Jenner cites a few of his most egregious anti-LGBTQ actions. Namely, there's the memo from the Department of Health and Human Services which the New York Times obtained this week. In it, the Department proposes that, under Title IX, a law that governs gender discrimination, sex be determined by biology and "science." The draft states that sex would be "on a biological basis that is clear, grounded in science, objective and administrable." This stance on gender would effectively erase the term "transgender" from Title IX protection.