are also protected by the Americans with Disabilities Act. In 2017, interACT submitted an amicus curiae in the matter of Gavin Grimm (G.G. v. Gloucester County School Board) regarding protections in education for issues of gender identity under Title IX. The submission stated that the Gloucester County School Board held a "simplistic view of "physiological" sex [that] is demonstrably inaccurate as a matter of human biology. Moreover, it demeans many thousands of intersex youth by erasing their bodies and lives and placing them outside the recognition of the law". Identification documents Third sex classifications On Intersex Awareness Day (October 26) 2015, Lambda Legal filed a federal discrimination lawsuit against the United States Department of State for denying non-binary intersex navy veteran, Dana Zzyym, Associate Director of Intersex Campaign for Equality, a passport. On November 22, 2016, the District Court for the District of Colorado ruled in favor of Zzyym, stating that the State Department violated federal law. The ruling stated that the court found "no evidence that the Department followed a rational decision-making process in deciding to implement its binary-only gender passport policy," and ordered the U.S. Passport Agency to reconsider its earlier decision. On September 26, 2016, California resident Sara Kelly Keenan became described as the second person in the United States to legally change her gender to non-binary. Keenan, who uses she/her pronouns, identifies as intersex "both as my medical reality and as my gender identification ... It never occurred to me that this was an option, because I thought the gender change laws were strictly for transgender people. I decided to try and use the same framework to have a third gender." In December 2016, Keenan received a birth certificate with an 'Intersex' sex marker from New York City, the first birth certificate issued using this term in the United States. Keenan had applied for a "non-binary" birth certificate but the City Department of Health and Mental Hygiene required a biological term. Press coverage in December 2016 also disclosed that Ohio issued a birth certificate with a sex marker of 'hermaphrodite' in 2012. Ohio issues birth certificates based on "an historical record of the facts as they existed at the time of birth" and the individual was able to demonstrate a diagnosis of true hermaphrodite. Birth certificates are also known to have no sex specified. Right to life Robert Sparrow has stated that the genetic elimination of