantum of harm” suffered by a transgender student is greater than the harm a biological girl that identifies as a girl would suffer if she was unable to use the boys’ bathroom because of the policy. See Oral argument at 16:57 through 21:47. But harm is not part of Equal Protection Clause jurisprudence. Once the requirements of standing (including an injury) are established, the question is whether the definition of sex employed by the School Board is substantially related an important governmental interest rendering that injury non-actionable.
Precedent counsels that classifications based on sex for these reasons is constitutionally permissible; that is, where real differences between the biology and physiology of boys and girls necessitate the classification. As the Supreme Court held in Tuan Anh Nguyen v. I.N.S., a classification built on a stereotype is one built on a “frame of mind resulting from irrational or uncritical analysis.” 533 U.S. 53, 68 (2001). According to the Supreme Court:
[t]o fail to acknowledge even our most basic biological differences ... risks making the guarantee of equal protection superficial, and so disserving it. Mechanistic classification of all our differences as stereotypes would operate to obscure those misconceptions and prejudices that are real.
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Id. at 73. Adams asks this Court to countenance the reduction of the real differences between men and women into stereotypes.
This case is not like Frontiero v. Richardson, where a distinction was made between men and women based on stereotypical notions about the earning power and ability of the sexes. 411 US 677, 688-91 (1973). This is not a case like United States v. Virginia, where the classification between men and women was based on stereotypical and paternalistic notions about women. 518 U.S. 515, 549-51 (1996). Rather, this is a case where the real differences in biology and physiology of the sexes were used to advance the important governmental interest of maintaining privacy in student bathrooms, and there is no evidence that some other benign classification could serve that interest just as well, or at all.
So, what of Bostock and the Equal Protection Claim in this case? Bostock’s implicit finding that the term sex in Title VII means the biological differences between men and women, and its explicit finding that sex is distinct from transgender status, support the conclusion that defining sex along biological and physiological lines for purposes of using the bathroom was just the type of permissible distinction envisioned by the Supreme Court in cases like Nguyen. This merits reversal.
This case is not like Frontiero v. Richardson, where a distinction was made between men and women based on stereotypical notions about the earning power and ability of the sexes. 411 US 677, 688-91 (1973). This is not a case like United States v. Virginia, where the classification between men and women was based on stereotypical and paternalistic notions about women. 518 U.S. 515, 549-51 (1996). Rather, this is a case where the real differences in biology and physiology of the sexes were used to advance the important governmental interest of maintaining privacy in student bathrooms, and there is no evidence that some other benign classification could serve that interest just as well, or at all.
So, what of Bostock and the Equal Protection Claim in this case? Bostock’s implicit finding that the term sex in Title VII means the biological differences between men and women, and its explicit finding that sex is distinct from transgender status, support the conclusion that defining sex along biological and physiological lines for purposes of using the bathroom was just the type of permissible distinction envisioned by the Supreme Court in cases like Nguyen. This merits reversal.
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CONCLUSION
Bostock recognizes the inescapable fact that sex is based on biology and is separate and distinct from an individual’s transgender status. This common sense recognition entirely supports the policy adopted by the School Board and its arguments raised in this case. As such, the district court should be reversed.
Respectfully submitted this 2nd day of July, 2020.
/s/ Terry J. Harmon
Terry J. Harmon FBN 0029001
/s/ Jeffrey D. Slanker
Jeffrey D. Slanker FBN 0100391 Robert J. Sniffen FBN 000795 Michael P. Spellman FBN 937975
SNIFFEN & SPELLMAN, P.A. 123 North Monroe Street Tallahassee, FL 32301 Telephone: (850) 205-1996 Fax: (850) 205-3004
Counsel for The School Board of St. Johns County, Florida
Bostock recognizes the inescapable fact that sex is based on biology and is separate and distinct from an individual’s transgender status. This common sense recognition entirely supports the policy adopted by the School Board and its arguments raised in this case. As such, the district court should be reversed.
Respectfully submitted this 2nd day of July, 2020.
/s/ Terry J. Harmon
Terry J. Harmon FBN 0029001
/s/ Jeffrey D. Slanker
Jeffrey D. Slanker FBN 0100391 Robert J. Sniffen FBN 000795 Michael P. Spellman FBN 937975
SNIFFEN & SPELLMAN, P.A. 123 North Monroe Street Tallahassee, FL 32301 Telephone: (850) 205-1996 Fax: (850) 205-3004
Counsel for The School Board of St. Johns County, Florida
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CERTIFICATE OF COMPLIANCE
I CERTIFY that this brief complies with this Court’s June 17, 2020, Order limiting supplemental briefs to no more than twenty (20) pages. I FURTHER CERTIFY that this brief complies with the typeface requirements of Fed. R. App. P. 32(a)(5) and the type style requirements of Fed. R. App. P. 32(a)(6). This brief has been prepared in a proportionally spaced typeface using Microsoft Word Version 2007 in 14 point Times New Roman.
/s/ Terry J. Harmon
TERRY J. HARMON CERTIFICATE OF SERVICE
I hereby certify one true and accurate copy of the foregoing document has been furnished by electronic means to all counsel of record as well as by U.S. Certified Mail, Postage Prepaid and Return Receipt Requested.
One originally signed version and six copies of this brief with tan covers have been delivered via Federal Express to:
I CERTIFY that this brief complies with this Court’s June 17, 2020, Order limiting supplemental briefs to no more than twenty (20) pages. I FURTHER CERTIFY that this brief complies with the typeface requirements of Fed. R. App. P. 32(a)(5) and the type style requirements of Fed. R. App. P. 32(a)(6). This brief has been prepared in a proportionally spaced typeface using Microsoft Word Version 2007 in 14 point Times New Roman.
/s/ Terry J. Harmon
TERRY J. HARMON CERTIFICATE OF SERVICE
I hereby certify one true and accurate copy of the foregoing document has been furnished by electronic means to all counsel of record as well as by U.S. Certified Mail, Postage Prepaid and Return Receipt Requested.
One originally signed version and six copies of this brief with tan covers have been delivered via Federal Express to:
David J. Smith, Clerk
U.S. Court of Appeals for the 11th Circuit 56 Forsyth St. N.W.
Atlanta, GA 30303
U.S. Court of Appeals for the 11th Circuit 56 Forsyth St. N.W.
Atlanta, GA 30303
/s/ Terry J. Harmon
TERRY J. HARMON
TERRY J. HARMON
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