Windsor v. United States of America (2nd Cir. 2012): EJS signed on to an amicus brief filed by Lambda Legal, the National Center for Lesbian Rights, and McCarter & English LLP before the Second Circuit. The brief urged the court to apply heightened judicial scrutiny to the Defense of Marriage Act (DOMA) and other laws that classify on the basis of sexual orientation. The brief asserted that the historical discrimination suffered by lesbian, gay, and bisexual individuals calls for heightened scrutiny as an immutable, core trait that lacks any bearing on the ability of these individuals to perform in and contribute to society.