  Applying Butler's ideas about embodiment, which emphasize the inconstancy of conceptualizations of bodily kinds, feminist legal scholar Kathryn Abrams contends that one reason the Americans with Disabilities Act (ADA) has had trouble in the courts, with most plaintiffs losing their cases (at least under Title I - Employment), is because the social model disrupts a premise of mainstream jurisprudence. The legal norm presumes that human bodies are biological objects of fixed kinds, whereas on Butler's theory bodies are contingently constituted by transient social interactions (Abrams 2011:76).  However, not all judicial thinking has been so narrow. For example, in 2006 a pre-surgery transexual individual's denial of employment suit was allowed to proceed, despite the defendant's claim that Title VII did not apply because the plaintiff was not a woman; in supporting the plaintiff, the court invoked the factual complexities that underlie human sexual identity and explained that these complexities are occasioned by how biological sexuality interacts with social, physiological, and legal conceptions of gender (see Schroer v. Billington 2006, 2009).