the family structures of same-sex couples, including marriage. Some countries and jurisdictions mandate that all individuals restrict themselves to heterosexual activity and disallow homosexual activity via sodomy laws. Offenders can face the death penalty in Islamic countries and jurisdictions ruled by sharia. There are, however, often significant differences between official policy and real-world enforcement. Although homosexual acts were decriminalized in some parts of the Western world, such as Poland in 1932, Denmark in 1933, Sweden in 1944, and England and Wales in 1967, it was not until the mid-1970s that the gay community first began to achieve limited civil rights in some developed countries. A turning point was reached in 1973 when the American Psychiatric Association, which previously listed homosexuality in the DSM-I in 1952, removed homosexuality in the DSM-II, in recognition of scientific evidence. In 1977, Quebec became the first state-level jurisdiction in the world to prohibit discrimination on the grounds of sexual orientation. During the 1980s and 1990s, several developed countries enacted laws decriminalizing homosexual behavior and prohibiting discrimination against lesbian and gay people in employment, housing, and services. On the other hand, many countries today in the Middle East and Africa, as well as several countries in Asia, the Caribbean and the South Pacific, outlaw homosexuality. In 2013, the Supreme Court of India upheld Section 377 of the Indian Penal Code, but in 2018 overturned itself and legalized homosexual activity in India. Ten countries or jurisdictions, all of which are predominantly Islamic and governed according to sharia law, have imposed the death penalty for homosexuality. These include Afghanistan, Iran, Brunei, Mauritania, Saudi Arabia, and several regions in Nigeria and Jubaland. Laws against sexual orientation discrimination United States Employment discrimination refers to discriminatory employment practices such as bias in hiring, promotion, job assignment, termination, and compensation, and various types of harassment. In the United States there is "very little statutory, common law, and case law establishing employment discrimination based upon sexual orientation as a legal wrong." Some exceptions and alternative legal strategies are available. President Bill Clinton's Executive Order 13087 (1998) prohibits discrimination based on sexual orientation in the competitive service of the federal civilian workforce, and federal non-civil service employees may have recourse under the Due Process Clause of the U.S. Constitution. Private sector workers may have a Title VII of the Civil Rights Act of 1964 action under a quid pro quo sexual harassment theory, a