Report on U.S. Eleventh Circuit Court Ruling in Lange v. Houston County and its Implications for Sustainable Development Goals

Introduction

On September 9, 2025, the U.S. Court of Appeals for the Eleventh Circuit issued an en banc ruling in Anna Lange v. Houston County, Georgia, et. al., holding that the denial of health insurance coverage for gender-affirming surgery does not constitute sex discrimination under Title VII of the Civil Rights Act of 1964. This decision presents significant challenges to the advancement of several United Nations Sustainable Development Goals (SDGs), particularly SDG 3 (Good Health and Well-being), SDG 5 (Gender Equality), SDG 8 (Decent Work and Economic Growth), SDG 10 (Reduced Inequalities), and SDG 16 (Peace, Justice and Strong Institutions).

Case Analysis and Procedural History

Background of the Dispute

The case involved a transgender woman employed as a deputy with the Houston County Sheriff’s Office since 2006. The core issue stemmed from the county’s employee health insurance plan.

• The plaintiff, upon transitioning, received coverage for hormone therapy and psychological care, which are integral to gender-affirming treatment.
• Coverage was explicitly denied for gender-affirming surgery, based on an exclusion in the insurance plan for “[s]ervices and supplies for a sex change.”
• The plaintiff filed a discrimination charge, arguing the exclusion violated Title VII by discriminating on the basis of sex.

Judicial Rulings

1. District Court: The U.S. District Court for the Middle District of Georgia granted summary judgment in favor of the plaintiff, finding the exclusion constituted unlawful sex discrimination and issued a permanent injunction against its enforcement.
2. Three-Judge Panel: In 2024, a three-judge panel of the Eleventh Circuit affirmed the district court’s decision.
3. En Banc Reversal: The full Eleventh Circuit Court voted to rehear the case en banc and, in a 108-page opinion, reversed the prior rulings. The court held that the exclusion was not discriminatory because it applied equally to all individuals, regardless of sex or gender identity. The majority opinion drew parallels to the Supreme Court’s reasoning in United States v. Skrmetti and distinguished the case from the precedent set in Bostock v. Clayton County.

Implications for Sustainable Development Goals

The court’s decision has profound implications for progress on key SDGs by potentially institutionalizing barriers to healthcare, equality, and justice for a vulnerable population.

SDG 3: Good Health and Well-being

The ruling directly undermines the objective of ensuring healthy lives and promoting well-being for all. By permitting employers to exclude medically necessary gender-affirming care from health plans, the decision creates a significant barrier to essential healthcare for transgender individuals. This can lead to adverse physical and mental health outcomes, contrary to the universal health coverage targets embedded in SDG 3.

SDG 5: Gender Equality and SDG 10: Reduced Inequalities

This decision represents a setback for achieving gender equality and reducing inequalities. The court’s interpretation of non-discrimination law fails to protect transgender individuals, a marginalized group, from discriminatory practices in employee benefits. This reinforces systemic inequalities and hinders the goal of achieving full social, economic, and political inclusion for all, irrespective of gender identity, as mandated by SDG 5 and SDG 10.

SDG 8: Decent Work and Economic Growth

SDG 8 calls for full and productive employment and decent work for all. Comprehensive and non-discriminatory health benefits are a cornerstone of decent work. The ruling allows for unequal compensation in the form of benefits, creating a work environment that is not inclusive or equitable. This can impair the ability of transgender individuals to secure and maintain decent work, thereby affecting their economic stability and overall participation in the workforce.

SDG 16: Peace, Justice and Strong Institutions

The conflicting judicial opinions—from the district court to the en banc panel—and the influence of shifting executive orders highlight inconsistencies within the legal framework. SDG 16 aims to build effective, accountable, and inclusive institutions. This ruling, which narrows the scope of anti-discrimination protections, raises questions about the judiciary’s role in ensuring equal access to justice for all and protecting the rights of minority groups.

Recommendations for Stakeholder Action

In light of this ruling, organizations committed to the SDGs should proactively assess and align their policies with principles of equity and inclusion.

• Align Corporate Policy with SDG Principles: Employers should consult with benefits and legal counsel to review health plans. The objective should be to remove discriminatory exclusions and ensure that benefits packages actively support SDG 3 (Health), SDG 5 (Gender Equality), and SDG 8 (Decent Work) by providing comprehensive and equitable healthcare coverage for all employees.
• Monitor Evolving Legal and Regulatory Frameworks: Stakeholders must remain informed of changes in federal and state laws. Proactive adaptation of health and benefit plans is necessary to maintain compliance and uphold commitments to reducing inequality (SDG 10).
• Foster Inclusive and Equitable Workplaces: Organizations should conduct a thorough review of all employment policies. This assessment must ensure that internal standards not only comply with the law but also actively promote an environment of equity and equal treatment, reflecting the core values of the Sustainable Development Goals.

