of proof required for a retaliation claim under Title VII. The Court held that while Title VII applies a mixed motive discrimination framework to claims of discrimination on the basis of race, color, religion, sex, or national origin (see ), that framework did not apply to claims of retaliation under . The Court reasoned that based on its decision in Gross v. FBL Financial Services, Inc. and on common law principles of tort law, the plaintiff was required to show that a retaliatory motive was the "but for" cause of the adverse employment action. United States: enacts the Transport for Female Genital Mutilation Act, which prohibits knowingly transporting a girl out of the United States for the purpose of undergoing FGM. United States: Vance v. Ball State University is a U.S. Supreme Court case regarding who is a "supervisor" for the purposes of harassment lawsuits. The Supreme Court upheld the Seventh Circuit's decision in a 5–4 opinion written by Samuel Alito, rejecting the Equal Employment Opportunity Commission's interpretation of who counts as a supervisor. The case was important because it resolved a dispute between several different circuits. The Supreme Court held that an employee is a "supervisor" for purposes of vicarious liability under Title VII only if he or she is empowered by the employer to take tangible employment actions against the victim. United States, Florida: A Florida man successfully forced the Florida Department of Motor Vehicles to accept his decision to take his wife's last name. International: The first United Nations Human Rights Council resolution against child, early, and forced marriages was adopted; the resolution recognizes child, early, and forced marriage as involving violations of human rights which "prevents individuals from living their lives free from all forms of violence and that has adverse consequences on the enjoyment of human rights, such as the right to education, [and] the right to the highest attainable standard of health including sexual and reproductive health," and also states that "the elimination of child, early and forced marriage should be considered in the discussion of the post-2015 development agenda." International: The U.N. Security Council unanimously passed Resolution 2122, which supported abortion rights for girls and women raped in wars, "noting the need for access to the full range of sexual and reproductive health services, including regarding pregnancies resulting from rape, without discrimination." United Nations Secretary General Ban Ki-moon had recommended to the U.N.