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The Legacy of Brown: Implications for Equal Educational Opportunities for Gay, Lesbian, and Bisexual Students

by Sarah A. Strauss - 2005

Concern about the impact of discrimination on the well-being of African Americans played a prominent role in Brown v. Board of Education (1954) and has been hotly contested in the ongoing struggle to achieve equal educational opportunities. The importance of this legacy is also reflected in the recent efforts on behalf of gay, lesbian, and bisexual (GLB) students in America. For those seeking to help GLB youth, the similarity between these two struggles means that Brown can provide crucial insights into attempts to undermine these efforts. This article will describe in detail the relationship between Brown and the well-being of African American students in order to shed light on the possibilities and obstacles facing those seeking to support GLB students.

Concern about the impact of discrimination on the well-being of African Americans played a prominent role in Brown v. Board of Education (1954) and has been hotly contested in the ongoing struggle to achieve equal educational opportunities. The importance of this legacy is also reflected in the recent efforts on behalf of gay, lesbian, and bisexual (GLB) students in America. For those seeking to help GLB youth, the similarity between these two struggles means that Brown can provide crucial insights into attempts to undermine these efforts. This article will describe in detail the relationship between Brown and the well-being of African American students in order to shed light on the possibilities and obstacles facing those seeking to support GLB students.

On the morning of Monday, September 8, 2003, seventy-five students seeking to enter the Harvey Milk School on its first day as a full-fledged New York City public high school had to be escorted past police, the news media, more than 200 supporters, and about a dozen protesters, including those who held up the Bible and a sign reading ‘‘God Hates Fags’’ (M. May, 2003; Zoepf, 2003). In the weeks preceding this spectacle, many of those opposed to the existence of the Harvey Milk High School, which serves a small number of gay, lesbian, bisexual, and transgender students, called the school legally sanctioned segregation. Such opponents included one New York state senator who filed a lawsuit to fight ‘‘segregation in any shape, type, or form’’ (Herszenhorn, 2003; N. May, 2003).

Those invoking the language of Brown v. Board of Education of Topeka, Kansas (1954) to condemn this high school present a distorted representation of the relationship between the experiences of gay, lesbian, and bisexual (GLB) youth and the legacy of this landmark Supreme Court case. They oversimplify the legacy of Brown in a way that overlooks a crucial aspect of this historic decision: At its core, the Court’s rejection of segregation under the Fourteenth Amendment’s Equal Protection Clause relied on an overriding concern for the impact schools have on the well-being of students. Contrary to what opponents of the Harvey Milk School have suggested, advocates for youth, including gay, lesbian, and bisexual youth, view Brown v. Board of Education of Topeka, Kansas (1954) as a symbol that informs and guides other movements seeking to protect the rights of students who had been discriminated against in the public educational system.

The Warren Court’s decision in the Brown case marked a substantial turning point in the history of this country by overturning Plessy v. Ferguson (1896), thereby rejecting the idea that separate but equal was constitutional. At the same time, largely because the NAACP and the Court drew on the works of Kenneth Clark and other social scientists, Brown emphasized the consequences of discrimination in schooling, particularly psychological outcomes, when assessing the relative equality of educational opportunities. It is this critical legacy of Brown that has, over the past decade, proven to be central to the struggle for equal educational opportunities for gay, lesbian, and bisexual students.

Advocates for gay, lesbian, and bisexual youth have drawn on this legacy of Brown, in their use of social science research and in the legal and political efforts that have emphasized the harm done to these young people, particularly at the hands of other members of school communities. As a result of these efforts, after years in which few even recognized the existence of GLB youth, recently, laws, policies, and educational practices have been implemented to provide support and protection for these young people in various locales. In spite of these advances, those seeking to help gay, lesbian, and bisexual youth must heed the warning issued by Patterson (1998), who observed the problematic consequences of the emphasis on victimization in the struggle to ensure equality in education and beyond.

In this article, I will provide a brief review of the way Brown moved the issues of discrimination and its relationship to schooling and the well-being of students to center stage with regard to the struggle for equal educational opportunities for African Americans. Through this review, I will demonstrate how this legacy is reflected in the movement for GLB student rights.


At the end of the 19th century, when the legal concept of separate but equal was made the law of the land, the dominant ideology regarding the cause of social inequality held by most of the white population and social scientists stemmed from the theory of social Darwinism, or the belief that nature—including ‘‘race’’—determines an individual’s social status. According to this ideology, any intervention to alter the natural system of social selecting and the resulting inequality would only create greater problems by harming the stronger members of society, and therefore, society as a whole (Hofstadter, 1959).

As Lofgren (1987) argues, during this period, ‘‘[a]lthough embodying no unified, internally consistent doctrine, popular and scientific opinion provided broad grounds for concluding that racial separation was ‘reasonable’ in the sense of arguably conducing to maintenance of public health, welfare, and morals’’ (pp. 114–115). This ideology was reflected in the laissez-faire approach of the federal government and in the racially determined caste system established in the Jim Crow South. In addition, it served as the foundation upon which the infamous Plessy v. Ferguson case was decided by the Supreme Court in 1896 (Orfield, 1996a).

Plessy v. Ferguson (1896), the decision that established the constitutionality of separate but equal, codified social Darwinist beliefs about the source of social inequality even in the face of the Fourteenth Amendment’s Equal Protection Clause. As Kluger (1975) has noted, this infamous decision asserted that separate but equal was tenable because the link between laws and inequality did not exist. In other words, the fact that African Americans and whites were separated from one another by law did not create differences in status; rather, in part, the Court blamed African Americans themselves for their ‘‘inferiority’’. This explanation is evident in Justice Henry Billings Brown’s majority opinion:

We consider the underlying fallacy of the plaintiff ’s argument to consist in the assumption that the enforced separation of the two races stamps the colored race with a badge of inferiority. If this be so, it is not by reason of anything found in the act, but solely because the colored race chooses to put that construction upon it. (Plessy v. Ferguson, 1896)

Within this framework, the ‘‘choice’’ to be unequal lay in the hands and minds of African Americans themselves, and could not be blamed in any way on the society’s legal system. Ironically, even while acknowledging the existence of ‘‘enforced separation,’’ the Court asserted the relative impotence of law to influence human relations that could lessen social distinctions.

Further, the Court argued that the consequences of taking legal action to end segregation of the races would differ dramatically from the outcome hoped for by those seeking to end discrimination. The Plessy decision was also built on the assumption that nature was paramount in structuring society. The Court noted the inevitable impact of using law to improve on nature with the following segment of the majority opinion:

The argument also assumes that social prejudices may be overcome by legislation, and that equal rights cannot be secured to the Negro except by an enforced commingling of the two races. We cannot accept this proposition. If the two races are to meet upon terms of social equality, it must be the result of natural affinities, a mutual appreciation of each other’s merits, and a voluntary consent of individuals. . . . Legislation is powerless to eradicate racial instincts, or to abolish distinctions based upon physical differences, and the attempt to do so can only result in accentuating the difficulties of the present situation. (Plessy v. Ferguson, 1896)

With the emphasis placed on ‘‘natural affinities’’ and ‘‘instincts,’’ Justice Brown highlighted the idea that nature, rather than law, determines so-called ‘‘social prejudices.’’ In accordance with the social Darwinist framework, the Court implied that intervention to alter this reality would only further damage—as defined by social Darwinist theory—the social order (Hofstadter, 1959; Tucker, 1994). From this perspective, Plessy suggested that protecting the larger social order from potential damage superseded the interests of African Americans, even in the shadow of the Equal Protection Clause of the Fourteenth Amendment.


