In 1994, fear of persecution due to sexual orientation became grounds for asylum in the United States. In 1996, in the case Nabozny v. Podlesny, the U.S. Seventh Circuit Court of Appeals ruled that school officials violated the rights of an openly gay teenager, Jamie Nabozny, when they allowed others to harass him for his sexual orientation. This was the first judicial opinion in American history finding that a public school could be held accountable for not stopping antigay abuse. In 1999 domestic partnerships were legalized in California — the first state to do so, and therefore, the first state to legally recognize same-sex relationships. There was also one prominent political success for gay men in the 1990s. In 1994, President Bill Clinton considered James Hormel for the ambassadorship to Fiji, but did not put the nomination forward due to protests from Fiji officials. Gay male sexual acts were punishable with prison sentences in Fiji and Hormel's being open about his sexuality would stand in conflict with culture. Instead Hormel was named as part of the United Nations delegation from the US to the Human Rights Commission in 1995, and in 1996 became an alternate for the United Nations General Assembly. In October 1997 Clinton nominated Hormel to be ambassador to Luxembourg, which had removed laws prohibiting consensual same-sex acts between adults in the 1800s. This appointment was the first nomination or appointment of an openly LGBT person from the US. The International Bear Brotherhood Flag was created in 1995. There is debate over its creator, but Craig Byrnes claims to have created it. Bear is an affectionate gay slang term for those in the bear communities, a subculture in the gay male community with its own events, codes, and culture-specific identity. Civil unions and same-sex marriages first became legally recognized in the United States in this decade. In 2000, Vermont became the first state to recognize civil unions. Several other states have legalized civil unions since. In 2004 San Francisco mayor Gavin Newsom allowed city hall to grant marriage licenses to same-sex couples. However, all same-sex marriages done in 2004 in California were annulled. Later in 2008 Prop 8 illegalized same-sex marriage in California, but the marriages that occurred between the California Supreme Court decision legalizing same-sex marriage and the approval of Prop 8 illegalizing it are still considered valid. In 2004, same-sex marriage was legalized in the state of Massachusetts. In March 2004, same-sex marriage was legalized in part of Oregon, as after researching the issue and getting two legal opinions, the commissioners decided Oregon's Constitution would not allow them to discriminate against same-sex couples.