Human Rights Commission Meeting Minutes Regular Meeting July 16, 2020 Virtual/Electronic Meeting 6:00 pm to 8:00 pm 1. WELCOME a. CALL TO ORDER i. Chair, Shantell Bingham, called the meeting to order at 6:08 pm b. ROLL CALL i. Jeanette Abi-Nader ii. Shantell Bingham iii. Pheobe Brown iv. Earnest Chambers v. Olivia Gabbay vi. Melvin Grady vii. Jessica Harris viii. Laura Keppley ix. Kathryn Laughon x. Sue Lewis xi. Andy Orban xii. Lyndele von Schill xiii. Ann Smith (arrived 6:25 pm) c. MISSION (recited by all): Act as a strong advocate to justice and equal opportunity by providing citywide leadership and guidance in the area of civil rights. d. Moment of silence i. Honoring those who have suffered due to COVID-19 and police brutality 2. MATTERS BY THE PUBLIC a. PUBLIC COMMENT i. Robin Hoffman 1. Expressed concern around people not wearing masks in Riverview Park on the bike path 2. Feels that people should take responsibility for the spread of COVID-19 and wear masks while on the path and generally 3. Asked HRC to consider what authority and action it could take to ensure that people wear masks a. Suggests contacting Delegate Sally Hudson to request the imposition of fines for people who do not wear masks b. COMMISSION RESPONSE TO MATTERS BY THE PUBLIC i. To Robin Hoffman 1. Adding a rule-based response (like fines) might be a challenging in this time given the current public response to police overreach 2. The Governor’s executive order currently does not require masks to be worn outdoors 3. The HRC has no mechanism for enforcement 4. Could add a message to the OHR/HRC webpage that encourages people to wear masks 5. Not all people have equal access to masks 6. Governor will mandate indoor mask-wearing in late July 7. HRC could send a message to the City Manager suggesting that Parks and Recreation explore how they could encourage people to wear masks in parks 3. MINUTES a. Minutes pending HRC approval i. HRC regular meeting on 06-18-2020 ii. HRC ad hoc committee meeting on 07-02-2020 b. Motion to approve i. Lyndele von Schill c. Second i. Jeanette Abi-Nader d. Vote i. Approve: 7 ii. Oppose: 0 iii. Abstain: 6 4. BUSINESS MATTERS a. Ordinance Discussion with Allyson Davies of City Attorney’s Office i. Review of eight recommendations sent to City Council and the HRC by Walt Heinecke on behalf of several local social justice organizations 1. It is within the purview of the HRC to share its recommendations with City Council for the qualifications of the HRC Director/OHR Manager a. It is important that a qualified applicant possess the skills necessary to assist the HRC with meeting its obligations under the Human Rights Ordinance 2. Revising the position description for the HRC Director/OHR Manager is also within the purview of the HRC a. It is suggested and recommended that the HRC seek assistance from the Human Resources Department when making those revisions or advertising for the position 3. With regard to establishing agreements with the EEOC or HUD a. This is a legal issue i. The current ordinance is silent on this issue ii. The HRC should discuss what it is trying to accomplish with its ordinance with respect to this iii. If the ordinance requires the HRC to establish a FEPA or FHAP, then ordinance would be requiring something that is out of the HRC’s control 1. Both require agreement with outside agencies who must be willing to enter into that agreement 2. The HRC would need to convince City Council to allocate the monetary and staffing resources sufficient to meet the requirements to enter into such agreements iv. Considering the above, changing the ordinance to require the establishment of a FEPA or FHAP is not recommended from a legal perspective b. The HRC should ask what it is trying to accomplish with entering into a FEPA or FHAP agreement i. One potential reason to enter into these agreements is for the HRC to be able to offer as many resources as possible to individuals who may have suffered a human rights violation 1. To the extent that the HRC wants to amend the ordinance to direct the director to pursue ongoing plans to this end, short of expressly specifying the program, that would be advisable c. Questions from Commission i. Does the ordinance need to change before a Director could pursue agreements such as the FEPA or FHAP? 1. The ordinance does not need to expressly talk about the FEPA or the FHAP for the Director to pursue those agreements 2. Charlene may have started that process 3. The point is that it would be ill-advised to name specific types of agreements in the ordinance because the establishment of those agreements is not within the control of the Director of the HRC to achieve 4. Revise the ordinance to reflect what is necessary to reflect what is necessary to move toward such agreements without naming them specifically a. This could be done in a work session with the City Attorney’s Office ii. As the HRC works on revisions to the Director position description, is it advisable to include language in the recommendations that the person have experience with developing such agreements? 