In Lampley v. Missouri Comm’n on Human Rights, the Missouri Supreme Court stated that sex stereotyping can form the basis of a sex discrimination claim under the Missouri Human Rights Act (MHRA). There, an employee claimed he was discriminated against because his behavior and appearance did not evoke sufficient “maleness” for his employer. Although the employee acknowledged he was gay and the MHRA does not protect sexual orientation, the Court stated that “an employee who suffers an adverse employment decision based on sex-based stereotypical attitudes of how [one] should act can support an inference of sex discrimination.” Moreover, “sexual orientation is incidental and irrelevant to sex stereotyping.” Employers must take care to ensure equal treatment of employees, regardless of stereotypes associated with one’s biological sex.