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37 Colum. Hum. Rts. L. Rev. 189 (2005-2006)
Sex Education: Recognizing Anti-Gay Harassment as Sex Discrimination under Title VII and Title IX

handle is hein.journals/colhr37 and id is 197 raw text is: SEX EDUCATION: RECOGNIZING ANTI-GAY HARASSMENT AS SEX DISCRIMINATION UNDER TITLE VII AND TITLE IX Courtney Weiner* I. INTRODUCTION Medina Rene worked as a butler at the MGM Grand Hotel in Las Vegas. Rene is openly gay. For two years, Rene faced almost daily harassment from his all-male coworkers and supervisor.I They called him feminine names like sweetheart and mufieca,2 told sexual jokes, and imposed sexually explicit material on him. At worst, the harassers grabbed and fondled Rene through his clothes.3 He initially claimed that his coworkers harassed him because of his sexual orientation, but he then stated his claim as one of more traditional sex discrimination under Title VII of the Civil Rights Act of 1964.4 To sidestep the problem that Title VII does not, as currently * The author is a J.D. candidate at Columbia Law School, 2006. She graduated magna cum laude from Princeton University in 2001 with an A.B. in history and a certificate in women's studies. She served as a staff editor for the Columbia Human Rights Law Review in 2004-2005. Special thanks to Susan Sturm for her guidance and inspiration in writing this note. Thanks also to Robert Weiner, Jeremy Gladstone, and Elana Berger for their editing assistance. Finally, thank you, as always to my parents for always supporting me in everything I do and my sister for keeping me grounded. 1. Rene v. MGM Grand Hotel, Inc., 305 F.3d 1061, 1064 (9th Cir. 2002) (en banc). 2. Mufieca is the Spanish word for doll. Id. 3. Id. 4. Id. Title VII states: It shall be an unlawful employment practice for an employer . . . to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual's ... sex .... Title VII of the Civil Rights Act of 1964 § 703, 42 U.S.C. § 2000e-2(a) (2000).

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