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.

