they still held to do so would require legislative action. Classification of characteristic sex is a public health matter in New York; and New York City has its own health department which operates separately and autonomously from the New York State health department. An important case in Connecticut was Darnell v. Lloyd (1975), where the court found that substantial state interest must be demonstrated to justify refusing to grant a change in sex recorded on a birth certificate. In K. v. Health Division (1977), the Oregon Supreme Court rejected an application for a change of name or sex on the birth certificate of a transgender man who had undergone sex reassignment surgery, on the grounds that there was no legislative authority for such a change to be made. Driver's licenses All U.S. states allow the gender marker to be changed on a driver's license, although the requirements for doing so vary by state. Often, the requirements for changing one's driver's license are less stringent than those for changing the marker on the birth certificate. For example, until August 1, 2015, the state of Massachusetts required sex reassignment surgery for a birth certificate change, but only a form including a sworn statement from a physician that the applicant is in fact the new gender to correct the sex designation on a driver's license. As of November 2019, the Commonwealth of Massachusetts no longer requires any documentation or a sworn statement from a medical doctor in order to change one's gender marker on their drivers license/state ID. In order to change the gender marker, one only needs to fill out a new drivers license/ID card application reflecting the correct information. The state of Virginia has policies similar to those of Massachusetts, requiring SRS for a birth certificate change, but not for a driver's license change. Sometimes, the states' requirements and laws conflict with and are dependent on each other; for example, a transgender woman who was born in Tennessee but living in Kentucky will be unable to have the gender marker changed on her Kentucky driver's license. This is due to the fact that Kentucky requires an amended birth certificate reflecting the person's accurate gender, but the state of Tennessee does not change gender markers on birth certificates at all. In addition, a number of states and city jurisdictions have passed legislation to allow a third gender marker on official identification documents