ENDA has passed. Whether or not to include such language has been a controversial part of the debate over the bill. In 2016 and again in 2017, Rep. Pete Olson [R-TX] introduced legislation to strictly interpret gender identity according to biology, which would end federal civil rights protection of gender identity. It remains legal at the federal level for parents to subject transgender children to conversion therapy. On October 4, 2017, Attorney General Jeff Sessions released a Department of Justice memo stating that Title VII of the 1964 Civil Rights Act prohibits discrimination based on sex, which he stated "is ordinarily defined to mean biologically male or female," but the law "does not prohibit discrimination based on gender identity per se." On January 30, 2012, HUD Secretary Shaun Donovan announced new regulations that would require all housing providers that receive HUD funding to prevent housing discrimination based on sexual orientation or gender identity. These regulations went into effect on March 5, 2012. State and local Over 225 jurisdictions including the District of Columbia (as of 2016) and 22 states (as of 2018) feature legislation that prohibit discrimination based on gender identity in either employment, housing, and/or public accommodations. In Anchorage, Alaska, voters chose in April 2018 to keep the existing protections for transgender people. In Massachusetts, a state law prohibited discrimination in public accommodations on the basis of gender identity; in October 2016, anti-transgender activists submitted the minimum number of signatures necessary to the Secretary of the Commonwealth of within Massachusetts to put the law up for repeal on a statewide ballot measure, Massachusetts voters chose on November 6, 2018 to retain the state law, with 68% in favor of upholding law, and 32% opposed. The Massachusetts Gender Identity Anti-Discrimination Initiative was the first-ever statewide ballot question of its kind in the United States. Some states and cities have banned conversion therapy for minors. Cases In 2000, a court ruling in Connecticut determined that conventional sex discrimination laws protected transgender persons. However, in 2011, to clarify and codify this ruling, a separate law was passed defining legal anti-discrimination protections on the basis of gender identity. On October 16, 1976, the Court rejected plaintiff's appeal in sex discrimination case involving termination from teaching job after sex reassignment surgery from a New Jersey school system. Carroll v. Talman Fed. Savs. & Loan Association, 604 F.2d 1028, 1032 (7th Cir.) 1979, held that