Professor Chuck Henson’s article, Title VII Works – That’s Why We Don’t Like It, was cited by Judge Gerard E. Lynch in support of his review of the legislative history of Title VII.  Judge Lynch dissented in a 2nd Circuit Court opinion allowing sexual orientation claims to proceed because Title VII’s legislative history provides no support for the argument that sex discrimination encompassed sexual orientation discrimination.  Sex discrimination as the term was used in 1964 exclusively related to discrimination against women.