encompass transgender individuals. When interpreting a federal statute legislative history is a significant factor for a court to consider. In Train v. Colorado Public Interest Research Group, the Supreme Court went so far as to hold that interpreting a federal statute without looking at its legislative history was “reversible error.” There is a lack of legislative history regarding the of “sex” as a prohibited class of employment discrimination in Title VII. House Report No. 914, 88th Cong., 2d Sess. (1964) states that Title VII was amended to include the category of “sex” without any prior legislative hearings or debate. Grossman v. Bernards Twp. Bd. of Educ.,.The amendment was proposed by Congressmen Smith of Virginia. Despite the lack of legislative history, Mr. Smith’s remarks exemplify Congress’s intent to not include transgender as a protected class under Title VII: “Now, I am very serious about this amendment. […] I think it will do some good for the minority sex.” 110 Congressional Record (88th Congress, 2nd Session, 1964), 2,577. Further, Congressmen Gathings added, “The amendment of the gentleman from Virginia to protect the employment rights of all women should be agreed to.” In addition, Ulane went through an extensive analysis of Title VII’s legislative history and concluded that “had Congress intended more, surely the legislative history would have at least mentioned its intended broad coverage of […] transsexuals and would no doubt have sparked an interesting debate.” The Congressional Record coupled with Ulane demonstrates that the word “sex” under Title VII was intended for the “minority sex” meaning that the intent of Congress in 1964 was to restrict the term “sex” to its plain biological meaning. This position is bolstered, discussed below, in Oiler v W>