In the process of overturning the separate but equal doctrine of Plessy, the Court’s decision in Brown v. Board of Education in 1954 essentially rejected the role of ‘‘nature’’ in the production of inequality. By examining the influence of education in American society in the middle of the 20th century, the Court emphasized the importance of social contexts in determining life chances. As Chief Justice Warren wrote in the unanimous ruling:

Today, education is perhaps the most important function of state and local governments. . . . In these days, it is doubtful that any child may reasonably be expected to succeed in life if he is denied the opportunity of an education. Such an opportunity, where the state has undertaken to provide it, is a right which must be made available to all on equal terms (Brown v. Board of Education, 1954).

Having asserted the central position of schools in American society, the Court highlighted the impact of education on each student’s future. The powerful consequences of this relationship between schooling and opportunities were used to justify the Court’s assertion of the state’s obligation to provide an equal educational opportunity for all.

To remove justification for Plessy, it was not enough to declare that educational policy and practice could produce inequality; to achieve this end, the Court used an argument initially put forth by the NAACP: that de jure racial segregation in schools did harm to African American students in school and in later life (Kluger, 1975). Warren cited the decision by the district court in Kansas with the following statement:

Segregation of white and colored children in public schools has a detrimental effect upon the colored children. The impact is greater when it has the sanction of the law; for the policy of separating the races is usually interpreted as denoting the inferiority of the Negro group. A sense of inferiority affects the motivation of a child to learn. Segregation with the sanction of law, therefore, has a tendency to [retard] the educational and mental development of Negro children and to deprive them of some of the benefits they would receive in a racial[ly] integrated school system.

Whatever may have been the extent of psychological knowledge at the time of Plessy v. Ferguson this finding is amply supported by modern authority. (Brown v. Board of Education, 1954)

Flipping Justice Brown’s social Darwinist reasoning on its head, the 1954 Court agreed that, yes, government intervention—in the form of de jure segregation—did exacerbate the ‘‘present situation’’ by causing greater harm to African American students. With this statement, the Court made the link between the school as a social institution and the production of social inequality. By emphasizing the psychological harm done to African American children, Brown placed a significant degree of responsibility for inequality on educational policies and practices and enabled the reversal of Plessy.

The Court’s focus on the well-being of African American students drew on social science evidence presented by the NAACP that played an important role in this shift of the Court’s evaluation of segregation under the Fourteenth Amendment’s Equal Protection Clause. The Supreme Court’s majority opinion, written by Chief Justice Warren, asserted that segregated schools damaged ‘‘Negro’’ youth and that this conclusion ‘‘is amply supported by modern authority,’’ a reference to the seven social science studies cited in the now famous ‘‘Footnote Eleven’’ of the decision (Brown, 1954; Kluger, 1975). These works, each of which had been noted in briefs submitted to the Court by the NAACP, provided support for the argument that legally sanctioned school segregation damaged African American children (Tucker, 1994; Jackson, 2000; Patterson, 2001).


The importance of the relationship between educational opportunity and the overall well-being of African American students continues to be contentious. The authors of the social science briefs in Footnote 11 were lauded as contributing to ‘‘psychology’s greatest achievement in social engineering,’’ while others have celebrated the ‘‘brilliance’’ of the NAACP’s argument ‘‘that segregation created an injury . . . [that] was constitutionally significant’’ (Jackson, 2000, p. 240; Crenshaw, 2004). At the same time, the use of social science research and the Court’s emphasis on psychology has received much criticism from numerous legal scholars and social scientists (Kluger, 1975; Patterson, 1998; Tucker, 1994).

This ongoing debate is nowhere more apparent than in the work of social scientists. Though many scholars since Brown have drawn attention to connections between psychological outcomes and educational inequalities in their work, others, including avowed pro-segregationists, have produced research that has either attacked or omitted the idea that social institutions influenced the experiences of individuals. Such efforts have a served to diminish this legacy and the way we think about racial discrimination and its consequences.

Of those works reflecting the legacy of the Brown decision, the most dominant are studies that have focused on the role of self-esteem in relation to the ongoing achievement gap dividing African Americans from white students (e.g., Steele, & Aronson, 1995; Demo, & Parker, 1987). These studies have often revealed that the average African American student has lower academic achievement but higher self-esteem than the average white student (van Laar, 2000)—seen as ‘‘one of the most striking examples of the still remaining inequality between Black and White America’’ (van Laar, 2000, p. 33).

Some researchers in this tradition have taken an alternate approach that seems to provide support for the assumptions of Brown. In particular, scholars have investigated the impact of minority adolescents’ experiences with discrimination on mental health and achievement (e.g., Wong, Eccles, & Sameroff, 2003; Phinney, Chavira, & Tate, 1993; Phelan, Yu, & Davidson, 1994). In fact, Wong, Eccles and Sameroff (2003) have found that the experience of racial discrimination at school ‘‘predicts declines in grades, academic ability self-concepts. . . [and] mental health’’ (p. 1198).

In contrast to these efforts, however, a retreat from the legacy of Brown has also been revealed in the work of social scientists. Initially, attacks penned by pro-segregation scholars, such as Henry Garrett, took aim at and the idea that schooling influenced the well-being of African American students (Jackson, 2000; Tucker, 1994). This push for retrenchment relied on returning the emphasis to the ‘‘natural’’ social order and erasing the notion that harm could be done to students by educational policy and practices. As Jackson (2000) has asserted, early attempts to diminish the acceptance of the harm done by segregation eventually seeped into mainstream historical narratives of the Brown case, as can be seen in the work of Patterson (2001) and Tucker (1994).

Notably, the overall well-being of students has been absent from mainstream investigations of schooling and inequality in the aftermath of Brown. Since this case was decided in 1954, a wealth of studies have been undertaken to explain the persistent nature of educational inequality. In contrast to the psychologically oriented vision fostered by the Court’s decision in this case, the ‘‘school effects’’ literature that grew out of this decision has generally focused on the relationship of school factors to measures of academic achievement. In particular, the work of one of the founders of the school effects movement, James Coleman, established academic outcomes as the focal point of this type of research.

Equality of Educational Opportunity (EEO), a highly publicized and controversial effort by Coleman, Campbell, Hobson, McParatland, Mood, Weinfield and York (1966), found relatively little effect of school factors on academic achievement. While focusing primarily on factors such as school facilities, curricula, and teacher characteristics, Coleman et al. found that: ‘‘It appears that variations in the facilities and curriculums of the schools account for relatively little variation in pupil achievement in so far as this is measured by standard tests’’ (p. 22). Coleman et al. acknowledged the difficulty of capturing the impact of schooling on students through statistical analyses (p. 22); still, many viewed the report’s findings as proof that schools could do little to diminish educational inequality. Of course, many have since asserted that Coleman’s focus on between-school variance in achievement is responsible for the finding that schools have only minimal impact on achievement (e.g., Fisher, Hout, Jankowski, Lucas, Swidler, & Voss, 1996). Nonetheless, the EEO report effectively served to ‘‘pummel claims of the significance of schools’’ (Watt, 2003, p. 346).

