the Fifth Amendment. The federal government then began to recognize lawfully performed same-sex marriages, and provide federal rights, privileges and benefits. On June 26, 2015, the Supreme Court ruled in Obergefell v. Hodges that same-sex marriage cannot be prohibited by a state. Consequently, same-sex marriages are licensed and recognized as valid and enforced in all states and areas subject to the jurisdiction of the U.S. Constitution. On June 15, 2020, the Supreme Court of the United States ruled that the protections provided by Title VII of the Civil Rights Act of 1964 are also extended to LGBT individuals, thereby making it illegal for workplaces with 15 or more employees to discriminate on the basis of sexuality or gender identity. The three consolidated cases were Altitude Express, Inc. v. Zarda; Bostock v. Clayton County; and R.G. & G.R. Harris Funeral Homes Inc. v. Equal Employment Opportunity Commission. USA Today afterwards stated that in addition to LGBTQ employment discrimination, "The court's ruling is likely to have a sweeping impact on federal civil rights laws barring sex discrimination in education, health care, housing and financial credit." History of LGBT rights under U.S. presidents George Washington Commander-in-Chief of the Continental Army To train the new American Army in the latest military drills and tactics, General George Washington brought in Friedrich Wilhelm von Steuben (1730–94), who had been an officer on the German General staff. Von Steuben escaped Germany where he was threatened with prosecution for homosexuality. He joined Washington's army at Valley Forge in February 1778 accompanied by two young aides. Steuben became an American general, and a senior advisor to Washington. Despite rumors about sexual behavior at his parties, there never was an investigation of Steuben, and he received a congressional pension after the war. The first evidence of discrimination to homosexuals serving in the United States military dates from March 11, 1778, when Lieutenant Frederick Gotthold Enslin was brought to trial before a court-martial. According to General Washington's report: "...Lieutt. Enslin of Colo. Malcolm's Regiment tried for attempting to commit sodomy ..." Washington's secretary described the results of the trial: "His Excellency the Commander in Chief approves the sentence and with Abhorrence & Detestation of such Infamous Crimes orders Lieut. Enslin to be drummed out of Camp tomorrow morning...." John Adams In 1801, Congress enacted the District of Columbia Organic Act of 1801 that continued all criminal laws of Maryland and Virginia