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LGBT Argumentative Essay Topics

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LGBT Argumentative Essay Topics : LGBT is a very thorny issue that is not accepted in many countries and even some people don’t want to talk about it, even in developed countries like the United States. No matter how much we try to hide it or shun it away, we must understand the LGBTQ community, as well as acknowledge their existence.

If you are researching and want to write an argumentative essay on LGBT, today we will look at some of the topics you can write about.

Find LGBT discrimination argumentative essay topics, LGBT rights argumentative essay topics, topics on argumentative essays on LGBT, and more.

1. Should the Universal Declaration of Human Rights explicitly include the rights and protection of rights of LGBT (lesbian, gay, bisexual, transgender) worldwide?

2. Should all companies’ Work cultures be adaptable to the LGBT community?

3. Is intersectionality so important when thinking about LGBT issues?

4. Must we all Become More Accepting of the LGBT Community?

5. Is there domestic Violence In the LGBT Community?

6. Should governments intervene to lower the Violence Against LGTBQ Community?

7. The United States Healthcare: Are there barriers to LGTB Health?

8. How should The LGTB Community be treated by society?

9. Should the Transgender Community And The LGTB Community be classified in the same category?

10. Did The Stonewall Riots of 1969 Jumpstart the Gay Movement?

11. Should Adolescents gays and lesbians be allowed to join gay movements?

12. Will Same-Sex ever Be Accepted By Everyone?

LGBT Argumentative Essays Samples For Students

50 samples of this type

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Gay Marriage Argument Essays: Should It Be Legalized

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Adam And Eve Not Adam And Steve Argumentative Essay Samples

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Table of Contents

Introduction 2

Man and Woman, Woman and Woman or Man and Man 4 Procreation or Not 4 Optimum Environment for Children 5 Gay Relationships are Moral or Immoral 5 Federal Law 6 President Obama 7 Politicians and Media Figures 8 Conclusion 10 Work Cited 10

Norah Vincents Learning Experience In Self-Made Man Argumentative Essay

Gay marriage in america argumentative essay examples.

Same-sex marriage is the legal union between people of the same sex. The debate concerning the marriage rights and benefits to gay couples has been intense since early 1970s. In 1996, the then US president Bill Clinton, signed DOMA (Defense of Marriage Act) into law (Pinello 12). This Act gives a legal definition of Marriage as a legal union between one woman and one man. However, this enactment gave the definition of marriage for federal law purposes only and gave authority to the states to make their own rulings concerning the matter.

Example Of Argumentative Essay On Gay Rights In Canada

Argumentative essay on gay marriage.

This thesis aims to highlight the issue of gay marriage that is now being seen in a positive light. It has readily gained acceptance over so many years. People are beginning to see it as an acceptable reality. The roots of its acceptance are also traced through various countries with so many countries beginning to understand how essential it is to allow man with the freedom of anything.

Free Argumentative Essay On Gay Marriages

Marriage is a social union between two people, a union that promotes connection. The definition of marriage often varies depending on individual beliefs, cultural values among others. It can be defined as a union where individual relationships such as intimacy and sex are accepted. Marriage is formalized through a wedding either in a law court or in a church. Marriage was naturally supposed to be between people of different sex but in recent times, marriages between people of the same sex have been a normal scenario. Marriage is however not an institution for companionship alone but also for procreation, something gay couples are unable to do.

Legalizing Gay Marriage Argumentative Essay Examples

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Example Of Same Sex Marriage Arguments Essay

Argumentative essay on increased incidence of std in older adults.

Unprotected sex among older adults is giving rise to more incidents of sexually transmitted disease in people between the ages of forty-five to seventy. There will always be a reaction to every action, and having sex without protection is the cause of this increase of sexually transmitted disease among older adults. Protecting oneself from sexually transmitted disease requires the practice of safe sex. Safe sex should be worn as an amour against STDs.

Increased Incidence of STD in Older Adults

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1. In William Blake's "Songs of Innocence and of Experience," Blake attempts to dig into the very nature of existence and perception; part of the primary message of the works is that childhood is an innocent time that should be protected, but it is capable of being corrupted by the structures and rules of the adult world. As we get older and move through life, getting more experiences, we lose our innocence and start to become adults because of what the government, the church and the rich do to us.

Argumentative Essay On The Pros And Cons Of Single-Sex Schools

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Wong Kar-Wai is a director based from Hong Kong, who is hugely respected as not only a director, but an artist who is constantly mentioned by critics and film enthusiasts alike. Although many of his films did not go on to become big as other major films in the Box Office, Wong Kar-Wai's films have begun to be well known for breaking the contemporary style of Hong Kong cinema.

Gender Bender Argumentative Essay

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285 LGBT Essay Topics & Examples

Whenever you need original LGBTQ essay topics, check this list! Our experts have collected good samples for you to consider and title ideas to choose from.

