 Attorney Paul Smith, who argued "Lawrence v. Texas" (2003), stated that "[a]ny law, and I think there are dozens, that says you can’t discriminate because of sex is going to have a reckoning with this ruling"; indeed, Alito's dissent in "Bostock" notes that "[o]ver 100 federal statutes prohibit discrimination because of sex".American Civil Liberties Union (ACLU) lawyer Joshua Block said that "[a]ll of the Trump administration's actions ['curtailing protections for transgender Americans'] have been built around this assertion that Title VII [of the Civil Rights Act] and Title IX [of the Education Amendments of 1972] provide no protections to LGBTQ people... [i]t's an Achilles' heel that's been built into every single thing they've done.