A federal district court has held that discrimination because of sexual orientation is a form of sex discrimination. EEOC v. Scott Med. Health Ctr., P.C., 2016 U.S. DIst. LEXIS 153744 (W.D. Pa. 2016). Plaintiff complained of a sexually hostile work environment by deriding his sexual orientation. The court noted that "[t]here is no more obvious form of sex stereotyping than making a detemination that a person should conform to heterosexuality." The Supreme Court has never held that sexual orientation discrimination is a form of sex discrimination and a determination on this issue will have to wait until choice of the next Supreme Court Justice and an appropriate case.