🏆 Best LGBT Essay Examples & Topics

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The Pros and Cons of Gay Marriage Counteracting the argument that prohibition of gay marriage appears similar to discrimination is the idea that marriage, in the traditional understanding of the word, is the union of necessarily different sexes, a man and a […]
Homosexuality in Frankenstein by Mary Shelley However, at the same time, these breaks from the traditions incited a response reaction in favor of more traditional social roles in other areas, such as the refutation of male sexual relationships to the extent […]
Kant`s View on Homosexuality Kant says that homosexuality is not merely an inclination, which a human feels towards another, but it is the preference for another person’s sexuality.
Why Gay Marriage Should Not Be Legal Therefore, because marriage is a consecrated unification of a male and a female, ready to sacrifice all that is at their disposal for the continuation of the human species and societal values, I believe all […]
Defining Characteristic of LGBTQ Community In addition to this, the LGBTQ is a community since it is made up of a relatively small segment of the society.
Argument for Gay Marriages Enacting laws that recognize gay marriages would be beneficial to the society in the sense that it promotes equal rights among members of the society.
Homosexuals Should Not Be Allowed to Adopt Children Therefore, considering the significance of the traditional marriages in providing children with the necessary developmental support, it is important for societies to ban the concept of homosexuals adopting children.
“What Is a Homosexual?” by Andrew Sullivan According to Sullivan’s essay What is a Homosexual, homosexuality is the isolation from the rest of the society and a diversity of human sexuality; however, it is not a factor which people are guided by […]
Philadelphia: Prejudice About Homosexuality Philadelphia is the movie that touches upon numerous themes, and one of them is the development of the relations between two men with absolutely different interests and principles: one of them is Andrew Beckett, who […]
Homosexuality – Nature or Nurture? In a letter to The Wall Street Journal, members of the National Association for Research and Therapy of Homosexuality, a coalition of therapists who argue that they can cure homosexuality, stated that “many of the […]
Lesbian, Gay, Bisexual, and Transgender Subculture The pioneers of such campaigns disagree with the ideas and behaviors associated with the LGBT Subculture. These celebrations “have also made it easier for different members of the subculture to network and exchange their views”.
LGBTQ Co-Culture: The Key Aspects While all people have sexual orientation and heterosexuality presuppose romantic and sexual attachment to people of the opposite sex, gay and lesbian individuals are attached to partners of the same sex.
Women Reactions to Bisexual Husbands The paper will rely heavily on sociological perspectives of heterosexuality and bisexuality and the arguments that are likely to guide the women’s reaction to their husband’s bisexual nature.
Aspects of Equality for Transgender Athletes The authors of the article claim that transgender athletes deserve equal representation and the right to participate in competitions in the divisions of the gender they identify themselves by referring to social structures and justice.
Relations Between Homosexuality and Indian Culture Lesbianism is a relatively silent practice in India as opposed to gay practice and even the organizations for women do not really advocate for or promote it.
Homosexuality in Renaissance Italy As we begin to read the history of art in Italy one finds some examples of homosexuality among the notables of the time.
Gay Beaty Contests Question Issue For gays, beauty contests are regarded as celebratory events or ‘happenings’ and are best expressive of what is for many, particularly younger gays, seen to be one of the defining characteristics of gay life, that […]
Transgender Bathroom Policies in Schools The topic of why transgender pupils cannot simply utilize private rooms designated for such gender identification, given that individuals who identify as boys and girls have their washrooms, is at the heart of the discussion […]
Is Homosexuality a Psychological Condition? Romantic attractions as well as sexual acts are usually categorized as heterosexuals or homosexuals and depending on the biological sex of the individual; the person may classified as gay or lesbian.
Mental Health Issues Among LGBTQ (Queer) Youth Studies point to multiple factors that play a role in the risk of suicide among LGBTQ youth, such as gender, socioeconomic status, bullying, and school experience. There is a need for further research and interventions […]
LGBTQ+ (Queer) Military Discrimination in Healthcare Furthermore, the subject is relevant to the field of psychology as the current phenomenon examines discrimination in healthcare both from the psychological outcomes experienced by veterans as well as the perception of LGBTQ+ patients through […]
Equality of Transgender and LGBTQ+ Populations The principles of the struggle for the transgender and LGBTQ+ populations should include respect for the choice and self-identification of a person.
Transgender Student-Athlete Participation Policy The updated regulations place the decision to let transgender sportsmen take part in the competition in the hands of the national governing body or, in the absence of such, of a sport’s international federation.
LGBT Discrimination Research Prospects: An Analysis The aim of this assignment is to summarize the research that has been done on LGBT discrimination, particularly in the workplace and during the recruiting process.
Health Inequities in LGBT People By calculating and comparing the number of positive versus negative occurrences in the interactions between LGBT employees and the rest of the staff before and after the introduction of the relevant interventions, one will be […]
Health and Culture of LGBT (Queer) Community I want to do health assessments, so my patients know that their orientation and gender will not be factors in the diagnosis.
Addressing Mental Health Inequities: A Focus on LGBTQ Communities The main bioethical principles of organ transplantation that should be considered are beneficence – to act for the benefit of a patient, non-maleficence – not to harm, autonomy respect for a person’s choice, justice fairness, […]
Transnationalism and Identity: Gomez’s High-Risk Homosexual Categorization is an actual problem of society, which is covered in modern literature and is interconnected with such concepts as transnationalism and identity. The only mature and responsible behavior is not to impose them on […]
Migrant Streams and LGBTQIA (Queer) Experiences in Nursing The response of the staff to Milagro’s incomplete health records is characterized by frustration and the desire to strengthen their understanding of the situation.
Individual and Structural Discrimination Toward LGBT (Queer) Military Personnel Consequently, LGBT military personnel are potentially even more vulnerable to mental health issues due to the combined stress of being LGBT and being in the military.
Health Disparities in the Transgender Community The purpose of the research study is to improve health disparities in the transgender community by eliminating financial barriers, discrimination, lack of cultural competence of providers, and socioeconomic and health system barriers that will increase […]
LGBT+ (Queer) Status and Employment Opportunities The social learning theory provides context for the study by linking any discriminatory practices in hiring, assessment, and perception of the professionalism of the LGTBQIA2S+ community to socially acquired or learned behaviors.
The Gay Teen Suicide & Bullying The article explains that the ones who survive may have access to extensive facilities, support, and status beyond their world of bullies, which sounds reasonable for me.
The Perception of the LGBT (Queer) Community This work contains the conclusion of the analysis of self-presentation by homosexuals using the film My State of Idaho and the book The City of Night.
LGBTQ (Queer) Community’s Challenges in Healthcare For example, the absence of connectivity in healthcare and services for LGBTQ individuals is often isolated from sexual and reproductive health care owing to structural and financing barriers and damaging heteronormative attitudes.
Mental Health Equity for Queer (LGBTQ) People My support for mental health equity in the LGBTQ community as a clinical mental health counselor will require my understanding of cultural competency and how to can use it in practice.
Nurses’ Care of LGBTQ (Queer) Patients The involvement of the NPD practitioners will make sure that the students, more so the ones ready to head into the field, handle the patients at their best.
The Transgender Teens Policy Issues Problem recognition involves recognizing that policies serving to protect the interests of transgender teens need proper enforcement or even proper formulation to ensure effectiveness in protecting and ensuring the best interests of the children.
Nursing: HIV Among Queer (LGBT) Community A combinatory program is required to reduce the rates of HIV transmission, improve the prevention techniques against the virus and ensure the early-stage diagnosis procedures are as effective as possible.
LGBTQ+ Families: Discrimination and Challenges The family model directly affects the social status of family members and the well-being of children. LGBTQ+ families’ wealth level is lower than that of families in the neighborhood due to labor discrimination.
LGBTQ Members: Discrimination and Stigmatization What remains unclear from the reading is the notion that before the 1990s, people from the middle class expressed abiding and strong desires to be acknowledged as “the other sex”.
An Interest Group: The Rights of the LGBT One of the urgent problems in the United States remains the decision on the rights of homosexuals and other representatives of the LGBT.
Los Angeles LGBT Center’s Analysis Internal factors of the organization are cultural competencies, core values, and the effective management of the organization. They determine the goals and aims of the company in the field of healthcare services.
The Issue of Transgender in Sporting Activities Transgender women’s increased body strength and mass make it unfair for them to compete with cisgender women in the same sporting categories. The IOC sets the recommended testosterone level for transgender women to participate in […]
Transgender Women in Sports: Is the Threat Real? In this regard, it can be argued that the advantages of transgender women are a barrier to women’s sports. However, the topic of transgender people has received the most discussion in the last few years […]
The Advantages of Transgender Women Are a Barrier to Women’s Sports The main counterargument of proponents of transpeople participation in women’s sports is that there is no proven link between biology and endurance.
The Article “The Transgender Threat to Women’s Sports” by Abigail Shrier Abigail Shrier’s article The Transgender Threat to Women’s Sports provides a series of arguments and evidence that support the idea of excluding transgender people from women’s sports.
Transgender Women Take Part in Sports Competitions The issues that support this statement are unequal muscular mass of men and women unchanged by transgender therapy; and unequal height and length of the body needed in game sports and jumping.
Recognizing Homosexuality as a Personal Identity According to Freud, all human beings are inherently bisexual, and homosexuality results from a malfunction in the process of sexual development.
Lesbian and Gay Parenthood: Gender and Language However, when people see a lesbian couple whose attitude towards their children is the same as the one in heterosexual couples, they may change their attitude towards lesbian motherhood.
Transgender Participation in Sports Among the successes in resolving the subject of transgenderism in society, medicine, psychology and sports, scientists include the exclusion of transgender issues from the sections of psychiatric diseases, and their inclusion in the section of […]
Transgender Teenagers and Obstacles They Face Transgender teens are one of the most vulnerable groups of people due to the enormous amount of discrimination and everyday challenges they face.
Spirituality and Sexuality in Men Who Identify as Gay The main finding of the study was that gay men raised in Conservative and religious households were subject to discrimination and marginalization.
Suicide Risk in the LGBTQ Community As a result, it is vital to conduct a thorough analysis of all the factors contributing to the health disparity and identify the possible solutions to the problem of suicide risk among LGBTQ individuals.
Protecting Queer People (LGBTQ+) in San Antonio The law was written in such a way that sexual orientation and gender identity were added to the list of protected classes.
Queer (LGBT) in Roman and Greek Civilizations Its visions of beauty, relations, and a sense of life created the basis of the current people’s mentality. In both these ancient states, same-sex relations were a part of their culture and resulted from the […]
Homosexuality From a Christian Viewpoint However, the idea of “orientation” as a property inherent in a particular person is relatively new; it appears only towards the end of the 19th century, making it difficult to directly compare the phenomenon of […]
LGBTQI+ People: Issues They Face and Advocating for Them This is evident in the division of labor between men and women, which demonstrates one of the expectations of society concerning gender-associated roles.
Becoming an Ally of the Queer (LGBT) Population From my point of view, this state of affairs is not appropriate and should be addressed, meaning that I could act as an ally for social justice. This information reveals that allying with the LGBT […]
Depression among Homosexual Males The literature used for the research on the paper aims to overview depression among homosexual males and describe the role of the nurse and practices based on the Recovery Model throughout the depression.
Suicidal Thoughts Among LGBTQ Youth: Client’s Case Assessment The therapist must exercise special caution and delicacy while evaluating the factors related to the case and engaging the LGBTQ client in the process of treatment.
Aspects of Identity: Transgender Status, Gender Identity In many countries in Europe and the rest of the world, the whites always obtain more benefits at the expense of the people of color and other races.
Transgender Women Should Be Allowed to Compete in Olympic Sports It is all due to the higher level of testosterone in their bodies and that some of them can pretend to be transgender to compete against women.
The Use of Psychoactive Substances by LGBT Youth The purpose of this survey is to identify how reliable the information is that LGBT community adolescents are more likely to use psychoactive substances than heterosexual youth.
Homosexuality as Social Construction His research has focused on the evolution of homosexuality from the nineteenth century to the present day, the widespread public regulation of homosexuality in Britain, and the ways that allowed sexuality to become the object […]
Walmart: Insufficient Support of LGBTQ LBGTQ presumably are the category of the population that still is facing one of the highest degrees of xenophobia, for which reason the need for inclusion initiatives remains considerable.
Queer (LGBT) Teenage Bullying at School The importance of this source to the research is associated with the significant role that youth organizations have to play towards minimizing bullying among LGBT students.
Should Gay Couples Have the Same Adoption Rights as Straight Couples? The authors of this article decide to focus on the children of gay men as compared to those of heterosexual parents in their study.
Raising Queer (LGBTQ) Awareness Through Media Most of the violence perpetrated against the LGBTQ community is a result of systematic dehumanization on the basis of sexual orientation.
A Peer Intervention Program to Reduce Smoking Rates Among LGBTQ Therefore, the presumed results of the project are its introduction into the health care system, which will promote a healthy lifestyle and diminish the level of smoking among LGBTQ people in the SESLHD.
Lesbian, Gay, Bisexual, Transgender, and Queer Families’ Issues In tendency for this, it is essential to analyze issues faced by such families in the community and thus provide recommendations on approaches to adopt during counseling sessions of LGBTQ families.
Considering Social Acceptability of Transgender and Transracial Identities This essay will examine two articles providing different views on transgender and transracial identities and argue that considerations used to support the transgender community are not transferable to the issue of transracial.
COVID-19 and the Mental Well-Being of LGBTQ+ Community The newspaper article studied for this week highlighted recent questions about the relationship between COVID-19 coronavirus infection and the mental well-being of Americans in the LGBTQ+ community.
The Church’s Attitude Toward Homosexual Marriage Erickson Millard claims that Jesus’s teaching about the permanence of marriage is based on the fact that: God made humanity as male and female and pronounced them to be one.
Homosexuality and Feminism in the TV Series The depiction of these complex topics in the TV series of the humoristic genre implies both regressive and progressive impulses for the audience.
Challenges Faced by Members of the LGBTQ Community Historically, homosexuals have encountered many challenges due to their erotic orientation because there exist certain people in society who view them as a deviation from the norm.
Gay Marriage Should Be Repealed The institution of marriage has changed dramatically within the first two decades of the 21st century due to the gradual acceptance of gay marriage.
Transgender Athletes in Female Sports Teams Thus, there are two contrasting views: to allow transgender people to compete in the women’s competition or organize separate competitions for them.
Queer (LGBTQ) Therapy and Religious Impact Secondly, LGBTQ+ community members face an array of challenges, which are not seen by the rest of the population. The necessity is caused by unique unfortunate aspects of these people’s lives, which must be addressed […]
“Social Attitudes Regarding Same-Sex Marriage and LGBT…” by Hatzenbuehler It relates to the fact that the scientists failed to articulate a research question in the proper form. However, it is possible to mention that the two hypotheses mitigate the adverse effect of the lacking […]
Anti-Transgender and Anti-LGBQ Violence Crisis in the US The vicious circle of minority stress that leads to marginalization and the marginalization that contributes to the stigma has to be broken.
LGBT (Lesbian, Gay, Bisexual, and Transgender) in Canada, Japan and China With a perfect understanding of the LGBTQ issue in Canada, my team and I started to compare LGBTQ in Canada, China, and Japan.
The Defense of Marriage Act: LGBTQ + Community One of the milestones in the development of the struggle of members of the LGBTQ + community for their rights in the United States is the adoption of the Defense of Marriage Act.
Mental Health Problems in Bisexuals Thus, the study appears to be insightful in the context of exploring the mental health of bisexuals. This article is informative, as it describes that the aforementioned factors appear to be influential considerably in the […]
Mental Health in Bisexuals: Mental Health Issues The current research views the mental health of bisexuals from several different perspectives in order to evaluate all the possible mechanisms that could have contributed to mental health issues in bisexual individuals over the course […]
Why LGBTQ+ (Lesbian, Gay, Bisexual, Transgender, Queer) Is Becoming Popular In the context of the continuity of experience, morality, and moral values, it is appropriate to emphasize one of the most apparent global trends, namely the gradual recognition of the inalienable rights of the LGBTQ+ […]
Teaching Strategies for LGBTQ (Queer) Community Men and women have different learning styles and orientations that depend on past experiences, interests, and social and biological roles. Therefore, educators should learn the art of inquiry to assess a group, inform them of […]
Abuse in the Queer (LGBTQ) Community Rolle et al.establish that there is an overwhelming increase in the rate of abuse across the LGBT community mainly because of their societal stigma and potential rejection. The consistent abuse of the individuals is a […]
LGBTQ: Personal Characteristics in Health Promotion According to GLMA, since the patient’s cultural relevance is vital to improve their health in this healthcare facility, in addition to biophysical information, the questionnaire should contain cultural questions.
Kahiu’s Rafiki Movie: Stereotypes Regarding Homosexuality Kahiu’s Rafiki movie is a salvo regarding an ongoing cultural conflict in Kenya over the rights of the LGBTQ community. The reason is that they live in a society that prevents them from expressing the […]
Nursing: Caring for a Pregnant Lesbian The second sensitive issue is the family history of diabetes. It is unknown if the patient herself had diabetes in the past.
