JayCee Cooper v. USA Powerlifting, USA Powerlifting Minnesota, on Related Appeal ...

Syllabus

1. Under the Minnesota Human Rights Act's (MHRA) protection of transgender individuals against discrimination based on sexual orientation, Minn. Stat. § 363A.03, subd. 44 (2018), a policy that expressly prohibits transgender women from competing in the women's division of a powerlifting competition is facially discriminatory and constitutes direct evidence of discrimination based on sexual orientation under the MHRA's prohibition against business discrimination and discrimination by places of public accommodation, found at Minn. Stat. §§ 363A.11, 363A.17 (2018). 2. There is a genuine dispute of material fact as to whether seeking to ensure competitive fairness in an athletic competition satisfies the legitimate business purpose defense for sexual orientation and sex discrimination in business under Minn. Stat. § 363A.17 (2018) of the MHRA that forecloses partial summary judgment for the plaintiff as to liability on this claim. 3. In the absence of any alleged statutory exemption or defense, the district court properly granted partial summary judgment for the plaintiff on the claim of sexual orientation discrimination in public accommodations. 4. Our holding in Goins v. West Group, 635 N.W.2d 717 (Minn. 2001), is limited to claims of sexual orientation discrimination under the MHRA related to employment. Affirmed in part, reversed in part, and remanded.