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 plantings of cherry trees originated in 1912 as a gift of friendship to the People of the United States from the People of Japan. In Japan, the flowering cherry tree, or "Sakura," is an exalted flowering plant. The beauty of the cherry blossom is a potent symbol equated with the evanescence of human life and epitomizes the transformation of Japanese culture throughout the ages.
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.
Meritor Savings Bank, FSB v. Vinson, 477 U.S. 57, 106 S.Ct. 2399 (1986). The Court held that Title VII prohibits sexual harassment in employment, even if the harassment does not cause a direct financial injury. It was the first time the Court recognized a cause of action for sexual harassment based on creation of a hostile intimidating work environment, which is in contrast with the quid pro quo case where sexual favors were demanded in return for favorable personnel decisions, or adverse action was taken based on the denial of sex.
Harris v. Forklift Systems, Inc., 510 U.S. 17, 114 S. Ct. 367 (1993). This case establishes the standard and perspective for evaluating whether a conduct is unlawful harassment. The Court confirmed that the severity and pervasiveness of a particular offensive conduct has both an objective and a subjective component.
Burlington Industries, Inc. v. Ellerth, 118 S.Ct. (1998); and Faragher v. City of Boca Raton, 118 S.Ct. 2275 (1998), held that an employer is vicariously liable to an employee for an actionable hostile environment created by a supervisor with immediate or successively higher authority over the employee. If the employer takes no tangible employment action, it may raise an affirmative defense to liability or damages, subject to proof by a preponderance of the evidence.