The Gay Gene: Understanding Human Sexuality If this gene existed and it was similar to a gay gene, it would explain the difference in gay people. If this happened, there would be a great change in the way gay people are […]
HIV Transmission From Homosexual Men Receiving Cure The study reaches the following conclusions: In general, male partners to MSM receiving treatment are at risk of contracting HIV virus although the risk is relative to condom use as well as the last time […]
Gay Couples as Vulnerable Population and Self-Awareness The idea of same-sex marriages has developed in America to a legal platform. Cultural beliefs that undermine the role of same-sex parenting have an impact on the efficacy of gay couples as parents.
The Gay Marriages: Ethical and Economic Perspectives Among the key ethical dilemmas that are related to the issue in question, the conflict between religious beliefs and the necessity to provide the aforementioned services, the issue regarding the company’s needs v.its duty to […]
The Houston Gay Community’s Health Nursing Considering the demographics of this population group, this study seeks to carry out a community health analysis of the Houston Texas gay community, with a special emphasis on the health risks and health implications in […]
Homicides Associated With Homosexual Lifestyle Knight notes that murders by homosexuals are very common and most of the times they involve both sexes, either as the victims or the assailants.
HIV Intervention in Gay Community The AIDS scourge is at the center of this study because this paper seeks to address AIDS as a special health concern affecting the gay community in the Montrose area, with a clear aim of […]
Medical and Social Stances on Homosexuality The main aim of the essay is to highlight the medical and social view of homosexuality. There is no doubt that homosexuality is the current problem that threatens to wreck marriages and accelerate the spread […]
Attitude to the LGBTQ Rights in the Political System LGBTQ rights have advanced many positions in the last several decades. There is quantitative evidence regarding the increase in public support of gay rights.
LGBTQ Rights: Sexual Minority Members Discrimination In the past few years, the number of legal cases related to discrimination against LGBTQ representatives has been growing. In the past 30 years, LGBTQ activists have begun to fight for members of sexual minorities’ […]
Social Work With Disabled Representatives of LGBT Community Members of the LGBT community with disabilities are one of the most invisible and closed groups, both within the community itself and in society at large.
Bullying of LGBTQ Students in American Schools The chosen article focuses on the issue of bullying of LGBTQ students in American schools and its legal repercussions. The author shows that students who are openly gay or bi, as well as those who […]
The Opinion of Americans on Whether Gay Marriage Should Be Allowed or Not Based on the political nature of the population, 43% of the democrats think, American society supports gay marriages and only 18% of the republicans hold the same view.
Sexuality, Marriage, Gay Rights The supremacy of law and protection of people right lie in the heart of the protection of the freedom of personality.”Part of the basis of democratic government in the United States is a system of […]
Lesbian Motherhood: Identity Issues In the studies of Moore and Hequembourg, the problems of lesbian and black lesbian mothers are explored, while it is pointed out that women of color and those belonging to lower classes appear to be […]
The Gay Community’s Activism Events Research through interviews actually indicates that more than 60% of the population in the United States has come to the recognition and appreciation of their gay counterparts.
”Refugees From Amerika: A Gay Manifesto” Context Review In the 1950s, the West Coast became one of the pulsing centers of the counterculture, heralded in San Francisco by exponents of the Beat generation, including Lawrence Ferlinghetti and Allen Ginsberg, the latter openly gay.
The Debate Over Gay Rights in American Politics Proponents of gay rights vigorously dispute these interpretations, but many people on both sides of the issue do not realize that the Bible has historically been used to argue many things in the past including […]
Democracy: Forms, Requirements and Homosexuality Democracy exists in two major forms there is the liberal democracy which is a very capitalistic economic approach in nature while the other form is a socialist democracy that embraces economic aspects like subsidies and […]
The Seed That Grew: Homosexuality The title “The seed that grew” demonstrate the reality that the seed of homosexuality is planted in an individual and grows as the individual grows.
Societal Attitudes Toward Homosexuality Therefore, people should not be homophobic but should try as much as possible to learn and understand the reasons as they interact with these people.
The Case Against Gay Marriage The Constitutional protection to equal rights under the law has been invoked over and over again to try and afford homosexuals “equal right” to the social institution of marriage and to social security when one […]
Re-Thinking Homosexual Marriage in Rational and Ethical Fashion We demonstrate that the way out of the hysterical debate is to consider soberly the basis for supporting the ordinary family as the basic unit of society and protector of the next generation.
Why Homosexuality Among Females Is Overlooked vs. Males? This leads to the difficulties of gay men in securing work in the military because the focus is mainly on the men.
Parental Rejection Effects on Homosexuals Society needs to come to terms that it has to include the homosexuals among and as one of them and attend to their needs as effectively as for the rest of it.
Historical and Scientific Perspectives on Homosexuality From the context above, it is clear that historical and scientific perspectives on homosexuality contribute immensely to shaping how gay people view themselves.
Gay Marriage and Bible: Differences From Heterosexual Practice When respected the bonds of marriage leads to the good not only of the couple and their children, but also to the good of society as a whole.
Homosexuality and Conversion Therapy In order for conversion to occur in humans, there has to be a mental approach to facilitate the switch. This is attributed to the lack of a clear definition of sexual orientation.
How Views of Homosexuality Have Changed Homosexuality is the attraction and sexual acts performed with people of the same sex, between men and men and women and women.
Heterosexuality, Homosexuality and the Law In this respect the paper deals with the aspect of sociological research on the problem of heterosexuality and a lack of constructive data as for the sociological survey on the issue.
Gay Marriage: Evaluation Argument The basic theme of the article was to present advocacy of gay marriage and a thorough presentation of arguments in favor of the legalization of gay marriages.
Harassment of Young Adults Who Are Gay, Lesbian, Bisexual, Transgender, Questioning According to the professional code of ethics, it is the duty of a social worker to help people in need and with problems.
Homosexuality Aspects in Nazi Germany Dominating such a household would be quite easy for the German authorities because all they had to do was to convert the husband and the rest of the family would follow without question.
Lesbian, Gay, Bisexual, and Transgender Ideation, Correlations With ‘Suicidality’ In addition, experience of verbal ill-treatment and physical assault intensified feeling suicidal for both heterosexual and gay or bisexual men, not just for homosexual men alone as contained in many research findings, and that social […]
Homosexuality: Explanations of Origins and Causes Seen from the perspective of sexual orientation, homosexuality is “a lasting pattern of or inclination to encounter sexual, affectional, or romantic attractions predominantly to people of the same sex; it also relates to an individual’s […]
Homophobia in Social Workers: Gay Affirmative Practice Scale The obvious limitation of the study is the extremely low response rate. The sample size is the key strength of the study.
The Idea of Gay Parenting First of all, there have not been any studies done and proved that children of gay or lesbian parents are disadvantaged in any significant respect relative to children of heterosexual parents.
Transgender in Jewish Religion Transsexual people identify as or desire to live and be accepted as a member of the gender opposite to that assigned at birth.
Being Gay in Canada: Faced Problems and Difficulties It has encouraged immigration of Canada from all corners of the world and the homosexuals are making plans to move to this part of the globe to secure their rights and enjoy their life in […]
Discrimination Against Gays in the Military This information shows that the problem of gay men and lesbian in the military is a part of politics which supports discrimination and inequalities.
Homosexual Stereotypes in Film and TV Homosexuals are feeling more comfortable and open with their sexuality mainly due to the rise of new shows on American television that feature gay individuals and this exposure has resulted in a deep awareness of […]
Ethnography of Homosexuals Analysis According to Wikipedia LGBT is an acronym referring collectively to Lesbian, Gay, Bisexual, and Transgender/Transsexual people and relates to the diversity of gay culture.
Gay Culture’s Influence on Hip Hop Fashion Gay men have the influence of female fashion design due to the fact that most of the designers of female clothes are men and most of them are homosexual.
Feminism: Liberal, Black, Radical, and Lesbian 2 In the 1960s and the 1970s, liberal feminism focused on working women’s issues and the impact of experiences that females of any race could have.
Durable Inequalities in Relation to the LGBT Community in the United States The purpose of this paper is to discuss the phenomenon of durable inequalities with reference to the LGBT community in the US society to understand how four aspects of this concept are reflected in LGBT […]
Ethical Issues of the Transgender Rights One of the most significant burdens transgender people experience is the recognition of their identity. Therefore, to increase the chances for transgender adults’ health care, it is important to pay thorough attention to any signs […]
Growing Up Transgender: Malisa’s Story on NBC News It is essential to develop a better understanding of the concept of gender in relation to children and their development to ensure the protection of the interests of all people and, thus, improve their lives.
Gay Marriage: Societal Suicide While Colson and Morse cannot neglect the need to oppose gay marriage because it destroys human society, the tone, references to the law, and the language chosen for the article help the reader understand the […]
Transgender Bathroom Rights and Legal Reforms One of the themes that deserve discussion is the possibility of creating transgender baths and the rights that can be given to this category of the population.
Anorexia Nervosa (AN) and LGBTQ Suicide Awareness Concerning the format, the design of the poster is good and the words are readable. The colors and contrasts enhance the readability of the content and stress the key points, such as AN indicators, risk […]
Health Care for Transgender Individuals However, the medicalization of transsexualism made it more difficult to receive the treatment as individuals have to prove that they have such problems, and it is not just a temperate state of their mind that […]
The Discovery of the ‘Biological Marker’ of Homosexuality The discovery of the specific biological cause of homosexuality in one sex, but not the other, will most likely result in the following set of effects on people’s understanding of gender, sex and sexuality: The […]
Racism in Lesbians, Gays, Bisexuals, Transgenders Instead of supporting one another as members of a minority group, these people arrange internal arguments within the society of LGBT that leads to the increased feeling of depression and psychological pressure on behalf of […]
Homosexual Relationships: Ethical Reflection That is why it is useless to hope that the discovery of some genomes, which could be taken as the sign that the preferences of these people are the result of physical development, can improve […]
Vladimir Putin’s Government: Controversial Anti-Gay Law The aim of this essay is to analyze the news of the Russian government under Vladimir Putin passing the controversial anti-gay law.
Philosophy: “The Gay Science” by Friedrich Nietzsche Darwin gave the world his famous book On the Origin of Species, in which he tried to trace the genealogy of some species and which made a revolution in the world of science.
Indians in the 19th Century vs. Gay’s Struggle Today The plight of American Indians in 19thcentury The present plight of the gay struggle for acceptance Legislations The Dewes Severalty Act of 1887 was passed on February 8th, 1887, with an intention to allot lands to individuals (Nichols 125). It was perceived that by allocating lands to Native Americans, the government would not have to […]
Open Homosexuals’ Effects on Military Morale Britton and Williams start by noting that when President Clinton announced his intention to lift the ban that restricted homosexuals from participating in the military service, a debate emerged in which the performance of lesbians […]
Gender Studies: Lesbian Sadomasochism She insists critics of sadomasochism only see pain and humiliation yet the people involved consent to it because of the strong connection they feel.
Homosexual Religious and Legal Rights Another recommendation is that the legal structures that govern the issue of homosexuality should be coherent and considerate. Conclusively, it is evident that legal and religious provisions differ remarkably on their stands regarding the matters […]
Sociological Imagination of Homosexuality This is due to the commonality of problems that we may have as members of a given society. I did not know whether the signs I was exhibiting were that of a homosexual or it […]
“An Asian Lesbian’s Struggle” by C. Allyson Lee In the end, the author confesses that she has finally come to terms with herself, and she is proud of being an Asian lesbian.
Gender Issues and Sexuality: Social Perspective and Distinction It is rather interesting to note that society today has such a well-established preconception regarding genders that when presented with alternatives to such established norms the result has been subject to confusion, disdain, at times […]
Children in Gay and Lesbian Couples These techniques of getting children not only provide gay and lesbian couples with an ethical method to have children, but they also provide them with a chance to raise children for the donors.
Homosexuals and Their Personal Culture Unique culture generally refers to a set of beliefs, values, or generally the way of life of an individual irrespective of the way of life of people in the larger society.
Gay and Lesbian Adoption Issues The end of the 20th and the beginning of the 21st century are prominent in the evolution and empowerment of the LGBTQ movement.
The Problem of Discrimination Against the LGBT Community Subsequent stages of work in this direction can include the following steps: Making a presentation on the topic of the equality of people regardless of their religious, racial, and sexual background.
Cancer Screening in Lesbians, Gays, Transgenders Moreover, one of the diseases that are the burden of American society as a whole and the LGBT population, in particular, is cancer.
Homosexuality in “Laura” and “Brokeback Mountain” 1 It may seem that the representation of Waldo embodies the features of sexual perversion and decadence, as expressed by the sexual intercourse of the young men with the older man along with the unusual […]
Gay Society and Challenges in “Gay” by Anna Quindlen
Transgender Issues in Modern Society
Lesbian, Gay, Bisexual, Transgender at Life Stages
Transgender Bathroom Rights and Needed Policy
Women in Sports: Policy for Transgender Players
Women and Homosexuality in “Pariah” by Dee Rees
Gay Marriage and Its Social Acceptance in the US
LGBT Literature: “The Picture of Dorian Gray”
Transgender People in the USA
Transgender Inclusivity in Higher Education
Homosexuality in Natural Law Theory
Amy Zimmerman: It Ain’t Easy Being Bisexual on TV
British vs. Japanese Homosexuality Criminal Laws
Homosexuals and Heterosexual Brain Structure Differences
Age Bias, Disability, Gay Rights in the Workplace
Sexual Strangers: LGBT Politics in United States
United States v. Windsor – Homosexual Rights
Homosexual Marriage: Causes of Debates
Parenting: Learning That an Adolescent Is Gay or Lesbian
Challenges for Educators: Lesbian, Gay, and Bisexual Families
LGBTQ Issues in Korean Film Industry
Korean LGBTQ Films: The King and the Clown and Hello My Love
Homosexual Discrimination in Our Society: Causes and Effects
Homosexual Students and Bullying
Gay Judge’s Ruling Should Be Thrown Out
Homosexuality Issues in the Film “Milk” by Van Sant
Gay and Lesbian Relationships’ Nature
Legalizing Gay Marriage in the US
The Evolution of the LGBT Rights
Xaniths as a Transgender in Omani Culture
Queer Activism Influences on the Social Development of LGBT
“Gay Marriages” by Michael Nava and Robert Dawidoff
Dating Sites: Gay Latino Men and Women in Los Angeles
Globalization and Gay Tourism: Learning to Be Tolerant
Gay Marriage’s Social and Religious Debates
Members of the LGBT Community
Gay Marriage in The UK
Is homosexuality an Innate or an Acquired Trait?
Gay Marriage: Debating the Ethics, Religion, and Culture Analytical
Homosexuality, Religion and Atheism
Why Homosexuality Should Be Illegal
Homosexuals’ Right to Marry
Lesbian, Gay, Bisexual, and Transgendered Labor and Employment Issues
LGBT Labor and Employment Issues
Transgender Students on Colleges: Needs and Challenges
Lesbian, Gay, Bisexual and Transgender Sexuality in the Hispanic Culture
Transgender Issues in “The Crying Game” and “M. Butterfly”
Problems Experienced by Children of Homosexual Parents
Gay Marriages and US Constitution
The Issue of Gay Marriages: Meaning, Importance and Cons
Views of Young Australian and Chinese Adults on Homosexuality
Legalizing Gay Marriage
The Article “Against Gay Marriage” by William J. Bennett
Gay Marriage, Same-Sex Parenting, And America’s Children
Homosexuality Criticism Rates
Clinton Homosexual Discrimination Policy
Gay Couples’ Right to Marriage
Discrimination, Social Exclusion and Violence among the LGBT Community
Homosexuality: Why only some intimacies are labeled as homosexuality
Defending Gay Marriage
Relation of Gay Marriage to the Definition of Marriage
Setting the Parameters for Regarding Homosexuality: To Whose Doors Should One Lay the Blame To?
“The New Gay Teenager” by Ritch Savin Williams
Concepts of Gay Marriage
Gay Marriage: Culture, Religion, and Society
Homosexuality in the Contemporary Society
Gay Marriages in New York
Suicides Among Male Teen Homosexuals: Harassment, Shame or Stigma?
The Homosexual Lifestyle Issues
Why Gay Marriages Should Not Be Legalized?
Gay Marriage as a Civil Rights Issue
Gay Marriage and Parenting
Should Gay Marriages Be Allowed?
Gender Studies: Gay Rights
Gay Couples Should Not to Marry
Arguments for and against Homosexuality: A Civil rights & Liberties Perspective
Gays in the Military
Reasons of the High Homosexual Marriage Rate
BEAR Magazine: Lifestyle Entertainment for Gay Men
Gay Marriage and Decision Massachusetts Supreme Judicial Court
Gay Denied their ‘Rights’ in Australia
Arguments for Gay Marriages
Position of the Christian Church on Homosexuality
Gender Studies: Gays and Lesbians Issues in 1940’s and 1950’s
Young Opinion on Homosexuality
Should Homosexuality be Legalized?
Gay Marriages: Why Not Legalize Them?
Should We Allow Gay Marriages as Civil Unions?
Castro Gay Village’ Gentrification in San Francisco
Media and Homosexuality
Adopted Children With Gay Parents Have Better Chances of Succeeding
Must gay marriage to be legal?
Should Homosexuals be Allowed to Legally Marry?
Gay Marriage in the U.S.
A Critical Evaluation of Historical & Scientific Standpoints on Homosexuality
Gay marriage and homosexuality
Social Justice and Gay Rights
Gay Marriage Legalization
Gay in the Military
What Does LGBT Mean?
How LGBT Live in Russia?
Why Should the LGBT Community Serve Openly?
How LGBT Live in India?
How Can I Be More Inclusive With LGBT?
Are LGBT People Discriminated Against in the Hiring Process?
Why Should the LGBT Community Have Equal Rights?
What Were Cracker Barrels’ Reasons for Firing Their LGBT Employees?
How Does LGBT Culture Fall in Our Society Today?
How Happy Could LGBT People Be in a Homophobic Society Such as Ours?
Why LGBT Color Is Rainbow?
Why LGBT Teachers May Make Exceptional School Leaders?
How Does Stress Affect the LGBT Community?
Why Are LGBT Students Committing Suicide More Than Non?
Does LGBT Inclusion Promote National Innovative Capacity?
How Can I Be Kind to LGBT?
Are LGBT People Born This Way?
Does LGBT Marriage Threaten the Family?
How Are LGBT People Represented on TV?
How Virginia Woolf’s Orlando Subverted Censorship and Revolutionized the Politics of LGBT Love in 1928?
What Are the Different Flags for LGBT?
How LGBT Live in the USA?
How Successful Are LGBT People Straight Alliances?
Are You Born LGBT Person?
Were There LGBT Subcultures From the 1900s to the 1960s?
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213 LGBTQ Research Topics & Title Ideas for Essays

