"Should a gentleman offer a lady a Tiparillo?" Such a question, popu- larized in a familiar advertisement only a few years ago, gives one keen insight into the stereotyped roles accepted for men and women during the past decade. In sharp relief today, women's liberation groups would have one believe that a man need not offer a woman anything; if she wants something, it is hers for the taking. Indeed, a recent national convention of hardcore feminists, echoing this aggressive attitude and citing that women compose fifty-three per cent of the nation's population, have warned that they intend to capture a majority of the elected offices in the United States. While such groups admittedly have implemented some social progress, the real moving force has been the federal courts, newly emboldened by the potent elixir of Title VII of the Civil Rights Act of 1964. Not only have the courts through this Act widely eliminated sex discrimination in the recent past, but they have continued to do so, both on the state and federal level, primarily through further interpretation in recent cases of the controversial "bona fide occupational qualification" exception to the Act. Specifically, the decision of New York State Division of Human Rights v. New York-Pennsylvania Professional Baseball League, in striking another blow against sex discrimination, further defined and logically narrowed the "'bona fide occupational qualification" (hereinafter BFOQ) exception.