A federal district court recently ruled on a significant discrimination case involving Sloan Manning and the Office of Personnel Management (OPM). The court's decision affects how federal employees might pursue claims related to discrimination based on sex and disability. The ruling comes as the court granted OPM's motion to dismiss certain claims while allowing others to proceed, highlighting ongoing challenges in securing equitable healthcare coverage for transgender individuals.

The case, Manning v. Office of Personnel Management, Civil Action No. 2025-0342, was filed on September 29, 2026, by Judge Colleen Kollar-Kotelly in the District Court for the District of Columbia. The court’s opinion addressed Manning's allegations of sex and disability discrimination stemming from OPM's contract with a health insurance provider that denied coverage for part of his medical treatment.

Background

Sloan Manning, a former employee of the Internal Revenue Service (IRS), worked for the federal government for over a decade. He was diagnosed with gender dysphoria in 2012 and sought to transition medically and socially from female to male. As part of this transition, Manning required male chest reconstruction surgery, which included a bilateral mastectomy and nipple-areola reconstruction.

In January 2015, Manning's doctor submitted a request for pre-authorization to Aetna, the health insurance carrier managing his Federal Employee Health Benefits (FEHB) plan. While Aetna approved coverage for the mastectomy, it denied coverage for the nipple-areola reconstruction. Manning appealed this decision, but Aetna upheld its denial, forcing him and his wife to pay for the procedure out of pocket.

Manning initiated the Equal Employment Opportunity (EEO) complaint process with OPM in May 2015. After several procedural steps, including a formal complaint and an appeal to the Equal Employment Opportunity Commission (EEOC), Manning's case was ultimately dismissed by OPM, prompting him to file a lawsuit in federal court in 2025.

The Ruling

In the recent ruling, the court addressed OPM's motion to dismiss certain claims brought by Manning. The court dismissed Manning's claims under Section 1557 of the Affordable Care Act, the Americans with Disabilities Act (ADA), and constitutional provisions while allowing claims under Title VII of the Civil Rights Act and the Rehabilitation Act to proceed.

The court noted that “Title VII and the Rehabilitation Act provide the exclusive remedy for federal employees for claims of employment discrimination based on race, religion, sex, national origin, and disability.”

Judge Kollar-Kotelly highlighted that the ADA does not apply to federal employees, as the federal government is not considered an employer under the ADA. The court also ruled that Manning's claims under Section 1557 and the Constitution were essentially duplicative of his Title VII and Rehabilitation Act claims, leading to their dismissal.

Impact

This ruling is significant for several reasons. First, it underscores the limitations federal employees face when seeking redress for discrimination claims, particularly regarding healthcare coverage for transgender individuals. By allowing claims under Title VII and the Rehabilitation Act to proceed, the court affirms the importance of these laws in protecting employees from discrimination based on sex and disability.

The decision also reinforces the precedent that federal employees cannot pursue parallel claims under other federal laws if those claims are based on the same set of facts as Title VII or the Rehabilitation Act. This could impact future cases where federal employees face discrimination related to healthcare coverage and other employment-related issues.

What's Next

Following this ruling, Manning's claims under Title VII and the Rehabilitation Act will move forward in court. The dismissed claims cannot be appealed, but Manning retains the right to pursue his valid claims. The outcome of this case may also influence how OPM and other federal agencies handle discrimination claims and healthcare coverage for transgender employees in the future.