Along with political forces, Coleman’s powerful legacy has led many to maintain a similar focus on academic achievement, continuing the drift away from questions relating primarily to psychological outcomes in their empirical studies. Sorenson and Morgan (2000) note that almost all research on school effects has highlighted the question of ‘‘how much difference characteristics of schools make for student learning in areas where we have measures of learning outcomes, usually based on performance on standardized tests of achievement. . .’’ (p. 138). A variety of interests, including the availability of funding for research, have played a role in reinforcing common school effects research strategies. Unfortunately, the dominance of this approach emphasizing measures of academic achievement limits efforts to unravel the problem of educational inequality in America.

Much like those ideas posited by Garrett and his peers, and by many in the school effects field, some contemporary social scientists put forth arguments that dismiss the schools’ impact on African American students’ overall well-being. Of particular significance in this regard is Herrnstein and Murray’s (1994) much debated book, The Bell Curve. This book presents the theory that social institutions are not responsible for the intellectual and social inequalities between African Americans and Whites. They argue that the current ‘‘egalitarian ideal . . . underestimates the importance of the differences that separate human beings. . . . It overestimates the ability of political interventions to shape human character and capacities’’ (Herrnstein, & Murray, 1994, p. 532).

Their argument provides an explanation of the differences in educational achievement and life opportunities for Whites and African Americans that stands in stark contrast to that underlying Brown. While Herrnstein and Murray concede a minimally positive impact of what they term ‘‘the ideology of equality’’ on society, these authors emphasize the harm done by government action because it takes the form of ‘‘compelling people to treat [other groups] the same’’ (Herrnstein, & Murray, 1994, pp. 533–534). By arguing against a focus on the ‘‘equality of outcome,’’ Herrnstein and Murray willfully ignore the way the relationship between social institutions, including schools, and psychological factors plays a role in determining life chances. In so doing, their work mirrored beliefs characterizing recent Supreme Court cases that have undermined the integrity of Brown.

A concern for African American students’ well-being has been absent from court cases that have effectively dismantled Brown. Since the early 1990s, the Supreme Court has diminished its commitment to Brown and desegregation in a fundamental way; crucial decisions in this retreat, such as Board of Education of Oklahoma v. Dowell (1991), Freeman v. Pitts (1992), and Missouri v. Jenkins (1995), have been devoid of expressions of concern for the relationship between non-discriminatory schooling and African American student well-being (Orfield, 1996a; Orfield, 1996b; Patterson, 2001).

This seeming disinterest is particularly evident in the most recent Supreme Court ruling on school desegregation in the Jenkins case, when the Court concluded that school districts ‘‘need not show any actual correction of the education harms of segregation’’ before dismantling short-term remedies designed to alleviate long-term racial discrimination (Orfield, & Eaton, 1996, p. xxiii). Jenkins also emphasized the Court’s desire to protect the integrity of state and local authority despite the potential consequences for African American students. (Orfield, 1996a). Overall, these recent cases have marked a judicial retreat from a legal theory that connects the actions and policies of school systems to their impact on the experiences of African American youth—a retreat from the legacy of Brown.


In part as a response to the recent backlash to Brown and other civil rights achievements, some have deemed as problematic the emphasis on psychological harm done to African Americans in the debate over equal opportunities. While lauding the achievement of substantial progress due, in large part, to Brown and subsequent civil rights victories, Orlando Patterson (1998) argues that too often advocates and ‘‘liberal’’ social scientists working to remedy the inequality experienced by Blacks in America have highlighted, almost exclusively, the damage done to ‘‘Afro-Americans’’ by social institutions. In The Ordeal of Integration, Patterson (1998) notes that:

. . . the overwhelming popular and academic view is that Afro-Americans are now in the depths of some intractable crisis . . . this pessimism is so deep-seated and pervasive that it is becoming self-fulfilling, which, in turn, plays right into the hands of the racist extremists among both groups. (p. 5)

Pointing to liberalism’s emphasis on social institutions’ impact on individuals as largely responsible for ‘‘the progress made by Afro-Americans over the past half-century,’’ Patterson (1998) notes the political consequences of heavy reliance—dating back to the Brown decision— ‘‘on social determinism in explaining the condition of the poor, and especially the Afro-American poor’’ (pp. 5–6). Specifically, Patterson argues that social scientists are ‘‘implicated . . . in the ‘‘promotion of Afro-American determinism’’ (1998, p. 87). In other words, by highlighting the idea that society victimizes African Americans, researchers help reinforce racist assumptions that African Americans are at the ‘‘mercy . . . of the oppressor’’ (Patterson, 1998, p. 95). Such an emphasis not only denies individual agency, but also fuels alternate explanations of inequality based on ‘‘naturally’’ determined traits such as ‘‘intelligence’’, undermining the possibility that policy efforts might be used to bring about positive social change (Patterson, 1998; Scott, 1997; Tucker, 1994). These kinds of distortions have been utilized to argue that schools bear little to no responsibility for the ongoing inequalities that plague the American educational system, seriously eroding gains made by those striving to achieve equal educational opportunities for African Americans.


At the same time that scholarship and court cases have turned back the clock with regard to the substance of the Brown decision, since the early 1990s, on the foundation created by the legacy of Brown and the larger gay rights movement, advocates have been experiencing substantial gains in terms of legal and political efforts regarding gay, lesbian, and bisexual (GLB) students’ educational opportunities, often based on arguments similar to those underpinning Brown. Ironically, just as the role of the psychological consequences of discrimination has been ignored, attacked, or, as Patterson suggests, distorted, in the ongoing struggle over equal educational opportunities for African Americans, advocates for GLB youth have revitalized and, in a sense, reinvented this legacy. However, in reviving the idea that schooling can harm young people, advocates for GLB youth have also come to face similar threats to the sustainability of their efforts.

Prior to the 1980s, those who opposed gay rights and the presence of open homosexuals as teachers dominated both the legal and the public discourses on this topic; as a result, they shaped America’s view that schools had a duty to protect children from the ‘‘threat’’ posed by homosexuality. In this context, seemingly, GLB youth did not even exist. However, in line with the legacy of Brown, attempts to undermine this approach have been characterized, to a great extent, by an emphasis on the existence of GLB youth and the schools’ failure to guarantee these young people access to equal educational opportunities. Laws and policies put in place at the state and local levels have highlighted the existence of gay, lesbian, and bisexual (GLB) students and the challenges facing them, while notable federal court cases have reflected the failure of schools to punish those who harass these young people.

These legal and political achievements have mirrored assertions made in recent social science research suggesting that schools must protect students from homophobia, rather than from homosexuality. Largely on the foundation of social science research, advocates have drawn attention to the harm done to GLB youth in schools by emphasizing the high rate of suicideality among these young people, thereby transforming the way many look at the ‘‘problem’’ of homosexuality in schools. In the wake of these efforts, however, some opponents of GLB students’ rights in schools are attempting to take control of the explanation of the ‘‘true danger’’ of providing state-sanctioned protections for gay, lesbian, and bisexual students, in part by taking advantage of weaknesses in studies on GLB youth suicide (Sheldon, 2002).


