benefits, GLBT employees continue to face challenges in the workplace that their non-queer coworkers do not. According to a 2009 survey, 58 percent of GLBT employees say coworkers make jokes or derogatory comments about GLBT people "at least once in a while". But perhaps the single greatest contributor to the GLBT experience in the workplace is the decision of employees to come out or remain closeted at work. Brian McNaught, a lauded leader of gay sensitivity training, explained the pressures that surround a decision, noting that "gay people who have to worry about what will happen to them if they come out […] generally produce at a lower level than gay employees who don't" as it takes much energy to "put on a mask"; 54 percent of closeted employees report "lying about their personal lives in the past twelve months". Non-GLBT employees are never required to make the conscious decision to share or hide the details of their personal lives, while GLBT employees make that very decision daily. Even with the added stress of the "mask", a 2009 survey concluded 51 percent of GLBT employees report hiding their GLBT identity to those at work. These unique experiences have compounded to create significant concrete inequalities for GLBT workers in today's workplaces. For queer employees, there is an undeniable "pink ceiling"; not a single Fortune 1000 CEO is openly gay, and it is documented that being gay negatively impacts an employee's opportunity for promotion – 28 percent of gay employees remain closeted "because they feel it may be an obstacle to career advancement or development opportunities". Some of these fears are well founded; only 21 states and the District of Columbia currently have employment laws prohibiting discrimination based on sexual orientation – in many states it is thus perfectly legal to fire an employee for being gay. In 2020, the US Supreme Court ruled that the 1964 Civil Rights Act protects gay, lesbian, and transgender employees from discrimination based on sex. However, the federal law still did not protect LGBT employees from being fired based on their sexual orientation or gender identity in businesses of 15 workers or less. In addition to these challenges, transgender employees in particular also face many more. Though courts recently concluded that transgenderism is a protected class under Title VII of the Civil Rights Act of 1964, most notably in Smith v. City of Salem in 2004,