1. Yes. There is no reason not to include that language. iii. Staff notes that the FEPA agreement is required to investigate employment discrimination complaints in cases where the employer employs more than 16 (correction: 14) employees and where the action taken by the employer against the employee was something other than termination. Is a FHAP agreement required in order to investigate complaints of housing discrimination? 1. Housing discrimination is within the ordinance and within the OHR’s authority to investigate 2. There is a provision in the ordinance that the OHR/HRC not do something that another agency has already been designated to do a. The OHR/HRC becoming a designated agency may assist with any claims that might be made about authority or jurisdiction of the OHR/HRC under the ordinance 3. Counsel does not like the suggestion that if the OHR/HRC is not a FHAP it cannot investigate housing discrimination because the OHR/HRC does have that authority a. Complaints should be looked at case by case, based on the issue b. Becoming a FHAP gives clear authority under that agreement 4. The HRC should examine substantively what it seeks to accomplish and consider amendments to the ordinance that could assist with the HRC/OHR authority a. It is not advisable in the ordinance to reference too narrow or specific types of agreements b. If the HRC wants to pursue this further a work session could be arranged to define what the HRC would like to achieve iv. Staff notes that the ordinance currently states, very specifically, that the OHR/HRC will refer housing discrimination complaints to Piedmont Housing Alliance (PHA). In conversations with the Executive Director of PHA, it has been determined that this is an archaic reference to a service that PHA no longer provides 1. The OHR/HRC has general authority to enforce and investigate housing discrimination 2. The limitation in jurisdiction and authority stems from if there are other organizations that are already doing or have been designated to do that kind of work 3. If PHA is no longer designated to do that type of work there is no authority and jurisdiction question in that respect 4. If the HRC/OHR wants express authority, that would be achieved through an agreement v. If the ordinance is the HRC’s guiding framework, would we want to amend to say that we seek the most rigorous enforcement available? 1. There is a decided advantage to people not having seek remedy or enforcement in Richmond 2. HRC could develop language that says something like the Director of the HRC will develop programs locally that will allow enforcement to the greatest extent feasible 3. In a work session with the City Attorney’s Office the HRC can think through what it wants to accomplish and develop the language to accomplish that 4. There are many ways a Director could develop programs to achieve the underlying goal (example: the OHR previously hosted an EEOC investigator once per month) 4. Reduce the membership of the HRC back to 7 or 9 a. Not a legal question b. Ordinance specifies not less than 9 c. Commissioner comment i. No less than 9 offers potential for expansion to do specific work ii. At one time Commission got to 18 members but that expansion was the result of a delay in appointments by Council iii. Having too few members makes sub committees difficult iv. HRC has since shifted to ad hoc committees v. There may be a benefit to putting an upper limit on the number of Commissioners d. Recommending amendments to the ordinance with regard to membership size is within the purview of the HRC 5. Requirement that the HRC have members have expertise in housing, health, employment, education, and at least two commissioners be from organizations representing citizens of historically marginalized communities affected by housing and employment discrimination a. Legally, other boards and commissions have designated spots, so this is allowable and within purview of the HRC to recommend to Council b. Designating spots means that they can only be filled by the specified designee c. Recommendation #7 suggests designating a slot for a Council person i. This is also true for other boards and commissions and is allowable d. Commissioner questions i. What other boards and commissions have City Councilor designees? 1. Housing Authority 2. Retirement Commission e. The HRC could also request a Council liaison f. Chair requests non-legal guidance on having a Councilor as part of the HRC, given Allyson’s experience with other boards and commissions i. Advantage can be that Council knows specifically what the commission is working on 1. The Councilor can then make decisions when considering budgets ii. Disadvantage is that a Councilor tends to have more power and authority 1. If the HRC was exclusive citizen leadership, this could be viewed as a disadvantage iii. Regarding non-legal opinion regarding specifying categories of members 1. Not advisable, but not from a legal perspective 2. Could limit number of people able to serve, especially as recommended in letter a. 6 specific designees b. 3 citizens at-large g. Chair asks if the Police Civilian Review Board has designated members i. Allyson does not know, but they do have a designated City Councilor ii. Commissioner notes that, yes, there were specific designations, which caused a delay in appointments h. HRC could also seek expertise for studies or other work by finding people to work with outside membership