4 — Friday, March 13, 2020
Opinion
The Michigan Daily — michigandaily.com

Congratulations to the James B. Angell Scholars for 7+ Terms

97th Annual Honors Convocation | Sunday, March 15, 2020 | www.honors.umich.edu

The following students will be among those recognized during the Honors Convocation program on Sunday, March 15, 2020. These individuals have demonstrated the highest level of
undergraduate academic success by achieving seven or more consecutive terms of all A’s (A+, A, or A-) while taking a minimum of 14 credit hours, including at least 12 graded (A-E) credits,
and earning the designation of Angell Scholar. The University of Michigan congratulates these students on their superior scholastic achievement and wishes them continued success.

Tiffany Youling Chen
College of Literature, Science, and the Arts
Kailyn Grace Delonis*
College of Business, Dearborn
Skylar Marie Gleason
College of Literature, Science, and the Arts
Jillian C. Heidenreich*
College of Health Sciences, Flint
Emily Jean Iwanski
College of Engineering
Chen Liang
Gerald R. Ford School of Public Policy

Seraphina Gabrielle Provenzano
School of Kinesiology
Luis Enrique Rangel DaCosta
School of Music, Theatre & Dance
Jacob Wayne Rogers
School of Music, Theatre & Dance
Daniel Joseph Vonarburg
College of Literature, Science, and the Arts
Mackenzie Zierau
School of Nursing

Sujai S. Arakali
College of Literature, Science, and the Arts
Anna E. Argento
College of Literature, Science, and the Arts
Yuxuan Bao
College of Literature, Science, and the Arts
Hunter Nicole Berger
College of Literature, Science, and the Arts
Olivia A. Bloomhuff
College of Literature, Science, and the Arts
Erin N. Boensch
College of Arts & Sciences, Flint
Stuart T. Brabbs
College of Literature, Science, and the Arts
Bryan James Brauchler
College of Engineering & Computer Science, Dearborn
Jasmine C. Chang
College of Engineering
Fee Lia Christoph
Penny W. Stamps School of Art & Design
Dan Liviu Ciotlos
College of Literature, Science, and the Arts
Rachel A. Clark
College of Literature, Science, and the Arts
Melissa S. Connop
College of Literature, Science, and the Arts
Benjamin Jason Cormier
School of Music, Theatre & Dance
Andrew Daulton
College of Business, Dearborn
Katherine D. Dodge
College of Literature, Science, and the Arts
Sara Navaid Farooqui
College of Literature, Science, and the Arts
Taylor A. Feddersen
College of Engineering
Ashley Francis
College of Literature, Science, and the Arts
Evelyn A. Gagnon
College of Arts & Sciences, Flint
Alaina M. Galasso
School of Music, Theatre & Dance
Lukas Jensen Heberling
College of Engineering
Sarah Herndl
School of Nursing
Nicole E. Hocott
College of Literature, Science, and the Arts
Leah D. Hong
A. Alfred Taubman College of Architecture

and Urban Planning
Phoebe Aidan Hopp
College of Literature, Science, and the Arts
Rachel Michelle Horton
School of Nursing
Ruchita Iyer
School of Public Health
Natalia Marie Jenuwine
College of Literature, Science, and the Arts
Jason G. Jin
Stephen M. Ross School of Business
Razeen Karim
College of Literature, Science, and the Arts
Monica Kim
College of Literature, Science, and the Arts
Nolan Timothy Klunder
College of Literature, Science, and the Arts
Jacob E. Kopnick
Gerald R. Ford School of Public Policy
Joshua Davis Kremers
College of Engineering
David A. Kucher
College of Engineering
Rhea Kulkarni
School of Information
Malhar B. Kute
School of Music, Theatre & Dance
Sebastian Elijah Leder Macek
College of Literature, Science, and the Arts
Jenna L. Manske
College of Literature, Science, and the Arts
Lauren E. May
Gerald R. Ford School of Public Policy
Kathleen M. Mazur
School of Nursing
Devon K. Mccleskey
School of Music, Theatre & Dance
Kaitlin Elizabeth McKernan
College of Literature, Science, and the Arts

