See Jette v. Honey Farms & Millette v. Tutco (Mass. Commission Against Discrimination Oct. 10, 2001) (state administrative agency ruled that transsexual people are protected by Massachusetts state law prohibitions against sex discrimination); Maffei v. Kolaeton Industry, Inc., 626 N.Y.S. 2d 391 (N.Y. Sup. Ct. 1995) (city ordinance prohibiting “gender” discrimination protects transsexuals, disagreeing with the reasoning of federal cases which hold that Title VII does not protect transsexuals); Rentos v. OCE-Office Systems, 1996 U.S. Dist. LEXIS 19060 (S.D.N.Y. 1996) (court refused to dismiss transsexual woman’s claim that she had been discriminated against on the basis of sex in violation of the New York State Human Rights Law and the New York City Human Rights Law.) Note that as of 2002, the New York City Human Rights Law expressly prohibits discrimination on the basis of gender identity; Declaratory Ruling On Behalf Of John/Jane Doe (Conn. Comm’n on Human Rights & Opportunities Nov. 9, 2000) (state administrative agency ruled that transsexual people are protected by Connecticut state law prohibitions against sex discrimination); and Enriquez v. West Jersey Health Systems, 2001 N.J. Super. LEXIS 283 (N.J. Super. 2001) (concluding that New Jersey state law prohibiting sex discrimination in employment protects transsexual people)
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