Julienne Goins v. West Group

635 N.W.2d 717 (2001)

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Julienne Goins v. West Group

Minnesota Supreme Court
635 N.W.2d 717 (2001)

  • Written by Haley Gintis, JD

Facts

In 1997 Julienne Goins (plaintiff), who identified as transgender, began working for West Group (West) (defendant). West had originally hired Goins to work in New York but then transferred her to Minnesota. Before Goins relocated to Minnesota, she visited the facility. During her visit, Goins used the women’s restroom. After multiple females complained about Goins’s use of the female bathroom because she was biologically male, West developed a policy under which employees were required to use the restroom aligning with their biological gender. On Goins’s first day of work, the director of human resources informed her of the policy. The director explained that female coworkers expressed concern about sharing the bathroom with a biological male. The director informed Goins that she could use the single-occupancy restroom on a different floor rather than the men’s restroom. Goins suggested that, rather than adopting the policy, West could provide education and training on transgender individuals. West rejected the suggestion. Goins began her employment in the Minnesota office but refused to comply with the restroom policy. After West threatened Goins with disciplinary action, Goins resigned. Goins filed an action against West in Minnesota district court. Goins claimed that West’s restroom policy constituted sexual-orientation discrimination that violated the Minnesota Human Rights Act. The district court dismissed Goins’s claim on the ground that she did not establish that West had engaged in impermissible sexual-orientation discrimination. The court of appeals reversed. The matter was appealed to the Minnesota Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Anderson, J.)

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