In what appears to be a continuing trend, the Eleventh Circuit Court of Appeals, which covers the states of Florida, Georgia, and Alabama, has recently ruled that transgender individuals may bring claims of sex discrimination against their employers where they are adversely affected in the terms and conditions of their employment resulting from gender stereotyping. Other federal circuits have ruled in similar fashion. This is a shift for the courts who have historically ruled that federal law does not protect such individuals. The court limited its decision to transgender individuals. As such, it would be too premature to suggest that the court will similarly extend such protecton to the gay and lesbian community. The court’s decision, however, shows an increasing recognition that such things as sexual orientation and gender identity are no more or less voluntary than the color of a person’s skin, a person’s age, a person’s disability, or a person’s national origin — all of which are protected categories under federal, state and local anti-discrimination laws.