i. Chair also notes that the HRC has benefited in the past from having people who have lived experience as a member of a protected class or who bring specific expertise i. Notes that shrinking the size of membership and making specific member designations might not actually achieve the same advantage ii. Recruitment would be challenging given the limited public awareness of the HRC j. Commissioner notes that personal recruitment of people with specific skills may be one way to capture the skills we seek k. Commissioner notes that applicants apply because they are interested in the issues that the HRC focuses on, and this has worked out in the past without designation 6. Recommendation to move oversight over the HRC or Director under the City Attorney’s Office or City Council a. That is not permitted under the City’s charter b. Section 5 of the Charter i. City employees are under the purview of the City Manager c. Changes to the Charter require going the General Assembly d. Commissioner question i. Should the position description include language that states that the Director reports directly to the City Manager? 1. Yes 2. The Office of Human Rights is within the City Manager’s direct chain of command and authority 7. Recommendation to have a City Council designee on the HRC a. Not a legal question b. HRC can request a Council liaison without making any changes to the ordinance c. The decision will then be up to Council 8. Recommendation to modify the ordinance to mandate that the HRC Chair report to Council every quarter on their progress related to systemic studies of discrimination a. Ordinance currently specifies an annual report b. It is not legally necessary to change the ordinance to provide additional reports to Council ii. Public comments from Facebook Live broadcast are addressed 1. Commenter notes concerns about a lack of HRC focus on inequity in the Charlottesville public schools a. Commissioner comments i. HRC previously had a liaison from UVA Minority Rights Coalition, but attendance was minimal ii. Previous attempts to form a working relationship with the City schools were shut down iii. School Division asserted it was an entity unto itself and that the HRC had no purview over discrimination within the schools iv. Commissioner expressed an interest in bringing a renewed focus on education to the HRC iii. Review of proposed ordinance updates 1. Proposed language regarding the protected class of “sex” a. Note: the page containing the proposed language was mistakenly omitted from the agenda packet but is added as an attachment to the minutes b. Commissioner reads the proposed language c. Discussion i. Objective of revision is to separate sexual orientation and gender identity from the protected class of sex 1. Gender and gender identity while related to sex are not the same 2. Bundling all terms together under sex, makes them less visible ii. Legal perspective 1. Authority is derived from federal law regarding discrimination on the basis of sex 2. Courts have had to expand the definition of sex to include sexual orientation and gender identity 3. Most recent supreme court case was still taking the authority from on the basis of sex, even though specific allegation was discrimination based on sexual orientation 4. The ordinance defines sex broadly and discrimination on the basis of sexual orientation is on the basis of sex 5. Allyson will do further research regarding whether it is allowable to add additional categories which are outside the category on which we derive authority and still maintain authority 6. Ordinance could read “on the basis of sex (to include sexual orientation and gender identity), but that does not achieve the goal of making them distinctly separate a. Allyson stipulates that she will still do further research on this iii. Staff notes that the proposed language does not include transgender status, which is currently listed in the ordinance as included in the definition of sex 1. General agreement that it should be included iv. Commissioner notes that different courts interpret the definition of sex differently and so sexual orientation, sexual identity, and transgender status are very vulnerable 1. Suggests that HRC should look for opportunities to be vocal and supportive of people who identify as members of these categories 2. Proposed language from October 2019 regarding the following a. New proposed language for Section 2-432 i. Staff reads the proposed language ii. Legal perspective 1. Allyson has approved these revisions but is not sure that John Blair has seen them yet 2. No legal issues with this particular section 3. Suggests submitting all amendments for consideration at the same time b. New proposed language for Section 2-433 i. Staff reads the proposed language ii. Legal perspective on why item D was stricken 1. Developing policies for the City as a whole is out of the realm of authority of the HRC based on charges and responsibilities 2. Within purview to provide policy recommendations iv. Next steps regarding ordinance amendments 1. Allyson is willing to participate in a work session with the HRC 2. Regarding the process for ordinance amendments a. HRC finalizes what amendments it wants to include b. Re-write the ordinance to include the