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On July 21, 2020, the U.S. Court of Appeals for the Tenth Circuit in Frappied v. Affinity Gaming Black Hawk, LLC held that sex-plus-age discrimination claims are cognizable under Title VII of the Civil Rights Act of 1964. By taking a stance on the viability of sex-plus-age claims, the Tenth Circuit became the first circuit court to weigh in on the debate among the lower courts. Many federal district courts, relying on the availability of the Age Discrimination in Employment Act to address age discrimination claims, have rejected sex-plus-age claims under Title VII. This Comment argues that the Tenth Circuit’s decision is sound policy and logically follows the Supreme Court’s recent ruling in Bostock v. Clayton County.


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7 Sep 2022
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  • Subject
    • Civil Rights and Discrimination

    • Courts

    • Labor and Employment Law

    • Supreme Court of the United States

  • Journal title
    • Boston College Law Review

  • Volume
    • 62

  • Issue
    • 9

  • Pagination
    • E.Supp. II.-185

  • Date submitted

    7 September 2022

  • Additional information
    • Suggested Citation:

      Kayla King, Comment, Tenth Circuit Ruled in Favor of Sex-Plus-Age Claims of Discrimination Under Title VII in the Wake of Bostock v. Clayton County, 62 B.C. L. REV. E. SUPP. II.-185 (2021),