In Rene, two of the concurring judges felt that the plaintiff could state a claim under Hopkins because his harassers treated him "like a woman," and therefore engaged in unlawful sex stereotyping.

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Most claims by lesbians and gay men under Hopkins have failed. One federal court, for example, recently threw out a sex stereotyping claim by a gay corrections officer because there was no evidence that the plaintiff acted "in an effeminate manner" (Martin v. New York Dep't of Corrections [2002]). Since not all gay men are effeminate and not all lesbians are "macho," the Hopkins case may have limited value to employees harassed because of their sexual orientation.

Title VII shows some renewed promise after Rene, but the patchwork of protections across the country can only be cured by the passage of ENDA. Until then, some lesbians and gay men will be legally protected from workplace discrimination, and others will not.

The lesbian and gay civil rights movement has come a long way from the time, not too long ago, when coming out at work was extremely risky and could likely lead to reprisal. Today many millions of Americans are out at work and protected from discrimination by company policy or by local law. Yet this impressive story of successful activism will not be complete until Congress protects all lesbians and gay men with the passage of ENDA.

Anti-discrimination statutes and ordinances have made a real difference in the lives of millions of glbtq individuals.

"Domestic partnership" is the generic term for a variety of forms of legal and institutional recognition of same-sex couples that fall short of same-sex marriage.

Homophobia was originally defined as a "dread of being in close quarters with homosexuals," but it is now sometimes used to describe any form of anti-gay bias.

Early in the gay rights movement activists challenged organized labor to broaden its struggle against discrimination to include sexual identity; consequently labor unions became some of the first mainstream organizations to call for equal rights.

The question of whether glbtq people in the United States are protected from sexual harassment under federal law has been a major issue for courts in the past 30 years.

Stereotypes usually include inaccurate and negative assumptions about groups, thus contributing to racism, classism, sexism, and homophobia.

The Empire State Pride Agenda, which lobbies New York governments at both state and local levels for equal rights, is recognized as among the strongest statewide glbtq political organizations in the United States.

Equality California (EQCA) is one of the largest and fastest growing statewide glbtq advocacy and civil rights organizations in the United States.

The Gender Public Advocacy Coalition (GenderPAC) works to end discrimination and violence prompted by gender identification and stereotypes.

The largest glbtq political organization in the United States, the Human Rights Campaign has emerged as the leading national organization representing glbtq concerns.