been overruled. Harrah's implemented a policy named "Personal Best", in which it dictated a general dress code for its male and female employees. Females were required to wear makeup, and there were similar rules for males. One female employee, Darlene Jesperson, objected and sued under Title VII. In Jespersen v. Harrah's Operating Co., No. 03-15045 (9th Cir. April 14, 2006), plaintiff conceded that dress codes could be legitimate but that certain aspects could nevertheless be demeaning; plaintiff also cited Price Waterhouse. The Ninth Circuit disagreed, upholding the practice of business-related gender-specific dress codes. When such a dress code is in force, an employee amid transition could find it impossible to obey the rules. In Glenn v. Brumby, the 11th Circuit Court of Appeals held that the Equal Protection Clause prevented the state of Georgia from discriminating against an employee for being transgender. Education The Obama administration took the position that Title IX's prohibition on discrimination on the basis of "sex" encompasses discrimination on the basis of gender identity and gender expression. In 2016, the Fourth Circuit became the first Court of Appeals to agree with the administration on the scope of Title IX as applied to transgender students, in the case of Virginia high school student Gavin Grimm (G.G. v. Gloucester County School Board). The validity of the executive's position is being tested further in the federal courts. In 2017 the ACLU, representing Grimm, stated that they had stopped Grimm's "request for an immediate halt to the Gloucester County School Board's policy prohibiting him and other transgender students from using the common restrooms at school" but were "moving forward with his claim for damages and his demand to end the anti-trans policy permanently." Judge Allen of the U.S. District Court of the Eastern District of Virginia, in May 2018, ruled that Grimm's discrimination claim was valid based upon Title IX and the U.S. Constitution's equal protection clause. In 2014, Maryland Senate passed a bill that "bans discrimination based on sexual orientation and sexual identity but includes an exemption for religious organizations, private clubs and educational institutions. According to the Vera Institute in 2016, "transgender youth are more likely to leave school due to harassment, physical assault, and sexual violence". In 2016, guidance was issued by the Departments of Justice and Education stating that schools which receive federal money must treat a student's gender identity as their sex (for example, in