legislatively repealed. On September 29, 2011, the Ninth Circuit vacated the district court's decision, ruling that the legislative repeal of "don't ask, don't tell" rendered the case moot. The Obama administration, in its refusal to defend several lawsuits challenging Section 3 of the Defense of Marriage Act, argued that "heightened" scrutiny is the appropriate level of scrutiny to apply to statutes that discriminate on the basis of sexual orientation. See also Craig v. Boren Renton v. Playtime Theatres, Inc. Mississippi University for Women v. Hogan District of Columbia v. Heller References Civil rights and liberties Legal history of the United States United States constitutional law