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Before Bostock, an LGBT person could be terminated from employment in 30 states just because they were LGBT. Indeed, the employer could actually say: You are fired because you are LGBT which was the actual fact pattern in the three cases consolidated and heard together under Bostock. However, there was a time where the legal environment in the United State was unforgiving everywhere for LGBT employees. In particular, an extraordinary pattern of gay and lesbian discrimination has been documented among school teachers and government employees reaching back to the 1940s.