The court first needed to determine whether homosexuality was a suspect or quasi-suspect class which would entitle gays and lesbians to stricter protection. The court found that gay persons have been subjected to and stigmatized by a long history of purposeful and invidious discrimination.
During the northern hemisphere winter solstice, the Sun's incoming rays are perpendicular to the Tropic of Capricorn at 23.5 degrees south latitude. The Sun's path is the lowest above the horizon in locations north of the equator, and these regions experience the shortest day of the year.
Most deserts are hot. Within the latitudes of the Tropics of Cancer and Capricorn, the sun appears directly overhead at noon on at least one day of the year. To the north or south of them, the sun is never directly overhead, and not as concentrated as the beam that reaches the tropical areas.