The Equal Employment Opportunity Commission (EEOC) has filed its first cases alleging sexual orientation discrimination as a form of sex discrimination under the 1964 Civil Rights Act. Since the 1964 Civil Rights Act was established, age and disability discrimination have been added to it, but this is the first time the EEOC is addressing discrimination based on sexual orientation. The EEOC has signaled this new inclusion, both under its latest Strategic Enforcement Plan and other publications. In one case that was filed in the Federal District Court in Maryland, an employee, whose sexual orientation was known to her coworkers, said her supervisor made numerous comments regarding her sexual orientation and appearance. These new cases may be litigated further and could make it as far as the Circuit Courts of Appeal or even the Supreme Court.