Ulane v. Eastern Airlines, Inc.

742 F.2d 1081 (1984)

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Ulane v. Eastern Airlines, Inc.

United States Court of Appeals for the Seventh Circuit
742 F.2d 1081 (1984)

  • Written by Mike Begovic, JD

Facts

Karen Ulane (plaintiff) began working for Eastern Airlines (defendant) as a pilot in 1968, eventually becoming a first officer and flight instructor. Throughout much of her tenure, she went by the name Kenneth Ulane and presented herself as a male. In 1980, after taking female hormones, Ulane underwent sex-reassignment surgery, after which she was issued a new birth certificate listing her sex as female. Eastern Airlines terminated Ulane in 1981. Ulane filed a discrimination complaint with the Equal Employment Opportunity Commission, which issued a right-to-sue letter. Ulane filed suit in federal district court, contending that she was discriminated against as a female (count 1) and as a transgender person (count 2) in violation of Title VII of the Civil Rights Act of 1964 (the act). The trial court judge sided with Ulane on both counts, awarding her damages and reinstatement as a pilot. On count 2, the trial court judge interpreted Title VII to protect transgender individuals on the grounds that sex is a matter of sexual identity and self-perception and that it was reasonable to interpret Title VII broadly. Eastern Airlines filed an appeal.

Rule of Law

Issue

Holding and Reasoning (Wood, J.)

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