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From the Justice Department’s Account of Interest filed bygone in Soule v. Connecticut Ass’n of Schools, Inc.; I apprehend there’ll be a acknowledgment to it filed, and I’ll be animated to blog that as well:

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[A.] Title IX requires that “[n]o actuality in the United States shall, on the base of , … be denied the allowances of, or be subjected to bigotry beneath any apprenticeship diplomacy or action accepting Federal banking assistance.” 20 U.S.C. §1681(a); accordance 34 C.F.R. § 106.41(a). Title IX’s prohibition adjoin bigotry extends to contest operated or sponsored by recipients of federal money. 34 C.F.R. § 106.41. As a result, covered institutions charge “provide according able-bodied befalling for associates of both es.” Id. § 106.41(c).

The Connecticut Interscholastic Able-bodied Conference (CIAC), however, has adopted a action that requires biological males to attack adjoin biological females—despite the absolute physiological differences amid the es—if the macho is a transgender alone who about identifies with the changeable gender. CIAC claims that “federal law” requires this accompaniment of affairs. CIAC 2019-2020 Handbook (CIAC Handbook), at 55, http://www.casciac.org/pdfs/ ciachandbook_1920.pdf; see additionally Defs.’ Initial Summ. Issues at 7, ECF No. 63. So do the proposed student-intervenors. See Mot. to Intervene at 11, ECF No. 36.

They are incorrect. Title IX and its implementing regulations prohibit bigotry alone “on the base of ,” not on the base of transgender status, and appropriately neither crave nor accredit CIAC’s transgender policy. To the contrary, CIAC’s architecture of Title IX as acute the accordance of acceptance on able-bodied teams that reflect their gender appearance would about-face the statute on its head. One of Title IX’s amount purposes is to ensure that women accept an “equal able-bodied opportunity” to participate in academy able-bodied programs. 34 C.F.R. § 106.41(c); see additionally Cohen v. Brown Univ., 991 F.2d 888, 897 (1st Cir. 1993) (“Equal befalling to participate lies at the amount of Title IX’s purpose.”). Schools apprehend that purpose primarily by establishing abstracted able-bodied teams for men and women and by ensuring that those teams are on according footing. See 34 C.F.R. § 106.41(b)-(c). Because of the physiological differences amid men and women, the actuality of women’s sports teams permits women to participate added absolutely in contest than they contrarily could.

Under CIAC’s estimation of Title IX, however, schools may not annual for the absolute physiological differences amid men and women. Instead, schools charge accept assertive biological males—namely, those who about analyze as female—compete adjoin biological females. In so doing, CIAC deprives those women of the single- able-bodied competitions that are one of the covering accomplishments of Title IX. The United States appropriately submits this Account of Interest to aid the Court in the able appliance of Title IX in this case….

[B.] Title IX prohibits “discrimination” in educational programs and activities “on the base of .” 20 U.S.C. § 1681(a). Although Title IX includes statute-specific definitions of assorted terms, “” is not one of them. See id. § 1681(c) (defining “educational institution”); id. § 1687 (defining “program or activity” and “program”). Without such a definition, the appellation “” should “be interpreted as demography [its] ordinary, contemporary, accepted meaning.” Sandifer v. United States Steel Corp., 571 U.S. 220, 227 (2014) (citation omitted).

When Congress allowable Title IX in 1972, the “ordinary, contemporary, accepted meaning” of “” was biological . In that aforementioned year, 1972, the United States explained to the Supreme Court that “, like chase and civic origin, is a arresting and abiding biological characteristic,” U.S. Br. at *15, Frontiero v. Laird, No. 71-1694, 1972 WL 137566 (U.S. Dec. 27, 1972), and the Court agreed that “” is “an abiding appropriate bent alone by the blow of birth,” Frontiero v. Richardson, 411 U.S. 677, 686 (1973).

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Also during the time aeon surrounding Title IX’s enactment, dictionaries authentic “” as apropos to the physiological distinctions amid males and females, and added decidedly their changeable functions. For example, Webster’s Third authentic “” as “one of the two capacity of amoebic esp. animal beings appropriately appointed macho or female,” or “the sum of the morphological, physiological, and behavioral peculiarities of active beings that subserves biparental reproduction.” Webster’s New International Dictionary 2081 (3d ed. 1968). Added ancillary dictionaries authentic “” similarly. See, e.g., American Heritage Dictionary of the English Accent 1187 (1st ed. 1969) (“1. a. The acreage or affection by which bacilli are classified according to their changeable functions. b. Either of two divisions, appointed macho and female, of this classification.”); The American College Dictionary 1109-10 (1970) (“1. The appearance of actuality either macho or female  2. The sum of the anatomical and physiological differences with advertence to which the macho and changeable are acclaimed or the phenomena depending on these differences.”); The Random House College Dictionary 1206 (1973) (“1. either the macho or changeable analysis of a breed esp. as differentiated with advertence to the changeable functions. 2. The sum of the structural and anatomic differences by which macho and females are distinguished.”).

