Rouch World LLC v. Department of Civil Rights

Summary

The Michigan Supreme Court held that discrimination based on sexual orientation necessarily constitutes discrimination because of sex under the Elliott-Larsen Civil Rights Act, including when a public accommodation denies services on that basis. Applying the statute's but-for causation standard and plain meaning, the Court concluded that an individual's sex is necessarily part of a decision based on sexual orientation and that legislative history cannot override clear statutory language. The Court reversed the contrary portion of the Court of Claims' decision and remanded for further proceedings.