amendments i. Allyson can help with this process ii. An initial version will show the stricken language next to the amended language c. HRC will then vote to adopt the new version as a recommendation to City Council i. Grouping amendments will maximize Council’s attention to the request d. Draft a Council agenda memo explaining why the changes are desired i. This memo would be referred to the City Attorney’s and City Manager’s Office for a final review e. Then it can be put on a Council agenda i. Members of the HRC would need to be present at the Council meeting to explain why the changes need to be made ii. Council will then decide whether to amend the ordinances 3. Chair recommends another ad hoc Committee meeting to discuss a. Staff will set up a meeting with Allyson b. Lyndele will chair the ad hoc committee and set up a doodle poll i. Sue volunteers to co-chair b. OHR STAFF REPORT i. Overview of Individual Complaint Handling Process & Commission Hearing 1. Tabled due to time 2. Commissioners are encouraged to contact staff with questions after reviewing the documents included in the agenda packet ii. General OHR staff report 1. Written report is included in the agenda packet a. Commissioners encouraged to review the report outside of meeting time and contact staff with any questions b. Staff provides two updates i. Clerk of Council sent an email just before the start of the HRC meeting noting that Council has requested a presentation from the HRC at a regular Council meeting on 8/3 or 8/17 in lieu of the proposed 2:2:1 meetings. ii. City Manager reports that HRC Director/OHR Manager hiring is on hold pending Council’s actions iii. Notes that Mayor may still wish to go forward with meeting with Chair and Vice Chair of the HRC c. Discussion regarding meetings with Council i. Chair expresses concern with repeated changes by Council to proposed dates and structures of meetings ii. Councilor Sena Magill is present as an attendee and Chair invites Councilor Magill to respond 1. Notes that she was presented with the choice between 2:2:1 meetings and a presentation from the HRC a. She was not aware that the HRC had already been preparing for the 2:2:1 meetings 2. Council had only discussed this by email 3. Councilor Magill is fine with 2:2:1 meetings or a presentation iii. Commissioner responses 1. Pushes back on the idea of August presentations 2. Attempt to schedule has been going on for three months 3. Would prefer a joint work session as originally proposed 4. HRC gets criticism for not acting quickly but it depends on action from Council iv. Councilor response 1. Suggests that a Council liaison would be beneficial for bringing information like this back to Council 2. Notes that this information was only provided very recently v. Chair response 1. The HRC can only respond to the dates that Council proposes to meet 2. Council has changed the proposed meeting three times 3. A presentation feels like a demotion from a 2:2:1 a. Notes that this is a reflection of the value that Council is placing on Human Rights and equity work b. Places barriers on the HRC’s ability to do work c. Asks Councilor Magill to take this information back to Council vi. Vice Chair response 1. Notes that HRC meets at the same time every month with very little variation 2. Feels there is no reason for Council not to know what the HRC is doing vii. Commissioners respond 1. City Manager has been invited three times to HRC meetings but has canceled each time 2. Councilor Magill is not solely responsible for the decisions that Council makes 3. City Council has historically not engaged with the HRC, so Councilor Magill’s presence is appreciated viii. Discussion regarding next steps for trying to work with Council 1. Chair asks Councilor Magill about the best course of action 2. Councilor Magill responds a. Suggests a Council liaison, even as non-voting member b. Having a designated liaison ensure Councilor attendance c. Notes that Council lacks a good system for reporting back on Commission work d. She is open to 2:2:1 meetings or other formats e. She is sensitive to Communications staff time f. Sending emails to the full Council is a good way to communicate and have things addressed 3. Chair responds a. Expresses preference for joint work session i. HRC has already prepared for this b. 2:2:1 meetings leading up to a joint work session in late August or September would also work 4. Commissioner comments a. Preference expressed for joint work session i. Needed to address concerns that have been raised by the public repeatedly b. Suggests that Council appoint someone as a liaison 5. Councilor Magill responds a. In January Council is presented with a list of boards and Commissions with Council liaisons b. Councilors then choose who will attend which meetings c. The HRC was not on this list d. Commissions must request Council liaison e. Councilor Magill will take back to Council that HRC would prefer 2:2:1 meetings or joint work session f. Will express that a presentation is not what is needed now 6. Commissioner comments a. Understood that 2:2:1 meetings were not to replace a work session but rather leading up to a work session 7. Chair responds a. Confirms that 2:2:1s are preparatory for the joint work session b. The intent was