Fear of homosexuality has characterized much of America’s history; however, in line with the way social Darwinists justified racial segregation, the idea that ‘‘deviant’’ homosexuals threatened the nation’s social order became particularly pervasive at the outset of the Cold War, as anti-Communists in the government viewed homosexuals as posing a grave danger to American culture and national security (D’Emilio, 1983). Accordingly, in June of 1950, anti-Communist activists successfully persuaded the Senate to authorize an investigation into the ‘‘alleged employment of homosexuals and other moral perverts’ in government’’ (D’Emilio, 1983, p. 42).

Spurred on by the dominant view of homosexuality as sick and damaging to the fabric of America, anti-homosexual activities during the 1950s saw schools emerge as key battlegrounds in the fight over the danger of the ‘‘seduction of the young’’ (Smith, & Windes, 2000, p. 69). The Senate Committee seeking to purge the government of homosexual employees wrote that homosexuals would ‘‘frequently attempt to entice normal individuals to engage in perverted practices. This is particularly true in the case of young and impressionable people who might come under the influence of a pervert’’ (cited in D’Emilio, 1983, p. 42). In U.S.A. Confidential, a bestselling book on the various plagues burdening America at the time, journalists Lait and Mortimer (1952) noted that: ‘‘The perversion begins at school age when impressionable girls are often lured into it ‘for fun’ by a fellow student or a teacher or professor. Homosexual cells exist in many high schools, public and private. . .’’ (p. 43). These authors described such ‘‘forbidden fruits’’ as closely tied to communism, while emphasizing the homosexual’s powers of seduction and influence over young people.

In this climate, gay and lesbian teachers became vulnerable to public attack. Fueled by the high levels of anxiety that characterized the postwar era, cities like Boise, Idaho; Miami, Florida and Baltimore, Maryland became ‘‘havens for public abuse, anti-gay harassment, and violence’’ in the name of morality and national security, with educators at great risk of being targeted (Harbeck, 1997, p. 187).

In California, where gay and lesbian teachers were most vigorously identified and dismissed, the state Penal Code ‘‘required a sheriff or chief of police to notify the state licensing board and the local superintendent of schools immediately upon the arrest of a teacher for certain enumerated criminal behaviors relating to sex and morality, even if the arrest later proved to be erroneous or unsubstantiated’’ (Harbeck, 1997, pp. 188–189).

As a result of this and similar laws, countless teachers lost their jobs in California and all across the country, as state and district officials tried to prevent homosexual adults from threatening the safety of school children, and therefore of the nation as a whole.

While gay and lesbian teachers continue to face dismissal even today, laws allowing officials to use teachers’ homosexuality against them were defeated to some extent by the efforts of gay-rights activists. Ironically, although medical science and the field of psychology had helped to promote the stigmatization of gay and lesbian people for many decades by creating the concept of the homosexual, this labeling also helped so-called homosexual individuals to organize themselves politically (Seidman, 1996). In particular, historians note that this identity enabled individuals to develop affiliations with others similar to them and eventually, particularly after World War II, to build social movements organized around this identity of homosexuality, including the contemporary gay rights movement in America (D’Emilio, 1983).

Although gay-rights activism in the United States arose at various points and in various forms during the 20th century, the summer of 1969 is often marked as the key turning point for those seeking to achieve equality regardless of sexual orientation. The Stonewall Riots, a furious response to the New York City ‘s police seemingly routine practice of raiding bars where homosexuals gathered, are seen as giving rise to a more radicalized and visible demand for equality for gays and lesbians in America. After Stonewall, the relatively unchallenged wall of silence that fostered the acceptance of homosexuality as deviant began to crumble. This effort was furthered by successful attempts to remove homosexuality from the American Psychiatric Association’s diagnostic manual of mental illnesses in 1973.i These events fueled GLB individuals’ ability to combat images of them as ‘‘sick’’ and dangerous to American society as a whole, and, specifically to American children. Indeed, for many, these gains marked the beginning of the newfound visibility for gay people in America and of efforts to transform the way Americans view ‘‘homosexuals’’.

The successes of the post-Stonewall era gay-rights movement converged with the re-emergence of federal initiatives to ban discrimination through legislative efforts not seen since the Reconstruction era. Inspired by the passage of legal employment protections won by civil rights activists on behalf of Black workers and codified in the Civil Rights Act of 1964—yet another legacy of Brown—gays, lesbians, and bisexuals sought similar protections for themselves. Only five years before Stonewall, the African American civil rights movement helped give rise to Title VII, passed by Congress in 1964, which included a ban on discrimination because of race, religion, national origin, and gender in employment (Patterson, 2001). Building on this effort to use legal avenues to undermine institutionalized discrimination, gay-rights activists began to strive to pass similar legislation at the state and local levels during the 1970s. Initially, they met with some success on a small-scale in municipalities such as Dade County, Florida, in January of 1977 (Harbeck, 1997).

The institution of anti-discrimination legislation protecting women and minorities at all levels of government resulted in a conservative backlash across the country by the 1970s and 1980s, a backlash that would have serious consequences for the gay-rights movement and legal protections provided for teachers. Conservative politicians, such as presidential candidate Barry Goldwater, took public stands against civil rights legislation, including the Civil Rights Act of 1964 (Hodgson, 1996). This backlash emerged as a powerful counter-movement and was reflected in decisions on reverse discrimination cases, such as University of California Regents v. Bakke, in 1978, and the eventual defeat of the Equal Rights Amendment.

Largely as a result of this broad backlash against civil rights successes, the public discourse about GLB issues and education took a new turn in the 1970s. As with the organized challenges to the establishment of rights for other minorities, opposition to the gay-rights ordinances often centered on efforts to prevent ‘‘special’’ legal protections from giving ‘‘homosexuals’’ the chance to teach, thereby enabling them to ‘‘damage’’ schools’ efforts to protect the larger social order (Bryant, 1977). Such attempts to battle homosexuality in schools emerged most prominently during the late 1970s (Harbeck, 1997, p. 194). In particular, in Dade County, Florida, in California, and in several other locations, there were numerous attacks on the rights of gay and lesbian teachers to work in schools because of the ‘‘threat’’ that they posed to students (Harbeck, 1997).

The most widely publicized of these attacks was Anita Bryant’s work with Save Our Children, an organization that reasserted the importance of schools’ efforts to protect youth from homosexuality. This organization sought to repeal a Dade County law providing gays and lesbians with protections against discrimination in housing, public accommodations, and employment. Save Our Children opposed this law largely because the organization feared it would enable gay and lesbian teachers to endanger innocent young people, making them vulnerable to what Bryant called the ‘‘militant homosexuals’ efforts to influence children to their abnormal way of life’’ (1977, p. 15).

In advocating for the repeal of the anti-discrimination legislation, Bryant (1977) suggested the danger posed to the morality and health of children by the presence of legally protected homosexual teachers. Bryant used rhetoric that spoke of the threat of open and visible homosexual adults to the well-being of young people. She went further to emphasize the damage done by providing legal protections for homosexuals by stating that ‘‘[t]here are homosexual adults who are living irresponsibly, who in the name of ‘‘human rights’’ seek social rights that in reality only give them license for perversion and the flaunting of their deviant ways’’ (Bryant, 1977, p. 38).

In working to deny gay and lesbian teachers of legal protections, Bryant and her backers viewed these laws not only as unnecessary, but also as sanctioning the spread of homosexuality in schools and elsewhere. According to this view, homosexual teachers had to be denied the special or ‘‘social right’’ to ‘‘flaunt their deviant ways’’ in front of America’s young people.

