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Transgender rights in the United States vary considerably by jurisdiction. By the end of 2021, at least 130 bills had been introduced in 33 states to restrict the rights of transgender people.The Supreme Court of the United States has only once ruled directly on transgender rights, in 2020; in the case of R.G. & G.R. Harris Funeral Homes Inc. v. Equal Employment Opportunity Commission, the Court held that Title VII protections against sex discrimination in employment extend to transgender employees. The Equality Act, if passed, would prohibit discrimination on the basis of gender identity in employment; housing; public accommodations; education; federally funded programs; credit; and jury service.U.S. President Barack Obama issued an executive order prohibiting discrimination against transgender people in employment by the federal government and its contractors. In 2016, the Departments of Education and Justice issued a letter to schools receiving federal funding that interpreted Title IX protection to apply to gender identity and transgender students, advising schools to use a student's preferred name and pronouns and to allow use of bathrooms and locker rooms of the student's gender identity. Recognition and protection against discrimination is provided by some state and local jurisdictions to varying degrees. Birth certificates are typically issued by the Vital Records Office of the state (or equivalent territory, or capital district) where the birth occurred, and thus the listing of sex as male or female on the birth certificate (and whether or not this can be changed later) is regulated by state (or equivalent) law. However, federal law regulates sex as listed on a Consular Report of Birth Abroad, and other federal documents that list sex or name, such as the U.S. passport and Certificate of Naturalization. Laws concerning name changes in U.S. jurisdictions are also a complex mix of federal and state rules. States vary in the extent to which they recognize transgender people's gender identities, often depending on the steps the person has taken in their transition (including psychological therapy, hormone therapy), with some states making gender affirmation surgery a pre-requisite of recognition. Non-binary or genderqueer people may seek legal recognition of a gender identity other than that indicated by their birth sex; in 2016, Oregon became the first state to legally recognize non-binary people. When a person's gender is not officially recognized, they may seek associated changes, such as to their legal name, including on their birth certificate. The Supreme Court's decision in Obergefell v. Hodges established that equal protection requires all jurisdictions to recognize same-sex marriages, giving transgender people the right to marry regardless of whether their partners are legally considered to be same-sex or opposite-sex. The Matthew Shepard and James Byrd Jr. Hate Crimes Prevention Act, of 2009, added crimes motivated by a victim's actual or perceived gender, sexual orientation, gender identity, or disability to the federal definition of a hate crime. However, only some states and territories include gender identity in their hate crime laws.