to give some time for Commissioners and Councilors to get acquainted before the work session since there has been no works session in over a year 8. Councilor Magill responds a. Confirms that 2:2:1 meetings are preparatory for future meetings b. Notes that Council is trying to balance workload and recognizes that HRC is important c. The Mayor typically sets meetings with Commissions d. Will bring to Council i. An HRC presentation is not in the spirit of the work that needs to be done ii. Informative 2:2:1s would be beneficial before a work session 9. Chair responds a. Asks about timing for upcoming meetings b. Notes that the original work session was planned for July 28th and planned months in advance c. Asks if August 28th could work 10. Vice Chair responds a. Suggests that the schedule can be discussed during the Chair and Vice Chair meeting with the Mayor b. The Mayor sets the agenda for Council 11. Councilor Magill responds a. Notes that Council has several other things in August i. Strategic planning ii. Police open forum iii. Regular Council meetings b. September would likely be more possible for a work session with Council and the HRC c. Councilor Magill does not set the agendas but can make suggestions 12. Commissioner responds a. The initial email from Kyna Thomas regarding the 2:2:1s did propose them in preparation for a work session b. Holding 2:2:1 meetings in preparation for a work session in September would be in the spirit of the work 13. Next steps a. Councilor Magill will communicate to Council the HRC’s interest in going forth with the 2:2:1 meetings b. Councilor Magill will also communicate the importance of a joint work session since Council and the HRC have not been engaged in over a year c. Councilor Magill will also communicate that a presentation is not in the spirit of the work that needs to be done at this time d. Councilor Magill will send out an email tonight to this effect d. CHAIR UPDATE i. Housekeeping: Attendance Policy and Commissioner Engagement 1. Discussion via email 2. No clear policy around attendance 3. Chair will share attendance over past year for reference a. Intention is to ensure that all are actively engaged and participating 4. Chair thanks Catherine Spear for her service 5. Chair thanks Idil Aktan for her service 6. Chair also notes that Melvin Grady’s term is ending in August a. Melvin is able to run for another term 7. Olivia Gabbay’s term will also end soon as well a. She can also reapply for another term ii. 2-2-1 Meetings with City Council 1. See discussion above 5. WORK SESSION a. AD HOC COMMITTEE UPDATES i. Joint Meetings with Council/ Reviewing package for City Council to Review 1. Working on updates to position description a. Jeanette has modified the description based on feedback from Allyson during this meeting 2. The ad hoc committee also has an agenda prepared for the joint work session with Council and talking points for the 2:2:1 meetings 3. All documents are on Google drive and are open for further comments 4. Suggests meeting again before the joint session ii. Councilor Magill responds 1. Went through old emails and notes that she was the person who suggested the HRC presentation to Council 2. Notes a desire to be transparent and cites confusion about the purpose of the 2:2:1 meetings and apologizes for the delay 3. Notes that Mayor was not sure this work should happen before a Director of the HRC was hired 4. Asks HRC preference iii. Commissioner response 1. Part of the reason for requesting these meetings was to make recommendations regarding the hiring of a new Director 2. Mayor also asked for HRC to send a proposal a. Documents mentioned above can be assembled into a packet for HRC Chair to submit to Council for review iv. Chair responds 1. Thanks Councilor Magill for her honesty and transparency 2. Asks if a vote is required for submission of the documents to Council v. Staff responds 1. Suggests downloading the draft documents from Google Drive and circulating the documents with the changes incorporated so all Commissioners can review vi. Commissioner response 1. Ad hoc committees can present information to the body for HRC consideration 2. No need for a vote vii. Next steps 1. Jeanette will send the documents to Todd for circulation to the whole HRC 2. Deadline set for Wednesday, July 22, for HRC to review documents before Shantell sends to Council 6. UPDATES FROM COMMISSIONERS a. VAHR i. The HRC has not paid any dues for any members for two years ii. Sue will send the email to staff for further action b. Commissioner proposal for agenda items i. Discussion on the change in meeting time ii. Discussion around UVA students returning in the fall 1. Human Rights issue if return of students affects people in the community iii. Chair response 1. Equity Center Director has been tasked with this 2. Could potentially offer recommendations to Director c. Commissioner comment regarding size and make-up of the Commission i. Narrative has been that large Commission size is due to Council delay in appointing people and a rush to appoint 1. If true, that implies a lack of consideration of the applicants 2. Council appointed people without reviewing skills or backgrounds regarding the value of appointments 3. Feels demoralizing to describe