Other accoutrement of Title IX apply “” as a bifold term, and appropriately accommodate added acceptance that the prohibition on “” bigotry does not extend to bigotry on the base of transgender cachet or gender identity. If the appellation “” in Title IX included “gender identity”—which, according to the American Psychiatric Association, may accommodate “an individual’s identification as … some class added than macho or female,” Diagnostic and Statistical Manual of Mental Disorders Fifth Edition 451 (2013) (emphasis added)—then assorted Title IX accoutrement would accomplish little sense.

Title IX consistently uses “” as a bifold abstraction capturing alone two categories: macho and female. For example, the statute creates an barring for “father-son or mother-daughter activities at an educational institution, but if such activities are provided for acceptance of one , opportunities for analytic commensurable activities shall be provided for acceptance of the added .” 20 U.S.C. § 1681(a)(8) (emphases added). Likewise, Title IX includes a capricious aeon for an “educational academy which has amorphous the action of alteration from actuality an academy which admits alone acceptance of one to actuality an academy which admits acceptance of both es,” provided assertive belief are met. Id. § 1681(a)(2) (emphases added). Moreover, Title IX especially provides that annihilation in the statute “shall be construed to prohibit any educational academy … from advancement abstracted active accessories for the altered es.” Id. § 1686 (emphasis added). These accoutrement could not evidently action if the appellation “” includes “gender identity,” which, clashing “,” may not be bound to two categories.

[C.] Actual ambience added confirms that Congress acclimated the chat “” in its accustomed biological sense. “Title IX was allowable in acknowledgment to affirmation of common bigotry adjoin women with account to educational opportunities, which was accurate in hearings captivated in 1970 by the House Appropriate Subcommittee on Education.” McCormick ex rel. McCormick v. Academy Dist. of Mamaroneck, 370 F.3d 275, 286 (2d Cir. 2004); see additionally North Haven Bd. of Ed. v. Bell, 456 U.S. 512, 523 n.13 (1982). Adjoin that backdrop, associates of Congress voting on Title IX and any politically affianced aborigine would accept accepted the law as directed at eliminating bigotry in apprenticeship based on biological —i.e., diff analysis of men and women—consistent with the term’s accustomed meaning.

Congress’s accomplishments in the 48 years afterward Title IX’s achievement affirm that “” in this statute does not beset transgender status. In added approved contexts, Congress has acted affably to abode gender-identity bigotry as a audible class abstracted from discrimination. For example, back Congress allowable the Matthew Shepard and James Byrd, Jr. Hate Crimes Prevention Act of 2009, Pub. L. No. 111-84, Div. E., 123 Stat. 2190 (2009), Congress begin that the “incidence of abandon motivated by the absolute or perceived race, color, religion, civic origin, gender, animal orientation, gender identity, or affliction of the victim poses a austere civic problem.” 34 U.S.C. § 30501(1) (emphasis added).

Congress appropriately acclimated the Hate Crimes Prevention Act to alter or actualize several approved accoutrement that banned or contrarily accurately addressed bigotry based on “gender identity,” in accession to bigotry based on “” or “gender.” See 18 U.S.C. § 249(a)(2)(A) & (c)(4) (prohibiting acts or attempts to account absolute abrasion to any actuality “because of the absolute or perceived religion, civic origin, gender, animal orientation, gender identity, or affliction of any person,” and defining “gender identity” as “actual or perceived gender-related characteristics” (emphasis added)); 34 U.S.C. § 30503(a)(1)(C) (regarding federal abetment to state, local, or affiliated investigations of crimes “motivated by ageism based on the absolute or perceived race, color, religion, civic origin, gender, animal orientation, gender identity, or affliction of the victim” (emphasis added)); id. § 30506(2) (construing agitated acts motivated by absolute or perceived race, color, religion, civic origin, gender, animal orientation, gender identity, or affliction of a victim (emphasis added)); id. § 41305(b)(1) (regarding accumulation statistics “about crimes that apparent affirmation of ageism based on race, gender and gender identity, religion, disability, animal orientation, or ethnicity) (emphasis added)).

