"Equal opportunity" in organizations means that the organization hires employees in an equal manner, without regard to an applicant's gender, race, religion, or physical condition. Before equal opportunity polices were implimented, an organization could, if it wished, not hire women, African Americans, Jewish people or physically handicapped people. In other words, they could specifically hire only the "type" of applicant they wanted. American organizations now state "We are an equal opportunity employer" on their applications for employment. It is not lawful for an organization to not to hire equally. Discrimination occurs when an organization commits actions such as failure to hire or promote people based upon their gender, race, religion or handicap. It is illegal to discriminate against any person because of these qualities. The American Disability Act provided that those who are physically handicapped must not be discriminated against when they apply for employment. Cases of unlawful discrimination are usually handled by the civil courts in America.