appointments in that way ii. Staff response 1. Notes that Charlene requested copies of applicant packets prior to appointments 2. Commission reviewed all applicants and recommended to Council to approve all applicants based on merit iii. Commissioner response 1. Narrative should therefore be that everyone was in fact appropriately appointed d. Commissioner notes that July 23, is the anniversary of the Americans with Disabilities Act e. Commissioner expresses support for a non-voting Council liaison f. Commissioner asks for thoughts on public comment process i. Asks of public comment will be taken throughout the meeting ii. Notes that written comment took precedence over someone who had raised their hand iii. Suggests thinking through the process iv. Chair response 1. Agrees that reviewing all social media platforms during the public meeting is awkward 2. There is valuable information in the comments on social media 3. Is up to HRC whether to monitor social media platforms 4. Suggests further discussion outside the meeting on how to improve voting and public engagement v. Vice-Chair notes that Lyndele was also able to paste the Facebook comments into the Chat, so it may not be necessary to read aloud vi. Lyndele notes that the public cannot read the chat, so it does need to be read aloud 7. MATTERS BY THE PUBLIC a. PUBLIC COMMENT i. Robin Hoffman 1. Notes that public can read documents on screen share so no need to read 2. Appreciates Commission’s work 3. Regarding regulation of mask-wearing a. Suggests that HRC could present an alternative message to enforcement b. Consider peoples’ rights to be protected from harm c. COVID is changing how the rules apply to the world in all of the protected activities 4. She is nervous about the future of what harms might occur a. Presents the example of UVA students returning ii. Lyndele reads various public comments from Facebook Live 1. [Not included here due to context] b. COMMISSION RESPONSE TO MATTERS BY THE PUBLIC i. Chair response 1. Notes that HRC reads documents because there may be participants who are visually-impaired 8. NEXT STEPS a. HRC to seek assistance from the Human Resources Department when making revisions to the HRC Director/OHR Manager position description and with advertising the position. b. Staff will set up a meeting with Allyson Davies to further discuss changes to the Human Rights Ordinance i. Lyndele will chair the ad hoc committee and set up a doodle poll ii. Sue will co-chair c. Chair will share HRC attendance over past year for Commissioner reference and to ensure that all are actively engaged and participating d. Jeanette will send the Google Drive documents pertaining to the joint work session and 2:2:1 meetings to staff for circulation to the HRC for comments before Wednesday, July 22 e. Chair will send the finalized documents to Council for review after Wednesday, July 22 f. Vice Chair will send emails to staff regarding dues owed to the VAHR g. Chair will add the following to the agenda for August i. Meeting time change from 6pm ii. Human Rights concerns regarding UVA students returning h. Chair will initiate further discussion over email regarding improved voting and public engagement through Zoom webinars 9. ADJOURNED 9:22 PM Proposal to amend the City of Charlottesville’s Human Rights Ordinance to include sexual orientation and gender identity : In light of the June 2020 Supreme Court ruling 1 , the Charlottesville Human Rights Commission requests that the City’s Human Rights Ordinance 2 be amended to include sexual orientation and gender identity protection. Current Ordinance It shall be unlawful and a violation of this article for any person, partnership, corporation or other entity to engage in discrimination in housing, employment, public accommodations, credit, and education on the basis of race, color, religion, sex, pregnancy, childbirth or related medical conditions, national origin, age, marital status or disability. Proposed Ordinance It shall be unlawful and a violation of this article for any person, partnership, corporation or other entity to engage in discrimination in housing, employment, public accommodations, credit, and education on the basis of race, color, religion, sex, sexual orientation, gender identity , pregnancy, childbirth or related medical conditions, national origin, age, marital status or disability. Resources 1Supreme Court Decision - 17-1618 Bostock v. Clayton County (06/15/2020) https://www.supremecourt.gov/opinions/19pdf/17-1618_hfci.pdf 2 Charlottesville Human Rights Ordinance https://www.charlottesville.gov/Faq.aspx?QID=310 Sexual Orientation/Gender Identity Laws - Virginia https://www.lgbtmap.org/equality_maps/profile_state/VA Cities and Counties in the U.S. with non-discrimination ordinances that include gender identity https://www.hrc.org/resources/cities-and-counties-with-non-discrimination-ordinances-that- includ e-gender City of Portland, Civil Rights Policy https://www.portlandoregon.gov/citycode/28598 New York City Commission on Human Rights Legal Enforcement Guidance on Discrimination on the Basis of Gender Identity or Expression: Local Law No. 3 (2002); N.Y.C. Admin. Code § 8-102(23) https://www1.nyc.gov/site/cchr/law/legal-guidances-gender-identity-expression.page