childbirth, or related medical conditions. . (13) The absence of explicit prohibitions of discrimination on the basis of sexual orientation and gender identity under Federal statutory law has created uncertainty for employers and other entities covered by Federal nondiscrimination laws and caused unnecessary hardships for LGBTQ individuals. (14) The Supreme Court correctly recognized in Hobby Lobby v. Burwell that the Religious Freedom Restoration Act of 1993 (RFRA) provides no … shield to those who cloak discrimination as religious practice to escape legal sanction. This Act reaffirms that crucial limitation on RFRA, that Congress did not intend for it to be used—and indeed it cannot be used—to provide a defense against allegations of discrimination on the basis of any protected trait. (15) Chapter 1 of title 9, United States Code (commonly known as the Federal Arbitration Act ), represented an exercise of legislative power that required courts to recognize private voluntary agreements to arbitrate commercial disputes at a time when the courts were refusing to do so on grounds that arbitration represented a usurpation of the authority of the courts to resolve legal disputes. (16) The Federal Arbitration Act did not, and should not have been interpreted to, supplant or nullify the legislatively created rights and remedies that Congress, exercising its power under article I of the Constitution of the United States, has granted to the people of the United States for resolving disputes in State and Federal courts. (17) Recent court decisions, including AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (2011) and American Express Co. v. Italian Colors Restaurant, 133 S. Ct. 2304 (2013), have interpreted the Federal Arbitration Act to broadly preempt rights and remedies established under substantive State and Federal law. As a result, these decisions have enabled business entities to avoid or nullify legal duties created by congressional enactment, resulting in millions of people in the United States being unable to