Analysis of Sustainable Development Goals in the Article

1. Which SDGs are addressed or connected to the issues highlighted in the article?

1. SDG 3: Good Health and Well-being

   • The article’s central theme is the denial of coverage for “gender-affirming surgery,” a medical procedure sought by the plaintiff for her health and well-being. The text explicitly mentions that other parts of her gender-affirming treatment, such as “hormone therapy… and psychological care,” were covered, highlighting the selective denial of a specific health service.

2. SDG 5: Gender Equality

   • The legal case revolves around alleged discrimination. The plaintiff argued that the denial of coverage was “unlawful sex discrimination under Title VII.” The entire legal debate, including the court’s decision that the exclusion was not discriminatory, directly engages with the principles of gender equality and non-discrimination.

3. SDG 8: Decent Work and Economic Growth

   • The issue arises within an employment context. The plaintiff is “a deputy with the Houston County Sheriff’s Office” and was enrolled in the “County’s health insurance plan” as an employee benefit. The dispute over health coverage is a matter of employment conditions and the right to non-discriminatory compensation and benefits, which are core components of decent work.

4. SDG 10: Reduced Inequalities

   • The article highlights the inequalities faced by a specific group—transgender individuals—in accessing healthcare through employer-sponsored plans. The case illustrates a systemic barrier, an “express exclusion for gender-affirming procedures,” that creates unequal outcomes for transgender employees compared to their cisgender colleagues.

5. SDG 16: Peace, Justice and Strong Institutions

   • The article is a detailed account of a legal process involving multiple judicial institutions, including the “Middle District of Georgia,” the “U.S. Court of Appeals for the Eleventh Circuit,” and the “Supreme Court.” It examines how these institutions interpret and enforce laws like Title VII, directly relating to access to justice and the role of the judiciary in upholding (or denying) rights.

2. What specific targets under those SDGs can be identified based on the article’s content?

1. Target 3.8: Achieve universal health coverage, including financial risk protection, access to quality essential health-care services…

   • The plaintiff’s struggle to get her “gender-affirming surgery” covered by the “County’s health insurance plan” is a direct example of a barrier to accessing essential healthcare services. The plan’s “express exclusion” prevents universal coverage for this employee.

2. Target 5.1: End all forms of discrimination against all women and girls everywhere.

   • The plaintiff, a transgender woman, filed a lawsuit alleging that the insurance exclusion constituted “discrimination on the basis of gender identity, which was a form of unlawful sex discrimination.” The case is a clear instance of challenging a policy perceived as discriminatory against a woman.

3. Target 8.5: By 2030, achieve full and productive employment and decent work for all women and men… and equal pay for work of equal value.

   • Health benefits are a form of compensation or “pay.” By denying a specific health benefit to the plaintiff based on her transgender status, the employer is arguably not providing equal compensation for work of equal value, which undermines the principle of decent work.

4. Target 10.3: Ensure equal opportunity and reduce inequalities of outcome, including by eliminating discriminatory laws, policies and practices…

   • The lawsuit directly targets a discriminatory policy: the insurance plan’s exclusion of “[s]ervices and supplies for a sex change.” The legal challenge is an attempt to eliminate a practice that creates an inequality of outcome in health benefits for transgender employees.

5. Target 16.b: Promote and enforce non-discriminatory laws and policies for sustainable development.

   • The entire article discusses the enforcement of non-discriminatory laws. The core question before the court was whether the County’s policy “facially violated Title VII,” a key federal anti-discrimination law. The differing court opinions and the reference to Executive Orders 13988 and 14168 illustrate the ongoing struggle over how to interpret and enforce non-discriminatory policies.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

1. Existence of discriminatory clauses in policies (Qualitative Indicator)

   • The article provides a direct example of a measurable indicator: the presence of discriminatory language in official policies. The insurance plan explicitly “excluded ‘[d]rugs for sex change surgery’ and ‘[s]ervices and supplies for a sex change…'” The removal or existence of such clauses in employer health plans is a clear indicator of progress (or lack thereof) toward Target 10.3.

2. Number of discrimination charges filed with administrative bodies (Quantitative Indicator)

   • The article implies a measurable action by stating the plaintiff “filed a charge of discrimination against Houston County with the Equal Employment Opportunity Commission.” Tracking the number of such charges filed on the basis of gender identity is an indicator of the prevalence of perceived discrimination and the use of institutional mechanisms for justice (relevant to Target 16.3).

3. Content of judicial rulings and executive orders (Qualitative Indicator)

   • The article details the “108-page en banc opinion” that reversed a prior decision, the influence of the Supreme Court’s opinion in Skrmetti, and the rescission of Executive Order 13988 by Executive Order 14168. The content and direction of these legal and executive actions serve as a qualitative indicator of whether the legal framework is strengthening or weakening protections against discrimination, which is relevant to Target 16.b.

4. Table of SDGs, Targets, and Indicators

Source: jdsupra.com