 Archbishop José Horacio Gómez, president of the United States Conference of Catholic Bishops (which had filed an amicus brief against Bostock), called the ruling an "injustice" and said he was "deeply concerned that the U.S. Supreme Court has effectively redefined the legal meaning of 'sex' in our nation's civil rights law".Franklin Graham said it was "a very sad day".Dan McLaughlin of the "National Review" postulated that Dixiecrat Howard W. Smith's insertion of the word "sex" in Title VII of the Civil Rights Act of 1964 had inadvertently protected sexual orientation and gender identity from employment discrimination.