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female transsexual workers in violation of Title VII of the 1964 Civil Rights Act. 10Thisfollowed a 2012 administrative ruling in which the EEOC held that Title VII’s ban on sexdiscrimination prohibits bias based on transgender status and gender identity, Macy v.Holder, EEOC No. 0120120821, and is the latest in a growing list of legal developmentsthat recognize civil rights for transgender workers.For example, in October, 2014, the EEOC filed an amicus brief with the U.S. Court ofAppeals for the Seventh Circuit in which it urged the Court to reconsider a decision inwhich it held that Title VII does not bar sexual-orientation discrimination. 11This brief setforth the Commission’s broad view of the gender-stereotyping theory that it haddeveloped in federal sector cases.This theory and these cases arise out of the U.S. Supreme Court’s decision in PriceWaterhouse v. Hopkins. 12In Price-Waterhouse, the Court held that job actions takenon the belief that an employee does not conform to society’s expectations for persons ofthat gender are prohibited under Title VII. Although Price Waterhouse was not a genderidentity or sexual orientation case, it has been used by the EEOC and courts to increaseprotections for the LGBT community.In October, 2014, the Commission announced that it was adding two new chargecategorization codes for charges filed with the EEOC, specifically, “GO” for genderorientation bias and “GT” for gender identity bias. This stems from the fact the10 EEOC v. R.G. & G.R. Harris Funeral Homes, Inc., E.D. Mich., No. 2:14-cv-13710; EEOC v. LakelandEye Clinic, P.A., M.D. Fla., No. 8:14-cv-02421.11 See Muhammad v. Caterpillar, Inc., 7 th Cir., No. 12-1723, 2014.12 Price Waterhouse v. Hopkins, 490 U.S. 228 (1989).10