The LGBTQ community has progressed in winning equal rights but still faces significant discrimination, and specific LGBT issues remain unresolved. If interested in this subject, look at our LGBTQ title ideas. You’ll find a list of LGBTQ research topics for your inspiration – feel free to use them for your debate, persuasive papers, and other assignments.

🌈 7 LGBTQ Research Topics – 2024

🏆 best lgbt essay topics, ❓ lgbt research questions, 👍 good lgbt research topics & essay examples, 📝 lgbt argumentative essay topics, 🌶️ catchy lgbtq title ideas for essays, 🎓 most interesting lgbtq topics to write about, 💡 simple lgbt topics for research papers, 🔥 hot lgbtq research paper topics.

Theories of Deviant Behavior: Homosexuality
The LGBT Community Theoretical Framework
Gay Marriage and Ethical Theories
Transgender Women in Sports
Cultural Satire in John Gay’s Beggar’s Opera
Conflict Theories: Gay Marriages and Feminism
Should Gay and Lesbian Couples Be Allowed to Adopt?
Argument Against LGBTQ Discrimination LGBTQ discrimination is the unfair treatment of people who identify themselves as lesbian, gay, bisexual, transgender, or queer.
Gay and Single-Parent Families: Functionalist View The application of the functionalist perspective helps to resolve some problems by outlining the importance of issues and their contribution to the evolution of communities.
Gay Marriage Should not be Legal Due to media popularization of gay rights, opposition of gay rights to marriage is normally equated to intolerance.
Homosexual and Heterosexual Families Are the Same Opponents of homosexual parenting advance the argument that children cared for by gay or lesbian partners do not fare as well as those brought up by heterosexual parents.
The Issues of Gay Parents Scholars have noted a few differences in the characters of children brought up in same sex- marriages and those brought up in conventional ones.
The Portrayal of the LGBTQ+ Population in the Media Many scholars have investigated the portrayal of the LGBTQ+ population in the media, noting that it does not always reflect reality.
Barriers to LGBT Health Care Access and Effective Nursing Interventions Globalization and cooperation are significant factors contributing to the advent of a wave of sexual and identity orientation.
Homosexuality as a Problem in the Conflict Theory The term “sexual behavior” encompasses various actions that people engage in to show their sexuality. Sexual arousal is a part of these behaviors’ biological and cultural aspects.
Healthcare Disparities in the LGBT Community Apart from the disparities representatives of the LGBT community face in everyday life, they also deal with some major challenges as to their access to appropriate health care services.
For and Against of Gay Marriage Same-sex marriages is a union that takes place between two people who belong to the same social gender or similar biological sex.
Gay and Lesbian Adoption: Normalizing a Healthy Childhood This research paper will examine the legal framework of same-sex adoption in the US and Europe, review its socioeconomic, health-related and psychological implications.
Mental Health Disparities Among LGBT Community LGBT people are at higher risk of suicide, anxiety, substance abuse, and eating disorders. LGBT people are 2 to 3 times more likely to attempt suicide.
Transgender People and Healthcare Barriers This essay aims to explain the barriers that prevent transgender people from receiving quality care and suggest improvements that can be implemented in current medical institutions.
Transgender Issues in Cis- and Trans-Made Movies This paper discusses the implications of transgender and transsexual experience from the outside and from within, particularly how they are represented and how the public sees it.
Challenges of Transgender Patients Transgender patients have to face a certain amount of resistance and discrimination in society regularly, this group of people has to deal with certain challenges in the health care arena.
Ethical Relativism Regarding Queer (LGBTQ+) Community Ethical relativism does not always support tolerance toward minorities, such as the LGBTQ+ community, since it depends on the either personal or societal approach.
The Gay and Lesbian Rights Movement of the 1960s The purpose of this paper is to discuss the gay and lesbian rights movement of the 1960s and indicate its incredible importance.
Transgender Offenders in the Criminal Justice System The transgender population who are incarcerated often faces various unique challenges which expose them to vulnerabilities both physical and mental.
The Reluctance of Gay, Lesbian Victims to Report Domestic Violence Members of the gay community suffer from domestic violence in almost the same magnitude as members of the heterosexual community.
‘Why Shouldn’t Tommy and Jim Have Sex?’ by J. Corvino: Defense of Homosexuality The article written by John Corvino is a short series of paragraphs defending homosexual relationships. The reason is through an abstract example, which is two men, Tommy and Jim.
Transgender Women Athletes in Professional Sports The inclusivity and legal recognition suggest that transgender athletes are welcome to participate in competitive sport given they meet the established requirements.
The Perspective on Homosexuality The paper states that the perspective on homosexuality has been skewed by the presence of biases and the lack of tolerance among the general population.
Family Therapy Related to a Child’s Homosexuality This case study focuses on a 16-year-old African American male who disclosed his homosexuality to his parents, who are religious people and do not accept their son’s sexuality.
Transgender Prisoners and How They Are Treated According to international studies, transgender persons are a particularly defenseless population in the correctional structure, with their most necessities often being withheld.
Transgender Support Group Meeting and Its Importance The transgender support groups allow people to connect and talk about issues that they have faced in their lives.
Critical Thinking and Transgender Ethics Sexual orientation and preference is a debated and complex topic involving biological aspects, including hormones, which can alter and change people’s behavior and feelings.
Media Representation of Gay and Lesbian Parented It is alleged that the media often fails to represent the normal privacy and individuality of a heterosexual family.
Should Homosexuals Have Children? One of the controversies on homosexuality includes the debate on whether same sex couples should be allowed to adopt children or acquire a family.
Transgender Children’s Issues in Society The topic of transgender children in society proves to be divisive and is widely discussed by parents, teachers, clinicians, and politicians.
Gay-Friendly High Schools in Chicago Chicago officials have advocated for the creation of “gay-friendly high schools” for students who feel that schooling with pro-heterosexual students threats their safety.
Capitalism and Gay Identity by D’Emilio and Berube In this paper, the author will review the link between gay identity and capitalism from the perspective of two essays written by D’Emilio and Berube.
How to Get Others to Be More Open-Minded About LGBT People?
Which Iconic LGBT TV Character Are You Most Like?
How to Respond to Homophobic and Transphobic Attitudes Against LGBT People?
How to Respond to Rumors That Someone Is LGBT?
Does Bumble Work for LGBT?
How to Help LGBT Colleagues?
How to Respond to Heterosexual Friends or Coworkers Who Feel Negatively About a Person Who Is LGBT People?
What Should Say to Someone Who Is Afraid of Contracting HIV or Aids From LGBT People?
Are LGBT People More at Risk From COVID-19?
What Is the Difference Between Bisexual and Transgender LGBT People?
What Is the Nature of Same-Sex Relationships in an LGBT Family?
How Do People Know if They Are LGBT?
How Can I Tell if Someone I Know Is LGBT?
Why Should Healthcare Professionals Consider LGBT Communities?
Can LGBT People Change Their Sexual Orientation?
How to Respond to People Who Object to LGBT People for Religious Reasons?
What Is the Connection Between Bullying and LGBT Youth?
How to Respond When Someone Tells a Homophobic Joke Against LGBT People?
Why Are People LGBT?
How to Make Your Work More LGBT Friendly?
How to Become an LGBT Ally 2022?
Can LGBT People Be Good Parents?
Why Is It Important to Celebrate LGBT?
How Can I Become Myself More Approachable to People Who Are LGBT People?
“The Construction of Homosexuality” a Book by David Greenberg The book, The Construction of Homosexuality by David Greenberg presents the reflection of the author on historical timeline of the struggle by homosexuals to get their rights.
Policies Addressing LGBT (Queer) Healthcare Disparities The paper states that despite the continuous growth of the LGBT community across the globe, they continue to face challenges within the healthcare system.
Impact of Sociocultural Factors on the Development of the LGBTQ Identity LGBTQ identity is influenced by different sources, family, peers, culture, and community all play their roles in identity development.
The Fight for $15 Movement vs. the Transgender Law Center For an examination of non-profit organizations, it will be convenient to use case studies. The Fight for $15 movement and the Transgender Law Center will be used as comparisons.
LGBTQ (Queer) in English Language Learning Classrooms This study addresses the issue of the LGBTQ community’s underrepresentation in English language learning classrooms and in the curriculum.
The LGBTQ (Queer) Identity Development The purpose of this paper is to evaluate factors that impact the development of the LGBTQ identity from the position of sociocultural theory.
Underrepresentation of the LGBTQ (Queer) Community in English Language Teaching As the dominant culture becomes more and more accepting, the number of LGBTQ individuals who uncover their identity is growing.
Health Disparities of Transgender Population The problem is centered around the healthcare inequality experienced by members of the transgender community, where the barriers include financial factors and discrimination.
Clinically and Culturally Competent Care for Transgender and Non-Binary People The analyzed review can be considered an essential step toward a better understanding of how to work with such groups.
Transgender People in the Olympic Games The new guidelines state that transgender athletes may be permitted to compete in the Olympics without undergoing sex reassignment surgery.
Violence in LGBT (Queer) Couples Violence in LGBT couples is a serious societal problem that can affect the well-being of many citizens. Suicide risk factors are much more common within the LGBT community.
Disparity Accessing Health Care Services in LGBTQ+ Adopting legislative changes to enhance the lives of LGBTQ teens is the primary health strategy, including health policies and curriculum changes.
The Effects of Discrimination That LGBT Persons Encounter The paper focuses on the effects of discrimination that LGBT persons encounter. They never interfere with the lives of people who do not relate to the LGBT community.
Transgender People in Prisons: Rights Violations There are many instances of how transgender rights are violated in jails: from misgendering from the staff and other prisoners to isolation and refusal to provide healthcare.
Recognition of Human Rights for LGBT Individuals The paper discusses the importance of studying the issue of LGBTQ people discrimination, including its causes, harmful effects, and current state.
Parenting Peculiarities in Queer (LGBT) Families An examination of LGBT marriages has shown that same-sex partners have varied parenting desires, intentions, and child-rearing experiences.
Aspects of LGBTQ+ Community Values Acceptance and striving for equality represent the main features of the LGBTQ+ community. Acceptance provides the unifying kernel for marginalized strugglers.
Resolving Discrimination Against Queer (LGBTQ) Community The article focuses on practical measures that can be governed to ensure that LGBTQ people are not discriminated against and violated.
The Lesbian Family Impact on Canadian Society In this paper, an attempt will be made to explain the advantages of a lesbian family and the potential benefits for Canadian society.
Transgender People: Prejudice and Discrimination Transgender remains a stereotyped sexual identity, and these individuals face prejudice from critics, religious leaders, and the vast majority of society.
Transgender Health Disparities and Solutions People who identify as transgender, intersex, gender non-conforming, or gender diverse have exacerbated health disparities compared to other people.
Florida’s Bill ”Don’t Say Gay” The “Don’t Say Gay” bill should not be published because it will put the mental and physical well-being of LGBTQ+ students in danger and normalize censorship in the classroom.
Cause and Effect of Queer (LGBTQ+) Discrimination The LGBTQ+ community has continued to experience discrimination in various settings. The results of these factors include social segregation, unemployment, etc.
Discussion of LGBT Discrimination in Modern Society Despite the fact that most states of the world and humanity as a whole are actively fighting to protect the rights of the LGBT community, discrimination is still relevant.
Queer (LGBT) Hiring Policy’s Purpose and Authority Organizational consulting specialists (policy-makers) try to implement a new hiring policy regarding the LGBT population in the administrative processes of company performance.
Gay Marriage Redefines the True Meaning of Family This literature review aims to illustrate how the legalization of gay marriage helped redefine the meaning of family and argues that it transformed the social role of the unit.
Changes in Perception on Same-Sex Marriage and LGBTQ+ People The paper states that acceptance of the LGBT community and marriage between people of the same sex is gradually beginning to appear in modern society.
Mental Healthcare Services for Transgender Individuals This research paper suggests a range of options to treat mental health and related illnesses among the non-binary populations.
Queer (LGBTQ) Community as a Social Problem in Canada The Canadian government has shown interest in LGBTQ matters in recent years. Canadian queer persons are more likely to be victims of violent crime.
Media Coverage of Transgender Policy in Military This paper aims to provide an annotated bibliography for the ten articles related to the topic of media coverage of transgender policy in the military.
Homosexuality: History and Theoretical Perspective This paper will discuss the history of homosexuality from the perspective of three theoretical lenses. The first theory to review homosexuality is structural functionalism.
Is same-sex marriage morally acceptable?
Should same-sex parenting be legal?
Should transgender conversion therapy be banned?
LGBT media portrayals are vital for normalizing diverse relationships.
Should schools introduce gender-neutral bathrooms?
Should school anti-bullying policies specifically address homophobia and transphobia?
Are LGBT pride parades effective in raising awareness and advocating equal rights?
Should schools develop policies to accommodate students’ preferred pronouns?
Should countries grant asylum to people persecuted for their sexual orientation?
Can businesses turn LGBT individuals away because of religious beliefs?
The Problem of Violence Against LGBTQ People: Critical Analysis The perspective on psychological problems is most relevant to LGBTQ problems, as their psychological health is typically influenced by society and culture rather than genetics.
Homosexuality Perceptions in Mexican Culture The paper identifies the societal reactions and perceptions of homosexuality in Mexican culture and analyzes the social position of homosexual people.
Transgender Movement: Overview and Importance Ultimately, policies, guidelines, or steps ensure that the social change that the transgender movement is yearning for can be realized.
Is Being Homosexual a Choice or Inherent? The current essay discusses various perspectives to answer the question of whether homosexuality is a choice or inherent.
Global LGBTQ Health and Health Issues Although there has been rapid progress in the inclusion of LGBTQ people, they continue to face many health disparities, hence their poor health outcomes across the world.
Transgender Health Care in the USA: Then and Now The change of physical appearance or function through clothing, medical, surgical, or other means often becomes part of the personal gender experience of a transgender person.
Suicide Risk Factors in Queer (LGBTQ) Community Stigma and prejudice about a particular group of people may cause adverse consequences for their health and overall quality of life.
Cultural Immersion Project: Interview with Lesbian The principal challenge of the interviewee’s daily routine is the lack of acceptance by her colleague, which is not directly expressed but still evident.
Analysis of LGBT Integration in Military The study examines integrating LGBT people into the army and identified the main points that influenced the formation of acceptance of gays, lesbians, and transsexuals.
Why We Shouldn’t Compare Transracial and Transgender Identities To compare transracial identity with transgender identity is to reduce both to a set of immutable rules, be it rules of biology or society – and this is a very wrong approach.
Suicide Prevention in Teen Gays After They Come Out This proposal will recommend appropriate ways of rescuing LGBT youths from toxic environments that drive them to depression and commit suicide.
LGBT Populations and Health When addressing the health issues where minorities are involved, the LGBT population has been neglected in more than one instance.
Conflict Between Transgender Theory, Ethics, and Scientific Community This essay aims to give answers to questions of ethics within the transgender topic and research fraud based on scholarly articles and presentations by Dr. Q Van Meter.