Leo J. McManus
College of Engineering
Nitesh Mohan
College of Literature, Science, and the Arts
Katie Munson
College of Literature, Science, and the Arts
Nathan Ng
College of Engineering
Samir Vahdat Nooshabadi
College of Engineering
Kaelan J. Oldani
College of Engineering
Kelly Marie O’Toole
College of Engineering
Sarah Irene Overbeck*
College of Engineering & Computer Science, Dearborn
Kathryn Parkhurst
School of Nursing
Cameron B. Pawlik
College of Literature, Science, and the Arts
Quinn Michaela Powell
College of Literature, Science, and the Arts
Elena A. Ramirez-Gorski
College of Literature, Science, and the Arts
Safia Khadija Sayed
College of Literature, Science, and the Arts
Madeleine Elizabeth Schmitter
School of Public Health
Karalyn Jeann Schubring
School of Music, Theatre & Dance
Jasnoor Singh
College of Engineering
Ashton J. Skillman
College of Literature, Science, and the Arts
Griffin Teresa St Onge
College of Literature, Science, and the Arts
Jared M. Stolove
College of Literature, Science, and the Arts
Ethan Benjy Szlezinger
College of Literature, Science, and the Arts
Craig I. Tarnopol
Stephen M. Ross School of Business
Jeremy P. Tervo
College of Literature, Science, and the Arts
Kenny Topolovec
College of Engineering & Computer Science, Dearborn
Michael Ustes
College of Engineering & Computer Science, Dearborn
Alyssa Nicole Van Scoy
College of Business, Dearborn
Alexander Vidinas
College of Literature, Science, and the Arts
Matthew H. Ward
College of Literature, Science, and the Arts
Isabel Morgan Wayner
School of Music, Theatre & Dance
Ellie Rose White
College of Arts, Sciences, & Letters, Dearborn
Claudia K. Wong
College of Literature, Science, and the Arts
Florence Ying Wai Woo
School of Music, Theatre & Dance
Kay M. Wright
A. Alfred Taubman College of Architecture

and Urban Planning
Ziyi Wu
College of Literature, Science, and the Arts
Devyn K. Wylam*
School of Education & Human Services, Flint
Haoran Xiao
College of Engineering
Nicole P. Xu
College of Literature, Science, and the Arts
Jennifer Yang
College of Literature, Science, and the Arts
Kelly Yang
College of Pharmacy
Lucy Yang
College of Literature, Science, and the Arts
Matthew David Zeilbeck
College of Literature, Science, and the Arts
Amanda Zhang
College of Literature, Science, and the Arts
Yimeng Zhuang
College of Literature, Science, and the Arts
Charles Zinn
College of Literature, Science, and the Arts

EIGHT TERM ANGELL SCHOLARS

SEVEN TERM ANGELL SCHOLARS

*Denotes graduates

ERIN WHITE
Managing Editor

Stanford Lipsey Student Publications Building
420 Maynard St.
Ann Arbor, MI 48109
tothedaily@michigandaily.com

Edited and managed by students at the University of Michigan since 1890.

ELIZABETH LAWRENCE
Editor in Chief
EMILY CONSIDINE AND
MILES STEPHENSON
Editorial Page Editors

Unsigned editorials reflect the official position of The Daily’s Editorial Board.
All other signed articles and illustrations represent solely the views of their authors.

EDITORIAL BOARD MEMBERS

Alanna Berger
Zack Blumberg
Brittany Bowman
Emily Considine
Jess D’Agostino

Jenny Gurung
Cheryn Hong
Krystal Hur
Ethan Kessler
Zoe Phillips
Mary Rolfes

Michael Russo
Timothy Spurlin
Miles Stephenson
Joel Weiner
Erin White

W

hen I was an optimistic
high school freshman, I
tried out for the varsity
swim team. Armed with Banana
Boat sunscreen and a hideous two-
piece bathing suit, I entered the pool
woefully unaware of basic swimming
technique yet determined to make
varsity. Although I succeeded in
making the team (too few girls tried
out for the team at the tiny, all-girls
Catholic school I attended for anyone
to be turned away), I quickly realized
swimming wasn’t my true calling.
I’m certainly not an athlete.
But I am a Supreme Court geek.
Even in my days as an un-athletic
freshman, I skimmed Supreme
Court dockets to see the cases and
controversies that would be debated
in the next few months. That habit
has followed me to this day; even
as a busy college student I still read
Supreme Court blogs.
This year, the Supreme Court
will decide a landmark case about
employee discrimination. In 2010,
Donald Zarda was fired from
his job as a skydiving instructor
after he revealed he was gay (he
mentioned his sexuality to a female
client who was strapped to him for
a jump in an attempt to make her
more comfortable with the close
physical contact between the two).
Nearly a decade and several appeals
later, Altitude Express Inc. v. Zarda
concerns whether the Civil Rights
Act’s language protects against
employment discrimination based
on an individual’s sexual orientation.
Legal scholars and activists are
wondering whether the Supreme
Court will rule in favor of protections
for employers or employees.
This is not the first time the
Supreme Court has considered
sexuality and discrimination. In
1986, the majority opinion in Bowers
v. Hardwick compared homosexual
activity to “incest … and other sexual
crimes” when considering the case
of a police officer who had engaged
in consensual sodomy; sodomy was
criminalized in the state of Georgia
until Bowers was overturned in
2003. In 2000, Boy Scouts v. Dale
ruled that Boy Scouts of America’s
decision to fire an employee because

