In 2020, Alito wrote a dissent joined by Clarence Thomas to "Bostock v. Clayton County, Georgia", arguing that Title VII of the Civil Rights Act of 1964 does not prohibit discrimination by sexual orientation or gender identity and criticizing the majority's interpretation of Title VII. In October 2020, Alito agreed with the other justices to deny an appeal filed by Kim Davis, a county clerk who refused to issue marriage licenses to same-sex couples, but joined Thomas in writing a separate opinion reiterating his dissent in "Obergefell v. Hodges" and expressing his belief that the ruling was wrongly decided.