The Gay Marriage: Legal Arguments For and Against The Constitution not only legitimizes gay marriage but implies that the government should never have considered a ban and should instead actively pursue legalizing gay marriage.
Affordable Care Act for LGBTQ Populations The paper will provide a detailed description of the Affordable Care Act, indicate its supporting and opposing aspects, and analyze its impact on LGBTQ populations.
The Problem of Lesbian, Gay, Bisexual and Transgender Youth Suicidality Recently, there was a sharp increase in cases of suicides committed by lesbian, gay, bisexual, transgender, and queer youth.
Lesbian, Gay, Bisexual, Transgender Activism This paper aims at exploring the background of LGBTQ activism, the oppression that its members experience, the measures they take, and the opposition that hinders their progress.
Transgender Care: Challenges, Implications In a healthcare setting not putting effort into ensuring diverse patient groups are treated with professional finesse with no regard for their differences is a timely issue.
Lesbian, Gay and Bisexual People and Primary Healthcare Services The researchers argue that patient reticence about disclosing their homosexuality elevates the risk of incomplete histories being taken.
Should Gay Marriage Rights Be a State or Federal Law? If the issue of same-sex marriage is left to the states, some of them would probably recognize it, while others would not.
Incorrect Interpretation: Everyone Is Gay on Tiktok The article’s main idea is that becoming pseudo gay — when close bodily contact, kisses, and hugs are shown only on video — is hugely beneficial to increase own popularity.
Gay Marriage: Support of the Legalization Gay marriage remains a controversial topic of public debate and discussion that is often rooted in religious beliefs and various definitions of marriage.
Arrest Histories of High-Risk Gay and Bisexual Men in Miami: Article Analysis Arrest history was closely connected to many aspects of the syndemic theory of gay/bisexual men’s health disparities.
Religious Liberties and LGBTQ Employment Discrimination Reforms The biggest resistance to LGBTQ rights has been religion, with members of society who disapprove of homosexuality.
Hate Crimes Against Homosexuals in American Colleges Although hate crime is a setback for many students in college and universities, individuals LGBT are more likely to be exposed to a particularly difficult path.
Reproductive Health Care and the LGBTQ Community The purpose of this paper is to outline the competent treatment for those LGBTQ who are seeking reproductive care.
Trump Administration and Transgender Discrimination The paper reviews one of the recent issues that caught the public eye and media attention is the Trump administration’s treatment of transgender people’s healthcare rights.
Social Prejudice Kills LGBTQ Community Representatives Society must change its attitude and liquidate prejudice among the LGBTQ community members, as the consequences of these attitudes are disastrous.
Canadian LGBT Progress Overview and Analysis The LGBT progress in Canada is particularly relevant to Canadian Studies. One of the primary issues of these studies is exploring the matters of identity.
Don’t Ask, Don’t Tell: Gays in the Us Military Homosexuals in the military have always had to hide their sexual orientation to prevent discrimination, incrimination, or even discharge from service.
LGBT Minority in Higher Education This paper has, as its main objective, the need to show that in contemporary American society, the LGBT minority has witnessed increased attention.
Gays in the Military: Current Situation and Problems While much effort is being put in to allow the marriage of persons of the same sex, this has not affected the military, since homosexuals are barred from taking up in the military.
Homosexual Rights on a Historical Timeline Homosexuals are people, they have rights and should be able to live without discrimination and prejudice. Heterosexuals or homosexuals should be treated with respect as equals.
Gay Rights and ACT UP Struggle ACT UP struggle shows that gay men deprived human rights and have to fight against oppression and discrimination so they should be protected by the state from negative social image.
Gay and Poverty Marriage The institution of family and the issues of marriage play a crucial role in society today. Marriage status determines relations between spouses and their relations with the state.
The Issue of the Gay-Marriage Movement in the United States Gay people should have the right to marry because constitution is aimed to protect social and sexual rights of all people and all citizens of the USA.
Gay Marriages in the Media: Different Opinions About the Question Gay marriages are rather common affairs in modern world. Many countries began to think about legalization of same-sex marriages.
Gay Marriages Legalization: Arguments Against Proponents of same-sex marriages argue that legalization would grant same-sex marriages equal rights and benefits with heterosexual marriages.
Controversy on Gay Marriage in the U.S. The paper explores the question of the legalization of gay marriage and provides arguments on the positive sides of that for American society.
Gay and Lesbian Literature in the United States The paper is dedicated to the problem of gay and lesbian discrimination within the communities of people living in different countries.
Gay Marriages Legality Discussion Gay marriage is a union that is characterized by the joining together between spouses of similar sex and which is acknowledged legally like the vows of a conventional marriage.
Gender Non-Conforming or Transgender Children Care The purpose of this paper is to discuss the challenges to be aware of when working with gender non-conforming or transgender children and adolescents.
Transgender People’s Challenges Within Healthcare This paper aims to discuss the challenges in healthcare that the transgender community faces and how the challenges affect their overall health outcome.
Transgender Care by Healthcare Professionals Transgender patients require healthcare professionals who are conversant with their experiences and who can treat them with utmost respect and dignity.
Health Problems of the LGBT Community in the United States It is possible to state with certainty that the health problems of the LGBT community in the United States are various.
HIV Among Caucasian, African American, and Latino Homosexual Men Creating awareness at the community level would play a significant role in reducing the number of new HIV infections among Caucasian, African American, and Latino homosexual men.
Managing the Problem of HIV Among Gay Men at the Community Level Since there are noticeable disparities in the degree of HIV contraction among gay men belonging to different ethnicities, a detailed analysis of the factors to which the vulnerable groups are exposed must be due.
Transgender Bias in News Coverage In the context of increasing LGBTQ activism and recognition, transgenderism faces the greatest controversy and public backlash.
The Issue of Transgender Discrimination Despite numerous attempts to eliminate biased attitude, transgender people still face different challenges that deteriorate results of treatment.
Gay Community and Heterosexism in Language When speaking of gay people, they were often referred to as homosexual in the past. “Gay” is probably the only identity label that gay individuals reclaimed these days.
Transgender Community and Heterosexism in Language The term “transgender” became commonly used only by the end of the 20th century. Not all transgenders commenced using this and preferred to pass as a different gender.
Media Shapes History: Gay Liberation Movement By the late 20th and early 21st centuries, the portrayal of gay and queer folk in the US had vastly improved. This, in turn, had a positive effect on the Gay Liberation Movement.
Economic Justice: LGBTQ Individuals Economic justice cannot be achieved by using force. Until we learn to understand and accept LGBT people, no punishments of their offenders can secure their economic position.
Homosexuality and Adolescence Development This report discusses issues related to transgender disorders and homosexuality and considers social, cognitive, and physical development in adolescence.
Healthcare System: Transgender Patients Discrimination According to the statistics, almost 1 million Americans identifies themselves as transgender, making it a numerous population subgroup that is likely to expand in the future.
Transgender Patients Problem and the Consequences of Discrimination Transgender patients come across different forms of harassment and do not have the same access to services as other people do.
Homosexuality as Percieved in American Society This paper will examine the independent variables of religious affiliation, race, and gender that have an impact on the attitude towards same-sex marriage in the US.
Transgender and Gender Non-Conforming Children This paper discusses the issues a psychiatric mental health nurse practitioner should be aware of when interacting with transgender and gender non-conforming children and adolescents.
Homosexuality as a Genetic Characteristic The debate about whether homosexuality is an inherent or social parameter can be deemed as one of the most thoroughly discussed issues in the contemporary society.
Transgender Patients and Health Care Challenges One of the challenges encountered by transgender patients refers to the lack of adequate access to healthcare services.
Transgender Care and Health Care Professionals Despite the adoption of policies aimed at limiting discrimination, transgender people still face daily challenges in the aspects of employment, education, and healthcare access.
Transgender Healthcare Barriers in the United States This paper examines central barriers to high-quality health care and includes practices employed to address the issue and some recommendations.
The Spreading of HIV Across the Gay Men A thorough study of the age distribution of the HIV-positive gay men population would be the first step to determining an effective prevention strategy.
LGBT Healthcare Disparity: Theoretical Framework The paper prepares research on LGBT (lesbian, gay, bisexual, and transgender) healthcare disparities and presents a literature review and theoretical framework.
LGBT Community Portrayals in Traditional News The research identifies how the LGBT community is portrayed by traditional news and finds out if any signs of discrimination or unfair treatment are demonstrated.
Reducing HIV Amongst Gay and Bisexual Men in Florida There are many misconceptions regarding the passage of HIV among men with different sexual preferences.
Transgender Patients: Challenges & Discrimination in Healthcare It is worth noting that the concept of transgenderism implies a state of internal imbalance between the real and desired gender of an individual.
Healthcare Challenges of Transgender Patients Transgender individuals have health problems common for the whole population and frequently face challenges in healthcare settings related to inadequate healthcare.
Marriage Equality: LGBT Couples’ Constitutional Issues This essay explores the constitutional issue of marriage equality for married same-sex partners that still face discrimination, as shows the example of the case of Pavan v. Smith.
Lesbian and Gay Patients’ Medical Care and Education If all the specialists work jointly, there will be a chance to reduce the indicators of the infection and achieve positive results in fighting against HIV among gay men.
LGBT Rights in Canada Canada’s progress toward legal equality of LGBT community testifies to the deep belief of its citizens in the fundamental values of democracy and freedom.
Transgender Patients and Challenges in Health Care The community remains predominantly marginalized, with policies and laws denying them recognition of their gender, making accessing health care very challenging.
Lesbian, Gay, Bisexual, Transgender Patients’ Therapy The current quality of managing the needs of the representatives of the LGBT community needs a significant improvement.
LGBT Community in Chicago Chicago is considered to be a major center for the LGBT community. The city has a long history of the movement, dating back to the early 1920s.
Transgender Patients and Nursing Health Management There is a growing recognition today among health care providers and researchers that patients’ transgenderism may become a factor in their care.
Lesbian, Gay, Bisexual, Transgender in Hospital The paper discusses the cultural competency concept since it appears to be of critical importance for the profound understanding of the problems of the LGBT community.
Challenges to Transgender Patients Despite the recent attention to the issues of transgender people, the level of discrimination against them is still incredibly high.
Discrimination Faced by Transgender Patients Contemporary hospitals are not designed for transgender people, therefore, they can have many troubles there ranging from the unfriendly environment of a hospital and doctors.
Transgender-Associated Stigma in Healthcare Transgender individuals are people who assume a gender definition of identity that differs from gender assigned to them at birth.
Transgender Disorders and Homosexuality There is a lot of evidence of both the genetic mechanisms’ and surroundings’ influence on people’s sexual preferences. However, the environment is more responsible for such choice.
Epidemics of HIV in Gay Men Given that epidemics of HIV in gay men are on the rise in most countries, it is essential to diagnose the disease early.
The Problem of Addressing HIV in Gay Populations The challenges are presented by men’s unawareness of their infection, discrimination and stigma problem, and undiagnosed sexually transmitted diseases.
Transgender and Problems with Healthcare Services Transgender individuals find it difficult to approach physicians because it is difficult for them to reach needed treatment.
Transgender People in Healthcare Facilities Gender nonconforming and transgender people face discrimination in almost every sphere of human activity. It has a negative impact on the access of these groups to primary care.
Transgender, Its History and Development Transgender is not a new concept and people have discussed the issues associated with it since the 19th century.
Healthcare Needs of the LGBT Community Pinning down how long the problem of meeting LGBT members’ healthcare needs has been around is rather problematic because of the social controversy around the subject matter.
Problems of Transgender Patients in Health Care A number of transgender patients admit cases of discrimination from the health care workers. From 30% to 60% of the representatives of this group face biased attitude.
Transgender Discrimination in Health Care This paper investigates the discrimination that transgender persons are subjected to in the health care setting in more detail.
Successful Struggle of Canadian LGBT Community The Canadian LGBT community has managed to achieve its ultimate goal: official recognition of their rights, including the right to legal marriage in 2005.
Transgender Community’s Treatment in Healthcare This paper discusses the transgender community and the discrimination that affects them every day, especially in healthcare, and how we can help stop it.
The Health Problems that LGBT People Face Health Policy and Advocacy is a core nursing essential that most pertain to the issue of LGBTQ health promotion. The essential’s rationale is to advance social justice values.
Sidesteps Broad Gay Marriage Ruling The article, “Sidesteps Broad Gay Marriage Ruling,” by Peralta Eyder, explores the controversial 2013 ruling against the Defense of Marriage Act (DOMA) by the US Supreme Court.
Addressing HIV Prevalence among Gay Men This discussion outlines the strategic measures at the community level to address increased prevalence of HIV cases among Caucasian, African American and Latino gay men.
The Gay Human Rights: Harvey Milk Contributions Harvey Milk and his contribution in the struggle to preserve gay human rights are discussed from a theoretical perspective. This paper provides an in-depth understanding of gay human rights.
Morals Metaphysics: Criminal Punishment and Gay Basics It is not wrong to punish a criminal primarily as a means to reform the criminal. Execution is not the only just penalty for murder as two wrongs do not make a right.
Homosexuality From a Christian Point of View In the Old Testament, every person knew that homosexuality was an abominable sin, hated and disgusting even to mention.
Homosexuality in Canada Homosexuality can be explained in three main dimensions: biological, behavioral and psychodynamic dimensions of homosexual orientations.
Supreme Court Justice: Homosexual Marriages The question of homosexual relations and untraditional marriages remains to be open for a long period of time. It is hard to make all people choose the same position and stick to it all the time.
Relationships: Different Views on Gay Marriage Gay marriage is a topical issue caused by different perceptions and understanding of human nature and interpersonal relations. The approaches towards gay marriage are liberal and conservative.
The effects of coming out experiences on LGBT people’s mental well-being.
The root causes of LGBTQ youth homelessness.
The role of social media in LGBTQ activism.
LGBT parents’ experiences when seeking healthcare for their children.
Unique challenges of providing care for LGBT older adults.
The impact of conversion therapy on mental health.
Suicide risk in LGBT adolescents and protective factors.
Patterns of LGBT hate crimes and prevention strategies.
Queer art as the intersection of creativity and social activism.
The importance of parental support for LGBTQ individuals.

