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96 Tex. L. Rev. Online 1 (2017-2018)

handle is hein.journals/seealtex96 and id is 1 raw text is: Texas Law Review Online Volume 96 Article Against Gay Potemkin Villages: Title VII and Sexual Orientation Discrimination Anthony Michael Kreis* To help pay for school, Jameka Evans took a job as a security guard at Georgia Regional Hospital in Savannah.' Evans is a lesbian but never spoke about her sexuality at work.2 Her silence did not conceal her identity, however. Evans's masculine clothing and hairstyles telegraphed her sexual orientation to colleagues.3 Evans claims she was harassed and penalized at work because of her masculine characteristics and sexual orientation.4 The hostile work environment, she alleged, arose from her failing to comport with her supervisor's expectation that she act in a traditional woman[ly] manner.' Evans quit and filed a Title VII claim alleging she was discriminated against because of her sex. Specifically, Evans proffered the adverse treatment arose from her gender nonconformity.6 Title VII forbids employers from discriminating against employees * Visiting Assistant Professor, Illinois Institute of Technology Chicago-Kent College of Law. Ph.D., University of Georgia School of Public and International Affairs, J.D., Washington and Lee University, B.A., University of North Carolina at Chapel Hill. Thanks to Marty Malin, Greg Nevins, Elizabeth DeArnond, Kathleen Perrin, Kent Streseman, Mary Rose Strubbe, and my students for thought-provoking conversations on the subject and exceedingly helpful feedback. 1. Evans v. Georgia Reg'1 Hosp., 850 F.3d 1248, 1251 (11th Cir. 2017); see Matt Hennie, Guard: Georgia hospital fired me for being gay, PROJECT Q ATLANTA, Jan. 7, 2016, http://www.projectq.us/atlanta/guardsaysgeorgia hospital fired her for beinggay?gid=17501 [https://perna.cc/X7YH-D4HB]. 2. Evans, 850 F.3d at 1251. 3. Id. 4. Id. 5. Id. (alteration in original). 6. Id. at 1250.

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