See Conway v. City of Hartford, 1997 Conn. Super. LEXIS 282 (Feb. 4, 1997) (dismissing sex discrimination claim alleging violations of Connecticut Fair Employment Practice Act; however, the Connecticut Commission on Human Rights and Opportunities ruled in 2000 that transsexuals may bring sex discrimination claims under state law, based in part on case law that was issued after the Conway decision); Underwood v. Archer Management Services, Inc., 857 F. Supp. 96 (D.D.C. 1994) (dismissing sex discrimination claim alleging violations of the D.C. Human Rights Act; however, transgendered individuals are now protected by the section of the Human Rights Act which makes it illegal to discriminate based on personal appearance); Dobre v. National R.R. Passenger Corp. (AMTRAK), 850 F. Supp. 284 (E.D. Pa. 1993) (dismissing claim brought under sex discrimination provision of Pennsylvania Human Rights Act).
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