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Similarly, in 2013, Congress adapted the Abandon Adjoin Women Act to actualize a federal government administration action that adequate the abstracted bases of and gender identity. See 34 U.S.C. § 12291(b)(13)(A) (2013), as adapted by Pub. L. No. 113-4, § 3, 127 Stat. 56 (2013) (prohibiting bigotry in assertive federally adjourned programs “on the base of absolute or perceived race, color, religion, civic origin, , gender appearance (as authentic in [18 U.S.C. § 249(c)(4)]), animal orientation, or disability” (emphases added)).

These post-Title IX enactments allegorize that Congress “kn[ows] how” to prohibit bigotry based on gender appearance back it wishes to do so. Dep’t of Homeland Sec. v. MacLean, 135 S. Ct. 913, 921 (2015). “If Congress had meant to prohibit … transgender discrimination” in Title IX, “surely the best aboveboard way to do so would accept been to say so—to add … ‘transgender status’ or ‘gender identity’ to the account of classifications adequate under” Title IX. Wittmer v. Phillips 66 Co., 915 F.3d 328, 338 (5th Cir. 2019) (Ho, J., concurring) (addressing Title VII). Congress did not do so back originally assuming Title IX or subsequently. Instead, Congress has bootless to achieve proposed bills to alter Title IX to add protections for “gender identity.” See, e.g., H.R. 1652, 113th Cong. (2013); S. 439, 114th Cong. (2015).

To be sure, “it is ultimately the accoutrement of our laws rather than the arch apropos of our legislators by which we are governed.” Oncale v. Sundowner Offshore Servs., Inc., 523 U.S. 75, 79 (1998). Subjective expectations of Associates of Congress as to which accurate practices Title IX would prohibit appropriately do not control. But the actual ambience makes bright that, in application the appellation “,” Congress was apropos to bigotry based on biological — i.e., diff analysis of men and women—consistent with the term’s accustomed meaning. Conversely, the United States knows of no affirmation assuming that back Congress active the appellation “” in Title IX it did so to ability annihilation about transgender status, and CIAC has articular none.

[D.] In addition, Title IX prohibits alone “discrimination” “on the base of ,” 20 U.S.C. § 1681(a) (emphasis added), and acute all acceptance to participate on the able-bodied aggregation associated with their biological cannot be declared as “discrimination.” The “normal analogue of discrimination, is cogwheel treatment” or, added specifically, “less favorable treatment.” Jackson v. Birmingham Bd. of Educ., 544 U.S. 167, 174 (2005) (citation and centralized commendation marks omitted) (construing “discrimination” in Title IX). Thus, for a prohibition on bigotry because of , “[t]he analytical affair … is whether associates of one are apparent to adverse agreement or altitude … to which associates of the added are not exposed.” Oncale, 523 U.S. at 80 (citation omitted) (addressing Title VII). Acute acceptance to participate on the able-bodied aggregation associated with their biological accounts for the absolute physiological differences amid the es in a address that burdens anniversary equally, which is the capital acumen why Defendants may abide to advance single- teams. See infra Allotment B.

The bearings is no altered for transgender acceptance specifically: biological males with a changeable gender appearance are apparent to the aforementioned altitude as analogously anchored biological females with a macho gender identity.

Indeed, because such a action would facially about-face alone on biological differences rather than on gender identity, the action would not alike consider, abundant beneath discriminate on the base of, transgender status. Academy admiral would not alike accept to “know an individual’s transgender cachet in adjustment to accomplish the policy—knowledge of characteristics altered to gender alternative is both all-important and sufficient.” Doe 2 v. Shanahan, 917 F.3d 694, 733 (D.C. Cir. 2019) (Williams, J., acknowledging in result) (addressing aggressive action acute all “service associates [to] serve ‘in their biological ‘”); cf. Raytheon Co. v. Hernandez, 540 U.S. 44, 54 n.7 (2003) (noting that if an employer “were absolutely blind that such a affliction existed, it would be absurd for her hiring accommodation to accept been based, alike in part, on respondent’s disability”).

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If the law were otherwise, endless -specific behavior would be per se unlawful. A action mandating that macho acceptance not common the women’s bathrooms or locker rooms, for example, would be affected to challenge. And so would a action ambience altered physical- fettle standards for macho and changeable able-bodied events. Indeed, abounding of Title IX’s implementing regulations—which admittance -specific able-bodied teams, bathrooms, locker rooms, or battery facilities—would be in accident if CIAC’s appearance of bigotry were to backpack the day. See 34 C.F.R. § 106.33 (“A almsman may accommodate abstracted toilet, locker room, and battery accessories on the base of , but such accessories provided for acceptance of one shall be commensurable to such accessories provided for acceptance of the added .”); id. § 106.41(b) (permitting “separate teams for associates of anniversary “); see additionally infra Allotment B.

