Case No. 111-97-TC (1997) is a case decided by the Constitutional Tribunal of Ecuador on November 25, 1997 that resulted in a landmark decision regarding sodomy laws. The newly created Constitutional Tribunal overturned as unconstitutional the first section of Article 516 of the Penal Code which criminalized sexual activities between persons of the same sex. The case was the first step towards increasing recognition of gay rights in Ecuador. The following year, Ecuador became the first country in the Americas (and only the third in the world after South Africa and Fiji) to include sexual orientation as a protected category in its Constitution. Nevertheless, the decision handed down by the Constitutional Tribunal was not wholeheartedly received by gay rights activists, who criticized it due to its use of homophobic language qualifying homosexuality as an "abnormal conduct" which should be medically treated rather than penally sanctioned. The Constitutional Tribunal was accused of being traditional-minded for stating that "it is clear that even though [homosexuality] should not be a judicially punishable conduct, the protection of the family and of minors requires that it not be a socially exalted conduct".[1] Case No. 111-97-TC was also criticized by social conservatives opposed to the decriminalization of homosexuality altogether.[2]