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This essay topic collection was updated on January 21, 2024 .

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LGBTQ Rights: An Argumentative Landscape

Table of contents, understanding lgbtq rights and discrimination, the argument for lgbtq adoption rights, transgender rights and public spaces, conclusion: navigating a complex dialogue, works cited:.

Human Rights Campaign. "LGBTQ Youth Homelessness." Human Rights Campaign , www.hrc.org/issues/youth-homelessness. Accessed 15 Aug. 2023.
Obergefell v. Hodges, 576 U.S. 644 (2015).
Williams Institute. "LGBTQ Parenting in the United States." UCLA School of Law , williamsinstitute.law.ucla.edu/publications/parenting-lgbt. Accessed 15 Aug. 2023.
GLAAD. "Transgender FAQ." GLAAD , www.glaad.org/transgender/transfaq. Accessed 15 Aug. 2023.

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How Are LGBT Youths Affected by Discrimination and What Can Schools Do to Help?

This essay shows how discrimination leads to increased high school drop out rates for LGBT youths and, of greater concern, increased rates of suicide and substance abuse.

Gaell Jocelyn-Blackman

In this paper, I will discuss the different types of discrimination that LGBT youths are faced with and the effects on these youths. The paper will elaborate on the severe impacts on LGBT youths not only caused by discrimination but also due to lack of support and guidance. The paper will also discuss the roles of the parents and schools in helping minimize discrimination against LGBT youths. This paper will also hopefully instruct schools and parents to accept and support gay students rather than add to the discrimination that they already face. Doing so will reduce the high school drop out rate and most importantly the youth suicide rate. In essence, the purpose of this research paper is to identify the different effects on LGBT youths due to discrimination and to explore various actions that can and should be taken by schools and parents to help these youths live a normal and happy life. Therefore, my target audience is the school system as well as the parents of LGBT youths.

Suicide is the leading cause of death among gay and lesbian youths. Gay and lesbian youths are 2 to 6 times more likely to attempt suicide than heterosexual youth. Over 30% of all reported teen suicides each year are committed by gay and lesbian youths. . . . Gays and lesbians are at much higher risk than the heterosexual population for alcohol and drug abuse. Approximately 30% of both the lesbian and gay male populations have problems with alcohol. Gay and lesbian youth are at greater risk for school failure than heterosexual children. (U.S. Department of Health and Human Services, 1989, as cited in “Today’s Gay Youth,” n.d., n.p.)

Substantially higher proportions of homosexual people use alcohol, marijuana or cocaine than is the case in the general population. (McKirnan & Peterson, 1989, as cited in “Today’s Gay Youth,” n.d., n.p.)

Approximately 28% of gay and lesbian youths drop out of high school because of discomfort (due to verbal and physical abuse) in the school environment. (Remafedi, 1987, as cited in “Today’s Gay Youth,” n.d., n.p.)

Gay and lesbian youths’ discomfort stems from fear of name calling and physical harm. (Eversole, n.d, as cited in “Today’s Gay Youth,” n.d., n.p.)

M any people are guilty of discrimination against LGBT youths, whether consciously or unconsciously. LGBT youths are faced with daily discrimination from society, peers, family and even school teachers and administrations. The above statistics not only show that LGBT youths lack support and guidance but also prove how much these youths are clearly affected, in more ways than one, by discrimination. Cole (2007) mentions that there is a higher rate of abuse, neglect, and discrimination against LGBT youths than straight youths. I believe that most parents would prefer their children to be straight than to be gay, and most school officials also prefer straight students over gay students. This preference could be a contributing factor in discrimination against LGBT youths. This paper will hopefully capture the attention of parents and schools and perhaps help modify their outlook on LGBT youths. Fundamentally, I will attempt to answer the following questions throughout the paper: What are the effects of discrimination against LGBT youths? What is the role of the parents? What is the role of the schools? How can parents and schools work together to help minimize discrimination against LGBT youths? What more can be done? Before answering those questions, I will start by addressing the types of discrimination that LGBT youths are faced with.

Types of Discrimination

Some of the comments that LGBT youths are faced with are as follows: “I hate gays. They should be banned from this country;” “Get away from me, you faggot. I can’t stand the sight of you;” “These queers make my stomach turn.” Those are only a few of the biased statements that LBGT youths are faced with in society. According to Cole (2007), the word “faggot” is often used by anti-gay peers to terrorize LGBT youths. Words such as “faggot” or “gay” are sometimes used in a negative sense to express something either stupid or uncool (Human Rights Watch, 2001, p.35). When that occurs, it shows an even greater sign of discrimination against LGBT youths. I noticed that these words are not only used in the real world but also in movies and TV shows which makes it harder for LGBT youths to deal with. In addition to the discrimination from society and their peers, LGBT youths also endure discrimination from home/families and particularly schools.

“Today’s Gay Youth: The Ugly, Frightening Statistics” (n.d.) reports that one half of LGBT youths are neglected by their parents because of their sexual preference and approximately a quarter of LGBT youths are mandated to leave their homes. Cole (2007) explains that rejected LGBT youths generally do not learn how to build a relationship with peers or families. As a result, it creates a state of loneliness and isolation for them. Some LGBT youths are both verbally and physically abused by parents (“Today’s Gay Youth,” n.d.). In addition, roughly about 40% of youths that are homeless are classified as LGBT youths. The same article shows 27% of male teenagers who classified themselves as gay or bisexual left home due to quarrels with family members over their sexuality. Needless to say, parents and families play a big part in discrimination against LGBT youths and the effects that it has on them.

Nevertheless, it appears that the majority of the discrimination against LGBT youths emanates from the schools that they attend. Are schools taking any actions to minimize discrimination against gay students? What are they doing to help these adolescents? The following quote is an explicit example of how schools can contribute to discrimination against LGBT youths:

I took a call from one sixteen-year-old who came out to his counselor. The only other person he’d told was his friend in California. The counselor said, “I can’t help you with that.” After he left, the counselor called his mother to make sure she knew. The youth went home that night not knowing that he’d been outed to his parents. Sitting around the dinner table, his mother said to him, “I got a call from the school counselor today. We’re not going to have any gay kids in this family.” His father took him outside and beat him. (as cited in Human Rights Watch, 2001, p.106)

Human Rights Watch (2001) also reports that the same youth was harassed by his peers once they found out about his sexuality. At this point he turned to suicide, but was fortunately taken in by a family member who lived out of state where he finished school (p. 106). In the mentioned quote, the sixteen-year-old student did not get any support from his school guidance counselor or his parents. If his own school and parents would not give him any guidance or support, who else could he turn to? What is the alternative? This example could be a common concern throughout the world, where LGBT youths are not comfortable with their gender at school at home. Consequently, they are faced with an alternative which is rarely a positive one. The alternatives that they face may include depression, substance abuse, violence, and even suicide.

