prepared to fight systemic discrimination because the EEOC's broad authority, commissioner's charges, access to data, exemption from Rule 23 of the Federal Rules of Civil Procedure, focus on injunctive relief, and nationwide coverage. As a result, the commission created the role of Systemic Coordinator and Lead Systemic Investigator, and implemented programs that resulted in improved systemic expertise in the agency and all charges being investigated as potential systemic cases. In 2008, disability-based charges handled by the EEOC rose to a record 19,543, up 10.2 percent from the prior year and the highest level since 1995. That may again be showing that because the EEOC has not adjusted many of their initial 1991 fines for inflation, the backlog of EEOC cases illustrates erosion of deterrence. In 2011, the Commission included "sex-stereotyping" of lesbian, gay, and bisexual individuals, as a form of sex discrimination illegal under Title VII of the Civil Rights Act of 1964. In 2012, the Commission expanded protection provided by Title VII to transgender status and gender identity. In 2015, it concluded that for Title VII, sex discrimination includes discrimination based on sexual orientation. The Supreme Court upheld this position in R.G. & G.R. Harris Funeral Homes Inc. v. Equal Employment Opportunity Commission in 2020. In 2012, the EEOC achieved a second consecutive year of a significant reduction in the charge inventory, something not seen since FY 2002. Due to a concerted effort, the EEOC reduced the pending inventory of private sector charges by 10 percent from FY 2011, bringing the inventory level to 70,312. This inventory reduction is the second consecutive decrease of almost ten percent in charge inventory. During FY 2020, the EEOC secured a record amount of recovery, more than $535 million, for victims of discrimination in the workplace. Also, the agency reduced the private sector charge inventory by nearly 4 percent to the lowest level in 14 years. Notably, the agency increased the percentage of charges resolved and those with an outcome favorable to the charging party increased by nearly two percent, to 17.4 percent. Staffing, workload, and backlog In 1975, when the backlog reached more than 100,000 charges to be investigated, President Gerald Ford's full requested budget of $62 million was approved. A "Backlog Unit" was created in Philadelphia in 1978 to resolve the thousands of federal equal employment complaints inherited from the Civil Service Commission. In 1980, Eleanor Holmes Norton began re-characterizing the