See Conway v. City of Hartford, 1997 Conn. Super. LEXIS 282 (refusing to dismiss transsexual plaintiff’s claim of sexual orientation discrimination, but noting that “[h]ad the plaintiff failed to allege specifically discrimination based on sexual orientation, but rather merely referenced his transsexualism as a basis for discrimination based on sexual orientation, the . . . claim would have been legally insufficient”); Maffei v. Kolaeton Industry, Inc., 626 N.Y.S. 2d 391 (N.Y. Sup. Ct. 1995) (holding that the definition of sexual orientation in New York City ordinance does not include transsexualism); Underwood v. Archer Management Services, Inc., 857 F. Supp. 96, 98 (D.D.C. 1994) (“a conclusory statement that [transsexual plaintiff] was discharged on the basis of transsexuality . . . does not constitute a claim for relief on the basis of . . . sexual orientation”) However, in all three of these locales, discrimination on the basis of gender identity is now illegal under a state law basis other than sexual orientation: Connecticut (sex); New York (sex); District of Columbia (personal appearance)
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