Several other Supreme Court rulings were handed down in the 1990s on the issue of homosexual rights. These rulings did not have the impact of the above three, although they also yielded a mixed position on gay rights. Onacle v. Sundowner Offshore Services in 1998 found the Court unanimously ruling that same sex harassment was actionable under Title VII. The Court found even though same sex harassment was not contemplated by the statute, “statutory prohibitions often go beyond the principal evil to cover reasonably comparable evil.” The 1998 case of Bragdon v. Abbott found a divided Supreme Court allowing persons with HIV to be considered disabled under the Americans With Disabilities Act, even when the disease had not progressed to a symptomatic stage. This action was considered a major gay rights victory.

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