## Facts

- Julienne Goins, a transgender woman designated male at birth, began hormone therapy in 1994 and presented publicly as female by 1995.
- A Texas court granted Goins a legal name change and recognized a change in gender from “genetic male” to “reassigned female,” authorizing updates to official documents.
- Goins worked for West Group in Rochester, New York without incident and later transferred to West’s Eagan, Minnesota facility.
- Before relocating, Goins visited the Eagan facility and used the women’s restroom.
- After the transfer, some female employees complained to supervisors about sharing the women’s restroom with a person they believed to be biologically male.
- West’s human resources director consulted internal personnel and legal counsel and adopted a restroom-use rule requiring employees to use restrooms corresponding to their biological sex.
- West informed Goins she could use a single-occupancy restroom on another floor rather than the men’s restroom.
- Goins objected and proposed training for employees about transgender individuals; West declined.
- Goins refused to comply with the policy, was warned about possible discipline, resigned, and sued under the Minnesota Human Rights Act (MHRA) for sexual-orientation discrimination and hostile work environment.

## Issues

1. Whether an employer’s policy requiring restroom use based on biological sex constitutes sexual-orientation discrimination under the MHRA.
2. Whether the evidence created a triable issue that Goins experienced a hostile work environment under the MHRA.

## Decision

- The Minnesota Supreme Court reversed the court of appeals and reinstated summary judgment for West.
- The court held that designating employee restroom use by biological sex did not violate the MHRA’s prohibition on sexual-orientation discrimination.
- The court held that Goins failed, on the summary-judgment record, to establish a sufficient factual basis for a hostile work environment claim.

## Legal Principles

- MHRA “sexual orientation” includes having or being perceived as having a self-image or identity not traditionally associated with one’s biological maleness or femaleness.
- A workplace rule classifying restroom access by biological sex, applied uniformly, is not treated as discrimination “because of” sexual orientation under the MHRA for purposes of restroom assignment.
- Hostile work environment requires evidence of conduct that is sufficiently severe or pervasive to alter employment conditions and create an abusive working environment.
- Enforcement of a facially uniform restroom policy, coupled with access to a single-occupancy alternative, was insufficient on this record to establish severe or pervasive harassment attributable to the employer.

## Conclusion

The Minnesota Supreme Court held that an employer’s biologically sex-segregated restroom policy did not constitute MHRA sexual-orientation discrimination and that the record did not support a hostile work environment claim, warranting summary judgment for the employer.


Goins v. W. Grp., 635 N.W.2d 717 (Minn. 2001)