Glad, Inc. offered health insurance benefits to unmarried same-sex domestic partners but not to unmarried, cohabiting heterosexual couples. Francis, an employee of Glad, Inc., challenged the benefit plan, claiming that it was in violation of Title VII of the Civil Rights Act. Under the Civil Rights Act, an employer may not discriminate against any individual on the basis of sex. Discuss the tools that a court may use in interpreting the Civil Rights Act.