This section presents selected lower court rulings in the U.S. that evidence an impact on human and civil rights issues. In the case Chicoine v. Chicoine, the South Dakota Supreme Court, citing a mother's open lesbian behavior, remanded a trial court's order allowing the woman restricted visits with her two children. The justices cited several decisions from other states that hold a parent's sexual behavior does have relevance in deciding the scope and nature of visitation rights. In the case U.S. v. Minsky, a federal appeals court in Cincinnati, Ohio, ruled that a talk between a prosecutor and a judge violated the constitutional rights of a defendant whose attorney was not present. The ruling by the U.S. Court of Appeals for the Sixth Circuit directly affects the state of Ohio, Kentucky, Michigan and Tennessee and is likely to be closely scrutinized by other circuits. In the case, Jane Doe v. George D. Small, a Chicago, Illinois, federal appeals court reversed a trial judge's order banning a Christian display from a public park in Ottawa, Illinois. The Seventh U.S. Circuit Court of Appeals ruled that the ban on the display was too severe and unduly penalized the Jaycees, who sponsored the annual display.