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.
Because of the axial tilt of the Earth in its orbit, the maximum intensity of sun rays hits the earth 23.4 degrees north of equator at the June Solstice (at the Tropic of Cancer), and the maximum intensity of sun rays hits the earth 23.4 degrees south of equator at the December Solstice (at the Tropic of Capricorn).