Family Responsibilities Discrimination (“FRD”), also known as caregiver discrimination, was first articulated as a discriminatory employment practice in the early 2000s. By 2010, FRD cases had increased almost 400 percent, making it perhaps the fastest growing area of employment law. FRD grew out of the numerous statutes in the 1960s and 1970s designed to end discrimination against individuals on the basis of race and gender—passage of which was largely driven by President John F. Kennedy’s Commission on the Status of Women (“PCSW”), established by executive order in 1961. This influential commission, headed by Eleanor Roosevelt until her death, was charged with reviewing progress and making recommendations for constructive action in a number of areas. These included differences in the legal treatment of men and women in regard to political and civil rights, property rights, and family relations, and the employment policies and practices of the government of the United States. The Commission also advocated for additional affirmative steps to be taken through legislative, executive, or administrative action to ensure nondiscrimination on the basis of sex and to enhance constructive employment opportunities for women.