Using these kinds of arguments, the Save Our Children movement in Florida helped foster numerous similar efforts inclusive of attacks on gay and lesbian educators across the country. In fact, other campaigns in St. Paul, Minnesota, Eugene, Oregon, and Wichita, Kansas, succeeded in repealing gay and lesbian rights legislation in the late ‘70s (Harbeck, 1997, p. 52). Similarly, California’s 1978 referendum ‘‘Proposition 6’’ asserted the state’s

compelling interest in refusing to employ and in terminating the employment of a schoolteacher, a teacher’s aide, a school administrator, or a counselor . . . who engages in public homosexuality and/or public homosexual conduct directed at, or likely to come to the attention of, school children or other school employees. (Hollibaugh, 2000, p. 44)

This sweeping proposition to penalize any educators engaging in ‘‘public homosexuality’’ or ‘‘homosexual conduct’’ was defeated largely because of effective grassroots organizing (Hollibaugh, 2000). Nonetheless, members of the blossoming New Right used their influence effectively during this time to define America’s sense of the danger regarding homosexuality and education: Children were at risk if the law allowed adult homosexuals in schools. This central vision focused on the importance of protecting kids, a vision that would be co-opted and transformed by those seeking to promote a gay-positive take on this objective.


It wasn’t until the 1980s that educators, advocates, and social scientists began having success in countering the argument that homosexuality in schools endangered youth, by making visible the existence of gay, lesbian, and bisexual young people and redefining the nature of the threat with regard to homosexuality and schools. This visibility emerged initially on a small but significant scale in the mid-1980s, with the founding of the New York City-based Institute for the Protection of Lesbian and Gay Youth’s (now the Hetrick-Martin Institute) Harvey Milk School, an alternative high school program that provided gay, lesbian, bisexual and transgender dropouts a safe space within which to learn (Campos, 2003; Mass, 1990), and the creation of Project 10, a school-based support group for GLB youth in a Los Angeles school. Both of these programs arose because of their founders’ concerns for the well-being of these young people (Mass, 1990; Harbeck, 1992).

The existence of the Harvey Milk program and Project 10 reinforced the validity of issues that had begun to be raised on a small-scale in the medical literature since the late 1960s. At times, incidentally, these works suggested the role that homophobia played in the lives of GLB young people. In particular, some researchers began to depict the existence of adolescent male and female ‘‘homosexuals’’ and pointed to the discovery that these youth appeared to be at high risk for suicide (Kremer, & Rifkin, 1969; Roesler, & Deisher, 1972). These studies also provided insight into the hostile environments in which GLB youth lived. Ironically, Kremer and Rifkin’s (1969) discussion of the process of identifying their sample exhibits the presence of homophobia in schools. Their research drew on a small sample of adolescent girls from New York City schools ‘‘thought to be homosexual by teachers or guidance staff and [who] were [therefore] sent for psychiatric evaluation’’ (Kremer, & Rifkin, 1969, p. 129).

In contrast, Roesler and Deisher (1972) consciously reflect on the hostility faced by the young gay men they studied, as they emphasize not only their ‘‘high rate of suicide gestures and attempts,’’ but the fact that schools, along with other institutions, are often ‘‘nonsupportive’’ to homosexuals (p. 1023). Unlike Kremer and Rifkin (1969), Roesler and Deisher (1972) point directly to the idea that schools are likely to play a damaging role in the lives of GLB youth, helping to pave the way for a limited, though growing, number of investigations into GLB youth and the challenges facing them in subsequent years (e.g. Hunter, & Martin, 1983; Hetrick, & Martin, 1988).

In spite of these efforts, concerns about GLB youth and suicide only began to have a nationwide impact in 1989, when attention came to be focused increasingly on issues relating to GLB youth, in large part because of the publication of the U.S. Department of Health and Human Services’ (HHS) Report of the Secretary’s Task Force on Youth Suicide: Prevention and Interventions in Youth Suicide. In this study authored by Paul Gibson, but produced by the first Bush administration, it was asserted that approximately 30 percent of all completed teen suicides annually are by gay, lesbian, and bisexual youth (Gibson, 1989). Drawing on previous studies, Gibson (1989) asserted that the high rate of suicide attempts stemmed, in part, from the fact that

[o]penly gay and lesbian youth or those ‘‘suspected’’ of being so can expect harassment and abuse in junior high and high schools . . . . The shame of ridicule and fear of attack makes school a fearful place to go resulting in frequent absences and sometimes academic failure. (pp. 112–113)

This report pointed to the role played by hostile school environments and the impact these environments have not only on educational opportunities, but also on the very survival of GLB young people.

Gibson’s (1989) report was met by criticism from a variety of detractors. Following the release of this study, then Secretary of HHS Louis Sullivan and some conservative members of Congress denounced it for ideological reasons. As Sedgwick (1993) notes, Sullivan spoke out—not against its accuracy—but, it seems, its very existence. In a written statement, Sullivan asserted:

the views expressed in the paper entitled ‘Gay Male and Lesbian Youth Suicide’ do not in any way represent my personal beliefs or the policy of this department. I am strongly committed to advancing traditional family values . . . . In my opinion, the views expressed in the paper run contrary to that aim. (cited in Sedgwick, 1993, p. 154)

Unlike Sullivan, some have criticized this study by directly questioning the validity of Gibson’s numbers. Specifically, Jenkins (1996) argued that Gibson’s paper was ‘‘a polemical piece . . . [that] is the sole source for current estimates of the numbers of gay teen suicides (p. 17). In spite of this opposition, Gibson’s study helped make visible the existence of GLB youth and shifted some of the focus away from concern with the problems of government intervention on behalf of ‘‘homosexuals’’ in schools.


Despite this initial conservative backlash against Gibson’s HHS report, its recommendations eventually helped to inspire the development of policies and programs to serve the needs of GLB youth. In particular, the report (1989) spelled out the possibility that changes in schools could enhance the well-being of these young people. Gibson argued that ‘‘[s]chools need to take responsibility for protecting gay and lesbian youth from abuse by peers and providing them with a safe environment to receive an education’’ (1989, p. 135). Because of this emphasis on schools as hostile environments for GLB youth, the publication of the Report of the Secretary’s Task Force on Youth Suicide (1989) and the attention it received from advocates gave rise to the passage of state and local laws to ensure equal educational opportunities for gay, lesbian, and bisexual youth. In fact, since the early 1990s, a number of states, districts, and individual schools have taken concrete steps to implement aspects of these recommendations, consistent with this plea to prevent harm to students in schools (Perotti, & Westheimer, 2001).

Efforts in Massachusetts represent the most expansive attempts by a state government to implement Gibson’s pleas to acknowledge the existence of GLB students and to address the intense homophobia they face in schools because of its link to suicidality. Many GLB activists and supporters in Massachusetts organized in the early 1990s to express their concerns regarding the connection between the school environment and gay, lesbian, and bisexual students’ experiences. Public hearings were held in November and December of 1992 so that students and concerned adults—including parents, educators, and advocates—could testify to their experiences (Perotti, & Westheimer, 2001). A number of the young people who spoke expressed their feelings about the hardships they endured in school. One student, 18-year-old Stephen Obuchowski, testified to his experiences:

I just began hating myself more and more, as each year the hatred toward me grew and escalated from just simple name-calling in elementary school to having persons in high school threaten to beat me up, being pushed and dragged around the ground, having hands slammed in lockers, and a number of other daily tortures. (Governor’s Commission on Gay and Lesbian Youth, 1993, p. 8)

This young man’s testimony pointed to the incessant harassment he confronted at school, implying that his ability to access educational opportunities was hindered, as facing this degree of abuse seemed likely to impede his capacity to focus on school work.