Nothing in Title IX or Supreme Court antecedent requires such abolitionist upheaval. To the contrary, the Supreme Court has accustomed that -based classifications sometimes are permissible because assertive “differences amid men and women” are “enduring.” United States v. Virginia, 518 U.S. 515, 533 (1996). That holds accurate in the breadth of physical-fitness standards, as “[m]en and women artlessly are not physiologically the aforementioned for the purposes of concrete fettle programs.” Bauer v. Lynch, 812 F.3d 340, 350 (4th Cir. 2016) (finding FBI did not breach Title VII back application altered concrete fettle standards for appropriate abettor candidates based on ); see additionally Virginia, 518 U.S. at 550 n.19 (admitting women to a ahead all-male aggressive academy “would assuredly require” that academy “to acclimatize aspects of the concrete training programs”).

[E.] Purpose and Regulations

Far from actuality appropriate by Title IX, CIAC’s transgender action is in astriction with “the amount of Title IX’s purpose”—namely, ensuring that women accept an “[e]qual befalling to participate” in educational programs and activities at covered institutions. Cohen v. Brown Univ., 991 F.2d 888, 897 (1st Cir. 1993); accordance McCormick ex rel. McCormick v. Sch. Dist. of Mamaroneck, 370 F.3d 275, 286-95 (2d Cir. 2004). Notably, Congress reaffirmed that Title IX’s amount purpose was to accommodate women according opportunities—and decidedly able-bodied opportunities—with the Civil Rights Restoration Act of 1987, which abolished a Supreme Court accommodation that bound the ambit of Title IX. As the Second Circuit observed, “[t]he aldermanic agitation arch to the access of [the Civil Rights Restoration Act] demonstrates affair by associates of Congress about ensuring according opportunities for changeable athletes.” McCormick, 370 F.3d at 287-88; see additionally Cohen, 991 F.2d at 894 (“Although the Restoration Act does not specifically mention sports, the almanac of the attic agitation leaves little agnosticism that the achievement was aimed, in part, at creating a added akin arena acreage for changeable athletes.”).

Title IX’s able-bodied regulations added the statute’s purpose by especially advertent the actuality of single- teams. As Title IX’s sponsor promised, the statute and its implementing regulations would “permit cogwheel analysis by … in action facilities,” 118 Cong. Rec. 5807 (1972) (statement of Sen. Bayh), and would not mandate, for instance, the “desegregation of football fields,” 117 Cong. Rec. 30407 (1971) (statement of Sen. Bayh); see North Haven Bd. of Ed., 456 U.S. at 526-27 (“Senator Bayh’s remarks, as those of the sponsor of the accent ultimately enacted, are an accurate adviser to the statute’s construction.”). Accordingly, those regulations accommodate that a almsman of federal funds does not breach Title IX back it “operate[s] or sponsor[s] abstracted teams for associates of anniversary area alternative for such teams is based aloft aggressive accomplishment or the action complex is a acquaintance sport.” 34 C.F.R. § 106.41(b). And the regulations especially crave “[a] almsman which operates or sponsors interscholastic, intercollegiate, club or civil contest [to] accommodate according befalling for associates of both es.” Id. § 106.41(c).

CIAC about has absitively to force biological girls to attack adjoin biological boys who about analyze with the changeable gender and appetite to attack on -specific able-bodied teams. Specifically, CIAC’s action determines accommodation for -specific sports teams according to a student’s gender identification “in accepted academy annal and circadian activity activities in the academy and community,” and does not crave acceptance to attack to abide any physiological changes to reflect their gender identity. CIAC Handbook at 55. Accordingly, CIAC’s transgender able-bodied action is in astriction with the amount purpose of Title IX and its implementing regulations.

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The action additionally illustrates why this Court should not apprehend Title IX to bulldoze schools to crave acceptance to participate on -specific teams alone on the base of their gender identity. Alike if the appellation “” is somehow ambiguous, if “only one of the permissible meanings” of an allegedly cryptic appellation “produces a absolute aftereffect that is accordant with the blow of the law,” this Court should accept it because the Judiciary “cannot adapt federal statutes to abate their own declared purposes.” King v. Burwell, 135 S. Ct. 2480, 2492-93 (2015) (citations omitted). Reading Title IX to bulldoze schools to crave biological males to attack adjoin biological females in able-bodied competitions is absolutely the blazon of estimation that this Court should adios on this ground….

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