On December 12, 2013, the Court of Justice of the European Union ruled [3] in Frédéric Hay v Crédit agricole mutuel de Charente-Maritime et des Deux-Sèvres that, according to the press release [4], “[e]mployees who enter into a civil partnership with a partner of the same sex must be granted the same benefits as those granted to their colleagues upon their marriage, where marriage is not possible for homosexual couples.”  Mr. Hay, who had entered into a PACS arrangement (civil solidarity pact) with his same-sex partner, was an employee of Crédit agricole mutuel, which grants certain benefits—days of special leave and a salary bonus—to employees on the occasion of their marriage.  Hay was refused those benefits on the ground that they were granted only upon marriage and subsequently challenged the refusal in French court.  The Cour de cassation “asked the Court of Justice whether the difference in treatment for persons who have entered into a PACS arrangement with their same-sex partner constitutes discrimination based on sexual orientation, which is prohibited under EU rules on employment relations,” specifically Article 2(2)(a) of Council Directive 2000/78/EC of 27 November 2000 [5] establishing a general framework for equal treatment in employment and occupation.  In making its ruling, the Court reasoned that the refusal to grant such benefits “constitutes direct discrimination based on sexual orientation.”