Effects of Discrimination

LGBT youths endure hostile verbal and physical harassment that can be excruciating for them (Human Rights Watch, 2001, p. 35). Human Rights Watch (2001) also states that although the youths that were interviewed emphasized their fear of physical and sexual assault, being called words like “faggot,” “queer,” or “dyke,” daily is still destructive (p.35).

One young gay youth who had dropped out of an honors program angrily protested, “just because I am gay doesn’t mean I am stupid,” as he told of hearing “that’s so gay” meaning “that’s so stupid,” not just from other students but from teachers in his school. (Human Rights Watch, 2001, p. 35)

Over 25% of LGBT youths are high school drop outs because of the discrimination they are faced with in the school atmosphere (“Today’s Gay Youth,” n.d.). The article also states the LGBT youths have a greater risk of academic failure than heterosexual students. Furthermore they don’t get involved much in student activities and have very little dedication to the school’s agendas because school isn’t a safe, healthy, or productive learning environment. Therefore, LGBT youths make an attempt to live, work, and learn with continuous fear of physical assault at school (“Today’s Gay Youth,” n.d.).

Physical abuse against LGBT youths usually occurs due to disregarded harassment (Human Rights Watch, 2001, p. 42). Human Rights Watch (2001) says that the number of physical assaults that were reported by interviewed LGBT youths had an enormous psychological impact on them, mainly because the physical abuse followed constant verbal and non-physical harassment that was overlooked by school officials (p. 42). For example, a lesbian student reported that several months of harassment and verbal threats grew to physical abuse. “‘I got hit in the back of the head with an ice scraper.’ By that point, she said she was so used to being harassed. ‘I didn’t even turn around to see who it was’” (Human Rights Watch, 2001, p. 42). Another incident mentioned by Human Rights Watch (2001) involved a tenth grade gay youth who was hit in the back of the neck with a beer bottle. He literally had to crawl to the nearest friend’s house for immediate assistance. The same youth was beaten up in the seventh grade by a couple of anti-gay kids (p. 42). One last example entails another gay youth who first suffered from verbal assault and students throwing items at him. Subsequently, a group of anti-gay students strangled him with a drafting line so bad that it cut him. Later that school year the youth was dragged down a flight of stairs and cut with knives by his classmates (Human Rights Watch, 2001, p. 42). Fortunately, he lived to talk about it.

Human Rights Watch (2001) implies that verbal and physical violence is a tension that LGBT youths have gotten accustomed to; however, it is damaging to their psychological wellbeing (p. 68). Many of the LGBT youths interviewed by Human Rights Watch (2001) reported signs of depression such as: “sleeplessness, excessive sleep, loss of appetite, and feeling of hopelessness”(p. 69). One reported incident involved a gay youth who could not take it anymore. He started to skip school so that he would not have to put up with the harassment anymore. He stayed at home all day and ended up missing fifty-six days of school. The youth explained, “‘It was mentally and physically stressful for me to go to that school. I remember going home and waking up in the morning just dreading it; dreading the fact that I would have to go back to that school’” (as cited in Human Rights Watch, 2001, p. 69). Other youths reported that even when the harassment was not addressed directly toward them, they were affected by it. One youth implied that discrimination and harassment makes him feel like he is backed up into a corner and so sad that he wants to cry (Human Rights Watch, 2001, p. 69). It is no wonder LGBT youth turn to drugs, alcohol, and suicide.

Cole (2007) claims that discrimination against LGBT youths can create repression along with a deficiency in their natural growth. Discrimination also has a social and emotional impact on them. Instead of being social individuals, LGBT youths remain in the closet and hide. The loneliness that they bear can turn into depression which often leads to substance abuse or even suicide. LGBT youths have greater chances of alcohol and substance abuse than heterosexual youths (U.S. Department of Health and Human Services, 1989, as cited in “Today’s Gay Youth,” n.d.). Also, roughly about one third of LGBT youths have a drinking or drug problem. Human Rights Watch (2001) interviewed some LGBT youths who say that they drink to the point of passing out or to feel good and normal (p. 69). The lack of support from parents or schools can possibly make them feel like there is no hope of ever living a happy life and being productive (Human Rights Watch, 2001, p. 68).

Roles of Parents

50% of all gay and lesbian youths report that their parents reject them due to their sexual orientation. In a study of male teenagers self-described as gay or bisexual, 27% moved away from home because of conflict with family members over sexual orientation. (Remafedi, 1987, as cited in “Today’s Gay Youth,” n.d., n.p.)

26% of gay and lesbian youth are forced to leave home because of conflicts over their sexual orientation. (U.S. Department of Health and Human Services, 1989, as cited in “Today’s Gay Youth,” n.d., n.p.)

In a study of 194 gay and lesbian youth, 25% were verbally abused by parents, and nearly 10% dealt with threatened or actual violence. (D’Augelli, 1997, as cited in “Today’s Gay Youth,” n.d., n.p.)

Approximately 40% of homeless youths are identified as gay, lesbian or bisexual. (Eversole, n.d., as cited in “Today’s Gay Youth,” n.d., n.p.)

Service providers estimate that gay, lesbian and bisexual youths make up 20-40% of homeless youth in urban areas. (National Network of Runaway and Youth Services, 1991, as cited in “Today’s Gay Youth,” n.d., n.p.)

It appears that the lack of support, protection, and guidance from family also has a major effect on LGBT youths. Perhaps, if their families were more supportive, the suicide and depression rates of LGBT youths would be moderately less. I believe that parents should embrace their children no matter what their sexual preference is. For an adolescent, I think that family should be the primary source for seeking support and guidance. When parents reject their gay or lesbian adolescent, I feel that it can possibly set him or her up for failure. This era is the time when adolescents would need their parents’ love and support the most. I also sense that when LGBT youths don’t get the love and support that they are looking for from parents, it contributes to their state of depression and suicidal phase. Therefore, parents of LGBT youths should take time to reflect on the circumstances before they make the wrong decisions.

One way of showing support would be for the youths’ parents or family to intervene with the school or at least make an attempt like the mother in the following quote:

“The more I talked to teachers, the superintendent, and the principal, the more they just kept throwing up brick walls and trying to convince me I would have to let my son go through this,” Ms. Cooper said. “But no child should have to go through this, whether he’s gay or not. When [bullying] gets to the point where a kid wants to quit school and give up his future, something has to be done.” (Browman, 2001, p. 3)

In the above case, the parent was being supportive to her gay son while the school officials were not. Like many other schools, they choose to ignore the fact that the gay student is being bullied and discriminated against. As mentioned earlier in the paper, that kind of response from schools also contributes to the effects of depression on LGBT youths.

Roles of Schools

“Educators cannot ignore the risks faced by homosexual students, but deciding how to deal with the issue should be a matter of local concern” (Archer, 2002, n.p.). In his article, Archer is stressing that educators must address discrimination against gay students and must put aside their personal views to create a safe environment for these students. In her article, Browman (2001) also talks about the lack of attention from school teachers and administrators toward gay discrimination and harassment. Browman (2001) acknowledges the educational effect on LGBT youths due to constant harassment in school. A very interesting point that was made in this article is, if a student makes a racial comment in school, he or she gets punished. So why should remarks like “dyke,” “fag,” or “queer” be acceptable? Are those words equal to the same level of discrimination as making a racial comment? The article advises that the problem of discrimination or harassment can be addressed at the verbal stage before it gets to the physical point or causes the youth’s academic learning to be harmed (Browman, 2001). The article continues to imply that teachers and administrators often fail to cease discrimination or harassment against LGBT youth. They are either afraid of facing prejudice from others or perhaps even because of their own prejudice (Browman, 2001). The article also suggests a way to express to all students that harassment or discrimination against LGBT students will not be tolerated. Consequences such as school conduct codes and discipline policies should be established as well as anti-harassment rules (Browman, 2001).

Browman (2001) reports that Human Rights Watch completed a two-year study on the topic where an immediate response was obtained from educational groups such as: The National Education Association, The Gay, Lesbian, and Straight Educational Alliance, and The American Federation of Teachers. The three groups adhered in influencing the Education Department to defend and protect gay and lesbian students from discrimination. They add that schools are making an effort to create a safe environment for all students where they can all be treated with equal respect and dignity. Accordingly, the department fights to provide the schools with information and guidance to help solve the problem of discrimination against LGBT youths (Browman, 2001).

Furthermore, New York City has made an attempt to come up with a solution that they thought would possibly reduce discrimination against LGBT youths by opening an all-gay school. I see this movement as a possible increase in discrimination against LGBT youths. If they are all put together in one school, how is that helping them deal with discrimination from society, peers and others outside of the school? And how is that teaching anti-gay students not to discriminate against LGBT youths? I don’t think isolation from the rest of the world is the best solution for LGBT youths. They are human beings just like the rest of us and they should be treated accordingly. I agree with what is stated in Browman’s (2001) article about the schools accomplishing all they can to stop discrimination against LGBT youths.

The two primary sources that have the power and ability to diminish discrimination against LGBT youths are schools and parents. In my opinion, they are the ones who have the greatest influence on LGBT youths and in turn have the ability to reduce substance abuse, educational failure, and suicides. Parents and schools need to realize how much they can help diminish the effects of discrimination against LGBT youths if they work together and productively. Clearly, if they remain on the same page they can ease the agony for LGBT youths and help them live a normal and happy life. One method that can be exercised in schools is a homosexual sensitivity training for anti-gay students and school officials. The training would benefit both students and school officials. I think that it would help the school officials manage whatever prejudices they may have against LGBT youths. Since anti-gay bullying students are perhaps ignorant to the subject, schools should modify a system where all students can be educated on the subject. It would probably help the students get a better understanding if homosexuality was compared to other subject matters such as culture and religion. Students should be provided with a full view of the subject just like any other. If this method helps only two out of ten anti-gay students cease discrimination against LGBT students, I am sure that it will make a difference. An additional scheme that should be established is monthly meetings between school officials and parents to review the progress of measures that are already in place.

Before writing this research paper, I never imagined how immensely affected LGBT youths were by discrimination. It is awful what they go through and how most people are clueless or even careless about what these youths endure. LGBT youths are faced with discrimination, torture, and sometimes even execution because of who they love, how they look, or who they are. I believe that sexual orientation and gender identity are integral aspects of ourselves and should never lead to discrimination or abuse. Doing this research not only made me realize the intense discrimination suffered by LGBT youths but also had an impact on me. This research has made me want to advocate for more laws and policies to help protect LGBT youths. I have gained a ton of information and knowledge during this process. However, if my readers obtain half of the valuable information that I have obtained, I know that I have accomplished my task.

Archer, J. (2002, February). Local schools must address safety for gays. Education Week, 21 (23), 3. Retrieved October 12, 2007, from EBSCO Host database.

Browman, D. H. (2001, June). Report says schools often ignore harassment of gay students. Education Week, 20 (39), 5. Retrieved October 12, 2007, from EBSCO Host database.

Cole, S. (2007, April). Protecting our youth. Edge . Retrieved October 31, 2007, from www.edgeboston.com

Human Rights Watch (2001). Hatred in the hallways. NY: Human Rights Watch.

Today’s gay youth: The ugly, frightening statistics (n.d.). Retrieved October 31, 2007, from www.pflagphoenix.org

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Top 5 Examples of LGBT Argumentative Essay Topics

The LGBT community is one of the most discussed modern topics. While many people stand for their rights, there are also those that strongly oppose them. Only knowledge and education can finish this conflict. That’s why it is so important to write essays on LGBT in educational facilities. Read our new material for some interesting ideas on LGBT argumentative essay topics.

Same-sex marriage essay

These are, by far, the most common essays dedicated to the question of LGBT. Usually, a same sex marriage arguments essay tells about the controversy surrounding the question of same-sex marriages. Such works are really interesting because they allow you to explore a truly heated debate. You may review a broad range of subtopics. For example, religious attitudes to the topic or, probably, some real-life stories about same-sex marriage.

Sometimes, it is very challenging to navigate through all the information on the given question. If you struggle with such an assignment, make sure to use a free essay sample as a source of inspiration. You can find it on the list of LGBT argumentative essay topics and examples written to help you deliver an excellent paper. Here you will find useful ideas and facts that will definitely help you.

Book review

There are many books dedicated to the question of LGBT. Many students receive a task to analyze such a book. This literary analysis will help you understand some interesting perspectives on the topic and explore various aspects of LGBT debatable topics. In most cases, an educator will present the most relevant book during the class. Later, you’ll be able to get its printed or digital copy for review. Remember to support your analysis with arguments from other sources. In this case, a library will come in handy.

