On November 21, 2011, President Obama signed into law the
federal 3% Withholding Repeal and Job Creation Act, P.L. 112-56. Title II
of the 3% Withholding Repeal and Job Creation Act is known as the Veterans
Opportunity to Work to Hire Heroes Act of 2011 (the "VOW to Hire Heroes Act").
Back in August, the United States Court of Appeals for
the Fifth Circuit decided a case and ruled that the Uniformed Services
Employment and Reemployment Rights Act ("USERRA") did not recognize claims of
hostile work environment based on an employee's membership in the National