Hofstra Law Review Volume 37 | Issue 3 Article 7 2009 Finding Common Ground: How Inclusive Language Can Account for the Diversity of Sexual Minority Populations in the Employment Non- Discrimination Act Meredith R. Palmer Follow this and additional works at: http://scholarlycommons.law.hofstra.edu/hlr Part of the Law Commons Recommended Citation Palmer, Meredith R. (2009) "Finding Common Ground: How Inclusive Language Can Account for the Diversity of Sexual Minority Populations in the Employment Non-Discrimination Act," Hofstra Law Review: Vol. 37: Iss. 3, Article 7. Available at: http://scholarlycommons.law.hofstra.edu/hlr/vol37/iss3/7 This document is brought to you for free and open access by Scholarly Commons at Hofstra Law. It has been accepted for inclusion in Hofstra Law Review by an authorized administrator of Scholarly Commons at Hofstra Law. For more information, please contact
[email protected]. Palmer: Finding Common Ground: How Inclusive Language Can Account for the NOTE FINDING COMMON GROUND: HOW INCLUSIVE LANGUAGE CAN ACCOUNT FOR THE DIVERSITY OF SEXUAL MINORITY POPULATIONS IN THE EMPLOYMENT NON-DISCRIMINATION ACT I. INTRODUCTION The Employment Non-Discrimination Act ("ENDA") aims to protect all American employees who are or may be perceived as gay, lesbian, or bisexual by prohibiting discrimination in employment or employment opportunities, including, "firing, hiring, compensation, terms, conditions and privileges of employment .... "' Thus, ENDA creates a cause of action for any individual who is discriminated against because that individual is "'perceived' as a homosexual, bisexual or heterosexual, whether or not they actually identify as such.2 This Note explores possible language for ENDA, a measure that has been the primary legislative vehicle for extending federal protection from employment discrimination on the basis of an employee's actual or perceived sexual orientation.3 The effect of ENDA's language on the scope of protection for the lesbian, gay, bisexual, and transgender ("LGBT") 4 community has 1.