At times, gay youths’ testimony revealed the severity of the consequences of the loneliness they experience well beyond the bounds of education. Randy Driskell described his isolation and his psychological state as follows: “But who could I talk to? Through the last few years, I have been conditioned into believing gay is wrong . . . . After three years of conditioning, I forgot all the things my mother taught me. I lost respect for myself and wanted to die” (Governor’s Commission on Gay and Lesbian Youth, 1993, p. 14).

Numerous disturbing testimonies such as these drew attention to the struggles that many GLB young people faced in school on a daily basis. These struggles highlighted the isolation and harassment experienced by gay, lesbian, and bisexual youth—as well as those perceived to be gay—and tended to support the findings in Gibson’s report regarding suicide.

In combination with extensive advocacy efforts, including lobbying carried out by high school students, the public hearings helped win support for funding for programs specifically targeting GLB youth. In fact, Massachusetts led the way in emphasizing the importance of protecting GLB students from harm as a key component of programs targeting gay, lesbian, and bisexual students. This program focused on the central notion that schools have a responsibility to protect the health and well-being of GLB students—and those perceived to be GLB—within school settings (Perotti, & Westheimer, 2001). During 1993, the Governor’s Commission on Gay and Lesbian Students made recommendations on creating a supportive and safe environment for gay and lesbian students. These recommendations, eventually adopted by the Board of Education, included the proposal that schools should:

● Develop policies that protect gay and lesbian students from harassment, violence, and discrimination.

● Offer school personnel training in violence prevention and suicide prevention.

● Offer school-based support groups for gay, lesbian, and heterosexual students.

● Provide school-based counseling for family members of gay and lesbian students. (cited in Perrotti & Westheimer, 2001, p. 3)

In the wake of these recommendations, government officials helped to establish the Safe Schools Program for Gay and Lesbian Students in 1993, making Massachusetts the first state to fund a program specifically designed to support gay, lesbian, and bisexual youth in schools.ii The Safe Schools Program sought to address the harassment facing these young people in schools and emphasized the threat of suicide to those who experience intense homophobia.

These efforts created the foundation for passage of legislation to amend Massachusetts’ student anti-discrimination law, which was passed and signed into law in 1993 by Republican Governor William Weld. The revised law reads:

no person shall be excluded from or discriminated against in admission to the public school of any town, or in obtaining the advantages, privileges, and courses of study of such public school on account of race, color, sex, religion, national origin, or sexual orientation. (Perotti, & Westheimer, 2001, p. 4)

The Massachusetts statute mirrored the concerns expressed in Gibson’s (1989) report and also resembled an earlier Wisconsin law, which received much less attention, ‘‘that bar[s] harassment or discrimination based on sexual orientation in their public schools’’ (Sandham, 2002, p. 5). The passage of these laws foreshadowed the adoption of similar commitments in other states, including California, Connecticut, Vermont, Washington, and Maryland. In addition, Minnesota and New Jersey have ‘‘added language to existing civil rights laws that prohibits discrimination based on sexual orientation in schools’’ (Sandham, 2002, p. 5).


Building in part on the foundation of this type of anti-discrimination legislation, over the past decade, legal advocates have taken on cases that reflect a concern for the physical and mental health of GLB youth. In so doing, the federal courts have weighed in on the language of the debate regarding the protections afforded to these young people. Many of these cases involving the harassment of gay or lesbian youth or students perceived to be gay, have drawn largely on Title IX—the Federal anti-gender discrimination policy—and the Fourteenth Amendment’s Equal Protection Clause as grounds upon which to decide claims of discrimination. One notable example of the latter is the 1996 case of Nabozny v. Podelsny based on events that took place in schools in Ashland, Wisconsin (Broz, 1998). Jamie Nabozny, who filed suit after having left Wisconsin during 11th grade, was harassed incessantly over the course of four years in this school district. According to the Court, during seventh grade, just as he realized that he was gay:

Nabozny began to be subjected to daily verbal and physical harassment. Students called him names such as ‘‘faggot,’’ and he was hit, kicked, and spat on inside the school premises . . . The most egregious incident in the seventh grade occurred [when] . . . [t]wo students . . . pushed Nabozny to the floor in a science classroom . . . [and] then performed a mock rape on Nabozny, telling him that he should enjoy it. Twenty other students watched and laughed. (Broz, 1998, p. 753)

While the horrifying treatment Nabozny received at the hands of some of his peers was emphasized, this student’s lawyers focused on the response he got from the staff and administration when he reported incidents to them. In particular, Nabozny’s middle school principal responded in a way that reflected a view that homosexuality should be punished. He stated that ‘‘boys will be boys,’’ and that these events were the result of Nabozny’s choice ‘‘to be so openly gay’’ (Broz, 1998, p. 753). The principal offered much the same response to Nabozny’s parents when they met with him. While the district court dismissed all of Nabozny’s claims, on appeal the Seventh Circuit U.S. Court of Appeals reinstated both Nabozny’s gender discrimination and sexual orientation discrimination claims under the Equal Protection Clause of the Fourteenth Amendment. After the Circuit Court issued its decision and remanded the case to the lower court, the Ashland school district arrived at an out-of-court settlement of more than $900,000, a victory gay-rights advocates claimed acknowledged the danger of homophobia in schools (Perotti, & Westheimer, 2001).

The Nabozny case signifies the conflict between two competing visions of the true danger with regard to homosexuality in schools. When testifying in front of Congress about his experiences, Nabozny suggested that the schools’ actions were founded upon an understanding that homosexuals are the source of ‘‘the trouble,’’ rather than the school’s climate. In particular, he pointed to the way in which the school had separated him from others because of the harassment he received from peers instead of dealing directly with the harassment as the problem (Broz, 1998, p. 778). The glaring lack of responsibility assumed by school officials suggests that schools continue to function in a way that punishes the GLB student for being gay, lesbian or bisexual, rather than penalizing expressions of homophobia. The settlement agreement seemed to suggest that schools could no longer function in this manner.

On April 8, 2003, the U.S. Court of Appeals for the Ninth Circuit delivered an even more significant decision with regard to this conflict than Nabozny. In the case of Flores v. Morgan Hill (2003), six former students in the Morgan Hill School District in California had filed suit, arguing that school administrators showed negligence by ignoring numerous complaints about anti-gay harassment and violence. The Ninth Circuit Court affirmed the lower court ruling and held that the defendants violated the plaintiffs’ Equal Protection rights under the Fourteenth Amendment, concluding that:

Here, as in Nabozny, we are unable to garner any rational basis for permitting one student to assault another based on the victim’s sexual orientation, and the defendants do not offer us one. . . the record contains sufficient evidence for a jury to conclude that the defendants intentionally discriminated against the plaintiffs in violation of the Equal Protection Clause (Flores v. Morgan Hill, 2003).