he was openly gay was protected
under the First Amendment. It was
reasonable, the decision reads, for the
Boy Scouts of America to claim that
homosexual activity was antithetical
to the Boy Scouts’ mission to be
“morally straight” and “clean.”
Since
1986,
however,
much
of
the
legal
discourse
about
employee
discrimination
has
shifted to a debate about conflicting
individual rights. Zarda is one of
the first cases since Dale to directly
address
discrimination
against
employees. More recent cases about
homosexuality and discrimination
have focused on the clash between
religious liberty and the individual
right to privacy as opposed to the
debate about whether homosexuality
is morally acceptable. In some ways,
it’s easy to look back on that stinging
Bowers decision and view it as
part of a controversial past, but the
arguments made in Zarda prove
things haven’t changed much.
Legal
scholars
who
defend
employers’ interests argue that
“sexual orientation” isn’t a protected
status in the Civil Rights Act the
same way that “sex” or “age” is. It
would certainly be unreasonable
to expect the Supreme Court to
rule on protections that have never
existed.
But
the
fundamental
problem with this argument is that
it ignores the interaction between
sex and orientation as applied to
civil rights protections.
Let’s use the word “sex” as
defined in the Civil Rights Act as
strictly biological sex (i.e., male
or female as assigned at birth) to
understand how it still applies
as a protection against sexual
orientation discrimination. Zarda’s
biological sex certainly played a
role in his employer’s decision to
terminate his gay employee. If
Donald Zarda had been a woman in
a relationship with a man instead of
a man in a relationship with a man,
there would not have been a reason
to fire him.
Furthermore,
neither
the
Constitution nor existing legislation
account for the cultural and social
changes that create shifts in
societal norms. After all, at the time

of the Civil Rights Act’s passage in
1964, homosexuality was defined
as a mental illness by the American
Psychiatric Association. Even if
sexual orientation isn’t explicitly
addressed within the text of
the Civil Rights Act, the logic of
protections on the basis of sex allow
sexual orientation discrimination
to be understood as a subset of
biological sex discrimination.
Beside my short tenure as a
swimmer, I recall many other
awkward moments from high
school. I think of my younger
self cringing as she changed into
her new, aerodynamic one-piece,
struggling to reconcile the feelings
she had about herself and her own
sexuality. I think about standing at
the deep end of the pool, breathing
in chlorine and trying not to
remember that one time I found
“Annie on My Mind” in the school
library (it is unclear to me still
how that got past the all-seeing
librarian). I think of myself staring
down the crucifix at the front of my
sixth-period math class, wondering
if I was morally straight and clean.
Zarda is not a case about
religious beliefs, or about whether
homosexuality is acceptable and
appropriate, or about whether we
should all be Christan. This is a
case about an individual’s right —
most importantly, the right to live
without being afraid or ashamed,
regardless of what they believe.
There are some things that just
are in the world. Children routinely
picked last for dodgeball teams
are not destined to be the next
Michael Phelps. The Cats movie
adaptation
is
an
abomination
worthy of Leviticus. Some people
are attracted to members of the
same sex.
Some people who vandalize
property and commit hate crimes
at Pride events will continue to do
so, regardless of how many court
decisions tell them it’s wrong. That
doesn’t mean the Supreme Court
should cease to uphold LGBTQ+
rights anyway.

ALLISON PUJOL | COLUMN

The right to have rights

KAAVYA RAMACHANDHRAN | CONTACT CARTOONIST AT KAAVYAR@UMICH.EDU

Allison Pujol can be reached at

ampmich@umich.edu.