Before the 1960s almost everything about living openly as a lesbian, gay, bisexual, or transgender (LGBT) person was illegal. New York City laws against homosexual activities were particularly harsh. The Stonewall Uprising on June 28, 1969 is a milestone in the quest for LGBT civil rights and provided momentum for a movement.
Vine Creek Ranch at Death Valley National Park. Steady drought and record summer heat make Death Valley a land of extremes. Towering peaks are frosted with winter snow. Rare rainstorms bring vast fields of wildflowers. Lush oases harbor tiny fish and refuge for wildlife and humans. Despite its morbid name, a great diversity of life survives in Death Valley.
Located 2,600 miles southwest of Hawaii, the National Park of American Samoa is the most remote unit of the National Park System and the U.S. National Park south of the Equator. The Park spreads across three islands, 9,500 acres of tropical rainforest, and 4,000 acres of ocean, including coral reefs. While remote, the islands of American Samoa, true to the meaning of the word Samoa (Islands of Sacred Earth), are welcoming and offer beautiful landscapes and centuries of culture and history.
Seasoned backpacker and adventurer Yang Lu earned the grand prize in the 2015 Share the Experience photo contest with this image of a sunburst captured at sunrise in Glen Canyon National Recreation Area, Utah. Yang has made the outdoors part of his daily life and finds deep connection to the land through his lens.
“My photography is not just for recreation, it is to inspire people to explore these areas." -- Yang Lu
Photo by Yang Lu (www.sharetheexperience.org).
The following are some of the significant cases in this area. They are offered as a start to understanding the issues, and are not intended as a substitute for obtaining legal advice from DOI's Solicitor's Office or private counsel. These summaries are intended neither as a legal analysis regarding specific matters, nor as a complete review of the topic.
Western Air Lines, Inc. v. Criswell, 472 U.S. 400, 113 S.Ct. 2743 (1985). The Court invalidated an airline company's rule requiring flight engineers to retire at the age of sixty because the age discrimination was not reasonably necessary to the normal operation of the airline company's business.
Hazen Paper Co. v. Biggins, 507 U.S. 604, 113 S.Ct. 1701 (1993). The court stated that the essence of age discrimination is "for an older employee to be fired because the employer believes that productivity and competence decline with old age." Court held that there is no disparate treatment under the ADEA when the factor motivating the employer is some feature other than the employee's age..
O'Connor v. Consolidated Coin Caterers Corp., 517 U.S. 308, 116 S.Ct 1307 (1996). Held that a plaintiff's replacement need not be under 40 years of age in order for the plaintiff to make out a prima facie case of age discrimination under the McDonnell Douglas paradigm.
Oubre v. Entergy Operations, Inc., 118 S.Ct. 838 (1998). Not necessary to tender back consideration to challenge settlement of age discrimination case if there is a failure to comply with Older Workers Benefit Protection Act.