Only with this recent decision has a federal court decided that a school district and its administrators had violated the Equal Protection rights of students who are gay, lesbian, or perceived to be so. While drawing on the Fourteenth Amendment of the Constitution, this federal court supported the notion that schools could not fail to punish these extreme expressions of homophobia. In so doing, the decision dramatically reinforced the notion that the damage done by homophobia, not homosexuality, serves as the real threat to young people in schools.


Although these legal decisions have marked significant victories in the struggle over homosexuality and education, social science investigations of GLB suicidal tendencies have also played a crucial role in informing efforts to ensure equal educational opportunities to GLB youth by drawing attention to the need to bring about changes in school practice and policy.

Prior to 1989, little research had been done on GLB youth in general or on their tendency toward suicide. Because of the lack of population-based health surveys of youth that included questions about sexual identity, the first substantial wave of literature written about gay and lesbian youth was based upon important but small case studies and convenience samples of gay youth. These early works on GLB youth based on convenience samples frequently pointed to an increased prevalence of suicide and suicidal tendency amongst the youth under study relative to national statistics. For example, various studies drawing samples from organizations such as youth groups, community centers, and social service agencies pointed to high levels of suicide attempts, ranging from one third to more than half of those studied (Remafedi, 1987; Kruks, 1991; Remafedi, Farrow, & Deisher, 1991; Proctor, & Groze, 1994; Hershberger, & D’Augelli, 1995).

Much like Gibson’s (1989) report, which drew on findings from earlier works, ‘‘first wave’’ studies based on convenience samples suggested some connection to students’ experiences of school contributed to participation in high-risk behaviors, such as suicide, or participation in suicidal ideation or attempts. Remafedi’s (1987) work suggested a role played by ‘‘school problems relating to sexuality’’, including high levels of dropout because of verbal and physical abuse experienced. Others investigating the impact of victimization on GLB youth mental health and suicidal tendencies found that victimization—in and out of school—had to be viewed in conjunction with other variables including family support and self-esteem (Hershberger, & D’Augelli, 1995). While the studies offered initial insights into GLB youth suicidal tendencies, a variety of important factors limit their significance. In particular, the ability to compare the studies is hindered by the use of inconsistent measures regarding age and sexuality.

Since the late 1990s, numerous researchers have begun to address some of the weaknesses in these ‘‘first wave’’ studies on GLB youth suicide. Researchers have made use of recent population-based studies that have included questions relating to suicidal tendencies, sexual orientation, and/or sexual behavior. These surveys have included the Centers for Disease Control-sponsored Youth Risk Behavior Surveys (YRBS) conducted in Massachusetts, Vermont, and other locales beginning as early as 1993, as well as the 1987 Minnesota Adolescent Health Survey (Remafedi, French, Story, Resnick, & Blum, 1998) and a 1991 national school-based survey of American-Indian adolescents (Saewyc, Skay, Bearinger, Blum, & Resnick, 1998). These surveys helped diminish the sampling bias present in earlier studies.

Based on these surveys, published studies regarding the health and wellbeing of gay, lesbian, and bisexual young people have generally supported the findings of Report of the Secretary’s Task Force on Youth Suicide (1989) by arguing that GLB-identified youth are at particularly high risk for suicide and suicide attempts (Remafedi et al., 1998; Garafalo, Wolf, Kessel, Palfrey, & DuRant, 1998; Garafalo, Wolf, Wissow, Woods, & Goodman, 1999).

Other studies have pointed to the increasing risk for suicide for same-sex sexually active youth (DuRant, Krowchuck, & Sinal, 1998; Faulkner, & Cranston, 1998). Using data from the 1995 Vermont YRBS, DuRant, Krowchuck, & Sinal, (1998) found that same-sex sexual behavior amongst males correlated with suicide. Faulkner and Cranston (1998) used 1993 Massachusetts data that did not include questions about sexual orientation and-argued that same-sex sexually active students (both male and female analyzed together) are almost 50 percentmore likely to have ‘‘seriously considered suicide’’ in the past year, with two times as many same-sex sexually behaving students as other students reporting they had attempted suicide within the past year. Additionally, these researchers found that with increasing numbers of sexual partners, risk of suicidal tendency increased as well.

Although most studies of youth risk behavior have focused primarily on data from individual states and cities, recently Russell and Joyner (2001) have drawn on a nationally representative sample from the National Longitudinal Survey of Adolescent Health (Add Health), a data set allows for identification of same-sex sexually attraction and behavior. Using this survey, Russell and Joyner found that, according to their definition of same-sex sexual orientation (SSSO), same-sex attracted/behaving youth are more than twice as likely as their peers to attempt suicide. The broad pattern exhibited by these more recent studies reflects the finding that gay, lesbian, and bisexual youth are more likely than their heterosexual peers to report high levels of suicidal tendency.

While most of these works did not attempt to investigate the relationship between GLB-identified or behaving youth suicidal tendencies and experiences of school, some have pointed to the association between specific indicators of a student’s level of victimization experienced by the student in the school setting and sexual behavior or identity. Faulkner and Cranston (1998) found that students sexually active with members of the same-sex reported a greater degree of victimization in school and concern for their safety in school than their peers who were sexually active with members of the opposite sex. For example, students with histories of sexual activity with members of the same-sex were more than three times as likely ‘‘to report not going to school because they felt unsafe and more than twice as likely to report having been threatened or injured with a weapon at school’’ (p. 263). Additionally, Bontempo and D’Augelli (2002) have found that GLB youth experiencing high levels of at-school victimization reported higher levels of suicidal tendencies and other risk behaviors than their heterosexual peers who experienced high levels of victimization at school.

Although these important works regarding GLB youth provided only limited evidence to support the notion that hostile school climates can be linked to suicidal tendency, some researchers have used their articles to assert the importance of investigating such a link. For example, Garafalo, Wolf, Wissow, Woods, and Goodman (1999) state that:

While most gay, lesbian and bisexual youths cope with stresses and become healthy, productive adults, understanding the interrelationships among demographic variables, health risk behaviors, sexual orientation, and suicide risk may aid in the recognition of vulnerable youths and the identification of individuals at risk. Perhaps the challenge is to move beyond statistical estimates of risk to the exploration of more complex issues, such as resiliency or the effects of marginalization on adolescent development and well-being (p. 492).

In addition to noting the idea that some GLB youth may benefit from ‘‘resiliency,’’ these authors also suggest that ‘‘marginalization’’ may play a crucial role in high rates of GLB suicidal tendencies. Recent work (Blake, Ledsky, Lehman, Goodenow, Sawyer, & Hack, 2001) has taken this suggestion a step further, with findings that implicate the school climate in gay and lesbian risk behaviors, though, unfortunately, this study did not draw on nationwide data.


