Sine qua non

US President Andrew Jackson once gave a toast on the occasion of his receiving an honorary doctorate from Harvard University, responding to his listeners, "E pluribus unum, my friends.

"[2] In 1938, Jomo Kenyatta, the general secretary of the Kikuyu Central Association and who later became Kenya's first prime minister, wrote that the institution of female genital mutilation was the "condicio sine qua non of the whole teaching of tribal law, religion and morality".

"[4] The term appears in the 1958 commentary on Article 59 of the Fourth Geneva Convention on the protection of civilians during wartime.

In this case, the use of sine qua non refers to the assurance for relief aid to go to the civilian population and not to be diverted toward "the benefit of the Occupying Power.

That is a higher burden for the plaintiff employee than merely showing that the jury service was a motivating factor for the termination.