While many insights have been gained from the attention drawn to the psychological and physical consequences of homophobia on GLB youth, critics have expressed concern regarding this strategy. The most politically charged critique of these efforts is one that resembles the warning issued by Patterson (1998) in his reflections on the African-American struggle for equality 50 years after Brown. As noted above, Patterson argues that emphasizing African Americans’ victimization at the hands of Whites perpetuates an acceptance of Black powerlessness and overwhelms the possibility of self-determination. Similarly, with regard to GLB youth, some have argued that highlighting risks and self-harming behaviors is creating a ‘‘distorted picture of what it is like to be a gay teenager’’ (Tuller, 2002). The most outspoken advocate of this perspective is Ritch Savin-Williams, professor of developmental and clinical psychology at Cornell University and a prominent researcher in this field; while acknowledging that the strategy has helped gain political support for assisting gay and lesbian youth, Savin-Williams has argued that ‘‘the research is ‘pathologizing’ gay youth and handing conservative groups ammunition to argue that being gay is inherently unhealthy’’ (Tuller, 2002). Savin-Williams has asserted that:

Most of this research was done essentially to try to gain resources and services for these youth by demonstrating to the outside world how poorly they have been treated. . . . But the research is delivering what I call ‘‘the suffering suicide script,’’ which essentially tells them, “Hey, look how horrible it is to be gay.” (cited in Tuller, 2002, p. D7)

In other words, Savin-Williams has argued that, in their efforts to serve GLB youth, researchers have placed too much emphasis on troubling aspects of the lives of these young people. As a result, he has called for social scientists to reevaluate their strategies in order to develop a more balanced view of GLB youth experiences that reflects the more ordinary experiences they share in common with other adolescents (Savin-Williams, 2001a; Savin- Williams, 2001b).

Much as Savin-Williams attests, conservative groups actively campaigning against GLB-positive efforts in schools have pointed to research findings about gay and lesbian youth risk behaviors as a way to attack these efforts and the underlying assumptions supporting gay and lesbian student advocates’ actions. For example, the Traditional Values Coalition (TVC), led by Reverend Louis Sheldon, has published a report that argues that ‘‘children are at risk when they self identified as homosexuals’’ (Sheldon, 2002, p. 8). Presenting confounding findings from one unnamed work by Remafedi and another by Dr. Joseph Nicolosi, a leader of efforts calling for schools to use ‘‘reparative’’ therapy, which ‘‘helps’’ gays and lesbians become heterosexual, this report argues that:

. . .the most important risk factors in gay youth suicide attempts are: 1. Early self-labeling; 2. Early sexual experiences; and 3. Acting like a member of the opposite sex. From what Dr. Nicolosi and Dr. Remafedi have observed, a teen who is recruited into the homosexual lifestyle at an early age is thus conditioned to believe he is born homosexual. The longer he is in the lifestyle, the more entrenched behavior becomes and the more difficult it becomes to be free of this destructive behavior. As a result, many self-identified ‘‘gay’’ teens may be tempted to kill themselves because of internal conflicts over their behavior. (Sheldon, 2002, pp. 7–8)

This rendering stands in stark contrast to Remafedi’s qualification offered in a 1998 article, in which the author asserted that ‘‘the associational nature of the findings does not permit causal inferences regarding homosexuality and suicide risk . . .’’ (p. 59). Nonetheless, according to Sheldon, making the ‘‘choice’’ of engaging in the so-called ‘‘homosexual lifestyle’’ is what leads to problems for these young people, rather than the hostility they may face in school and in the world around them. The TVC report cites Nicolosi, who argues that blame for the problems facing gay and lesbian youth rests with pro-gay efforts to intervene in schools:

I believe it is a profound mistake to encourage adolescents with homosexual feelings to identify themselves as ‘‘gay’’—and thus make a sexual lifestyle decision with long-term and potentially deadly implications. Yet that is precisely the goal of Project 10 and similar pro-gay programs, which are being instituted in scores of public high schools across the country. (Sheldon, 2002, p. 7)

By emphasizing the notions that youth choose to be GLB, conservative forces are currently arguing that ‘‘pro-gay’’ efforts are what damage young people, making matters worse by ‘‘encouraging’’ them to ‘‘become’’ gay.

While Savin-Williams and others have challenged social scientists to explore the fullness of the lives of GLB youth, unfortunately some very real and troubling barriers exist that block the creation of even stronger social scientific efforts to gain insight into these young people. In particular, political opposition to surveys that deal with sexuality serves as perhaps the most daunting obstacle to moving forward in this area. As with all surveys, current large-scale, population based random sample surveys of teenagers have their limitations, though they have offered initial insights into GLB youth experiences and the need to implement policies that serve them; unfortunately, in recent years, the inclusion of questions regarding sexual orientation in the Youth Risk Behavior Survey has been removed from all states except Massachusetts because of political attacks from conservative forces (Ireland, 2000). By successfully opposing the inclusion of these questions, conservative forces have effectively diminished the ability of social scientists to develop a more comprehensive picture of the lives of GLB youth with which to inform advocates and the American public.


In the aftermath of the success of Brown in placing African American students’ well-being at the center of the debate over equal educational opportunities, advocates of desegregation and other civil rights policies have faced powerful and effective opponents. So too, gay, lesbian, and bisexual youth, their advocates, and social scientists interested in understanding the experiences of these young people have made much progress, and yet also face an ominous threat posed by those who would dismantle research, laws, and policies upon which these initial strides have been made.

While the legacy of Brown is revealed in the efforts of GLB youth and their advocates to achieve equal educational opportunities, this troubled legacy can also serve to guide the future work of those seeking to ensure the quality of the lives of GLB youth. Because research efforts, laws, and policies have tended to focus on the role played by victimization in the lives of these young people within school settings, social scientists must strive to develop a more balanced picture of gay and lesbian youth experiences.

Further, since Brown’s complex legacy reflects an intensely contested debate over educational inequalities, researchers and advocates must recognize the obstacles put in place to impede the development of a more comprehensive vision of both the struggles and the strengths of gay, lesbian, and bisexual young people. In coming to understand the role that concerns for the overall well-being of young people have played in the battle surrounding Brown, concerned individuals must take heed of this history and confront efforts to dismantle access to information about the lives of gay, lesbian, and bisexual students. However, to undermine opposition to these ongoing social movements and to truly revive the legacy of Brown, we must also renew our commitment to guarantee the well-being of all students.


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SARAH STRAUSS is a high school social studies teacher and a graduate student in Sociology and Education at Teachers College, Columbia University. Her current research interests include the impact of the school environment on student experiences, with a particular focus on the lives of gay, lesbian, bisexual, and transgender youth.


i In contrast, as Sedgwick (1993) notes, while the 1980 publication of the diagnostic manual of mental illness was the first that didn’t include "homosexuality," it was the first to include a new diagnosis: "Gender Identity Disorder of Childhood." This left children seen as not fitting into their "proper" gender roles vulnerable to stigmatizing diagnosis and treatments.

In contrast, as Sedgwick (1993) notes, while the 1980 publication of the diagnostic manual of mental illness was the first that didn’t include "homosexuality," it was the first to include a new diagnosis: "Gender Identity Disorder of Childhood." This left children seen as not fitting into their "proper" gender roles vulnerable to stigmatizing diagnosis and treatments.

ii In recent years, this program has experienced serious cutbacks due, in large part, to state budget difficulties (Stewart, 2002, August 25).

Cite This Article as: Teachers College Record Volume 107 Number 3, 2005, p. 424-452
https://www.tcrecord.org ID Number: 11794, Date Accessed: 1/25/2022 6:51:23 PM

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  • Sarah Strauss
    Teachers College, Columbia University
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    SARAH STRAUSS is a high school social studies teacher and a graduate student in Sociology and Education at Teachers College, Columbia University. Her current research interests include the impact of the school environment on student experiences, with a particular focus on the lives of gay, lesbian, bisexual, and transgender youth.
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