Discussion essay on LGBT rights

LGBT rights are one of the most valuable LGBT argumentative topics. It is always surrounded by many controversies. In modern conditions, it goes primarily about measures taken against homophobic actions and hostility. During a sociology course, learners get many opportunities to explore the reasons for such behavior peculiar to some people. If you decide to deliver an essay on LGBT rights, you get a very fruitful field for some extensive research. There are also many sources you can use and many subtopics you may cover. For sure, it is a perfect choice for the most detailed and sophisticated papers.

Historical comparison essay

The rights and the attitudes towards the question of LGBT have changed over time. A great idea is to discuss these changes in a comparison essay. For example, you may compare the status of the LGBT society in the 19th century to the modern one. Many college students may focus on such an assignment, as it creates great opportunities for historical retrospectives. Such an approach also helps them research social change. There is an opportunity to apply various sociological theories or historical processes to explore the question in more detail. Anyway, the potential for research is almost unlimited in this direction.

Narrative essay on gay rights and problems

One of the greatest opportunities to explore the LGBT community and its issues is to deliver an excellent narrative on the topic. You are free to choose any subtopic related to this question for writing. For example, a decent idea would be focusing on your experience of interaction with its representatives. Probably, you may describe some personal experiences related to the LGBT community . This will help you explore some real emotions or characters. After all, such a work will be much more engaging to the readers. There are great opportunities to express your personal attitudes to the given question and include a meaningful appeal.

A great benefit of such an assignment is that you’re free to use your creativity. For example, you may suggest what the future of the LGBT community should look like. In this case, you may focus on the rights of such people, their future status, and your expectations of the future of same-sex marriages. This will make your work overlap with an argumentative essay on LGBT marriage. The main difference is that the work will show your ability to anticipate and make up something much better. Probably, even the most demanding university teachers will be satisfied with such an appeal.

Final thoughts

So, these were the most promising topics for an essay on LGBT. Probably, you may come up with your own idea, but make sure to use our topic examples for inspiration. The topic is extremely broad and includes many possible subtopics. So, with the right approach and a decent understanding of the question, you may come up with some great ideas on how to write an excellent LGBT essay.

David Tobin did his degree in psychology at the University of Edinburgh. He is interested in mental health and well-being.

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Writing About LGBTQ Rights

Essay paper writing

Academic writing

Violation of the rights of sexual minorities is an acute problem in modern society. That is why LGBT essay topics are getting more and more popular nowadays. The issue is that some conservative groups still regard homosexuality as unnatural and harmful phenomenon.

Cultural traditions and values that determine heterosexual behavior as ‘normal’ contribute to the formation of heterosexism and various phobias towards gay people. This attitude leads to the occurrence of social stigma, which turns the lives of sexual minorities into hell. Accordingly, to solve this problem, it is necessary to promote tolerance and acceptance towards LGBTQ people. You will take a little step in this direction when writing a homosexuality research paper.

Basic terminology for essay on homosexuality

‘Sexual minorities’ is a general collective term formed according to the principle of similarity with such notions as ‘national (ethnic) minorities’ (representatives of a nationality or ethnos) and ‘political minorities’ (representatives of the opposition).

It is worth explaining to the readers of your gay rights activist essay that this concept assumes that the sexual orientation is not deviant or pathological, just like national or political minorities.

The concept of ‘sexual minorities’ does not include groups of people whose sexual predilections are defined as deviant or pathological by medicine, or whose sexual actions occur not with the mutual consent of two adult persons: zoophiles, necrophiles, and pedophiles.

Since these parameters may not coincide with each other and can be manifested differently at various stages of life, an unambiguous division of individuals into hetero-, homo- and bisexual groups, as well as their number, is very problematic.

Here are some interesting facts that can be used for gay rights history essay:

The term ‘homosexuality’ was first used in 1869 in an anonymously published pamphlet written in German by the Austrian publicist Karl-Maria Kertbeny.
Half a century ago, the word ‘gay’ meant ‘cheerful and carefree’ in English. However, now it is no longer used in this meaning. The origin of its use for defining sexual orientation is not entirely clear.
In the Provençal dialect, the term ‘gay’ meant the ‘art of poetry and love.’
In England in the XVII century, the word ‘gay’ denoted a frivolous person, and then (with regard to women) a prostitute.
In the 1930s, it was the most frequently used name among the homosexuals themselves.
In the 1960s, this word began to spread to a wider range of speakers. For example, it was used by the psychotherapist Albert Ellis to refer to homosexuals in the popular book The Intelligent Woman’s Guide to Man-Hunting (1963).
The term ‘lesbianism’ comes from the name of the Greek island of Lesbos. The ancient poet Sappho ran to the island from Athens due to persecution. Her poetry was later perceived as the chanting of same-sex love between women.

Now let’s consider the phenomenon of transsexuality. As you definitely know, transsexuals are people who strive to change their sex to the opposite. The phenomenon of transsexuality existed in all historical periods; nevertheless, for centuries, such people were perceived as deviant ones.

In 1966, the American researcher Harry Benjamin devoted the book to this issue and managed to convince the medical community that the former opinion about the mental state of these people was incorrect. He also introduced the term ‘transsexualism’ and proved that it is a special form of psychosexual disorder: the human body remains healthy enough and possess the characteristics of natural gender, but the psyche (quite healthy from the point of view of psychiatry) belongs to a person of the opposite gender, which is confirmed by their behavior, lifestyle, habits, manners, and clothes.

Historical overview for gay rights research paper

In order to write a quality sexual orientation discrimination essay, it is worth touching upon the history of the issue under consideration. Homosexuality exists just as long as humanity. It was normal practice for inhabitants of undiscovered America as well as for the black people of the African continent. Moreover, this phenomenon broadly existed in Greek and Roman cultures. Finally, homosexuality in Slavic society was perceived as a normal intimate contact between willing partners.

At various stages of the development of civilizations, the attitude towards sexual minorities was quite ambiguous. The model of behavior depended primarily on the prevailing ideology, culture, and the existence of certain traditions.

Among the aborigines of New Guinea and Melanesia, the ritual of initiation (insemination) was quite popular. It was considered that a boy could become a real man only if he was inseminated by an adult tribesman who conveys the best traits: masculinity and courage. A similar ritual took place among the tribes of Brazil, Argentina, Chile, and Amazonia.

The Japanese were considered quite tolerant people until the XIX century. They respected the aesthetics of the male body. For example, the samurai homoerotic connection was a typical feudal relationship.

With the establishment of the dominant positions of Christian dogmatism in Europe, ‘sodomites’ were outlawed, and measures were introduced to curb the grave sin. In particular, along with the witches and heretics, the Holy Inquisition tortured homosexuals at the stake.

In an essay on gay rights violation in Russia, you may mention that in pre-Petrine time, serious penalties for ‘sodomites’ were not practiced, unlike in Western Europe. The Russian Orthodox Church condemned the “mortal sin,” but, meantime, monasteries were the source of the spread of same-sex relationships. Peter the Great tried to toughen the policy concerning sexual minorities. In 1706, the death penalty through burning at the stake was introduced for the military for ‘unnatural fornication’ (according to the Swedish model). In 1716, the ruler replaced the burning with corporal punishment and exile. However, these norms did not apply to civilians.

After the October Revolution, the situation changed radically. The acquisition of the governing role by the Bolshevik party drove gays and lesbians into the underground. In 1934, the article of the Criminal Code on imprisonment up to 5 years (up to 8 years in case of physical violence) for sodomy came into force. Although same-sex sexual activity between consenting adults in private was decriminalized in 1993, homosexuality is disapproved of by most Russians, and same-sex couples and households headed by same-sex couples are ineligible for the legal protections available to opposite-sex couples. Since 2006, numerous regions in Russia have enacted varying laws restricting the distribution of materials promoting LGBT relationships to minors; in June 2013, a federal law criminalizing the distribution of materials among minors in support of non-traditional sexual relationships was enacted as an amendment to an existing child protection law. This is a good example for your gay rights cases essay, which should be focused on the serious problems the gay people still have to face.

While homosexuality in the USSR was criminalized, in Europe and in the West, reverse processes progressed. Before Hitler came to power in Germany, there was a struggle between the country’s leadership and the gay community, which advocated the abolition of criminal punishment for people of ‘unnatural’ sexual orientation. Activists have achieved their goal only in 1969, one hundred years after the first attempts.

An important fact to describe in research essay on gay rights is that in Europe, in the 1970s, the activists adopted the official symbol of LGBTQ, the rainbow, as well as developed a concept with basic political requirements, namely the legalization of same-sex relationships and the right to marry. Recently, one more requirement has been added: the right to adopt children.

The first country to legalize the registered love unions of homosexual couples was Denmark (1989). The Netherlands, the Czech Republic, and the Scandinavian countries followed the trend. In April 2005, New Zealand also permitted same-sex civil unions. In December 2005, the conservative United Kingdom became the next country to allow the legalization of homosexual relations.

Information for development of LGBT rights essay

LGBT movement is a civil society movement that seeks to achieve legislation changes aimed at ensuring and protecting human rights for the LGBT community and promote social adaptation of its representatives in the society.

The opponents of this human rights movement are a variety of political and religious organizations collectively referred to as anti-homosexual unions.

Gay rights in different countries

It is worth describing the legal status of homosexuality in the world in an essay on gay marriages. The attitude towards the LGBT community is rather heterogeneous in different parts of the world. As a rule, in Western countries, homosexuals and heterosexuals have equal rights. In many states of Western Europe (The Netherlands, Belgium, Spain, Great Britain, Denmark, Norway, Sweden, Greenland, Iceland, France, Germany, Finland, Luxembourg, Northern Ireland, Slovenia, the Czech Republic, Switzerland since 2007), as well as some countries of North and South America and South Africa, same-sex couples may enter into so-called civil partnerships or marriages.

At the same time, discrimination against people of homosexual orientation is also a common phenomenon whose roots go far into history. There is a significant number of states in Africa and Asia in which non-violent homosexual intercourse is perceived as a criminal offense punishable by imprisonment or death, for instance, in modern Iran, Afghanistan, Saudi Arabia, Yemen, Somalia, Sudan, Nigeria, and Mauritania.

In these countries, there is no open struggle for the rights of sexual and gender minorities since such activities may pose a threat to their freedom and life. However, some political parties lobby for the softening of criminal legislation against homosexuals. The lobbyists are the reformist and moderately liberal forces in the leadership of these states. In particular, former Iranian President Mohammad Khatami expressed his views in favor of softening the laws against homosexuals.

In addition, international pressure is aimed to compel respect for human rights.

Abolition of instructions and provisions defining homosexuality as a medical pathology

The idea of rights equality implies the official recognition of homosexuality as one of the variants of the psychological norm in accordance with modern scientific views and official WHO documents.

In this regard, LGBTQ organizations, professional medical bodies, liberal politicians, and human rights activists fight for the abolition of instructions and provisions that define homosexuality as a mental disorder and adoption of official documents prohibiting them at the level of the state Ministry of Health and national associations of psychiatrists and psychologists.

You may use such LGBT research paper thesis: there should be no ‘treatment for homosexuality’ or ‘correction of sexual orientation’ for healthy people as homosexuality is not a disease. The harm of such influences for patients has already been proven, while there are still no reliable examples of ‘correction of orientation.’

Abolition of prohibitions on professions

In some countries, there have been or still exist bans on certain professions for people who are openly gay. This may be, for example, a ban on army service, work as a teacher at school or as a doctor. LGBTQ organizations seek, and in some cases, have already achieved the abolition of these prohibitions.

Special sociological studies conducted in Western countries revealed that the homosexuality of an officer or soldier does not affect the discipline or internal psychological climate of the military unit. Consequently, there is no reason to deny homosexuals the right to serve in the army.

It was also proved that the homosexuality of the teacher does not lead to any complications in the relations with the students and does not predispose an educator to committing lewd acts against the students. It’s an obvious fact that homosexuality and pedophilia are fundamentally different things. So, there is no reason to prohibit homosexuals from working as teachers at schools.

The idea of repealing the ban on the profession of a teacher for homosexuals is being criticized by conservative people who believe that the very presence of an educator with such sexual orientation in school is a negative example and the promotion of homosexuality. At the same time, supporters of this point view do not have any scientific data proving that there are more homosexual graduates at schools where gay teachers work or that such educators are more likely to commit lewd acts toward students. So this idea is just a prejudice of some groups of society.

Abolition of the ban on donation

In some countries, there is a ban on the donation of blood and organs from members of sexual minorities. LGBTQ organizations are trying to challenge this norm and achieve the elimination of discrimination.

Observance of human rights in relation to LGBT people

The gay rights movement essay should be focused on the fact that, even in countries where criminal and administrative penalties for manifestations of homosexuality were abolished a long time ago, the practice of human rights violations against homosexuals persisted.

LGBTQ organizations struggle not only for the formal abolition of criminal punishment for homosexuality but also for changing the real polices and administrative practices. For example, the notion of ‘disturbance of public order’ should be equally applied (or not applied) to same-sex and heterosexual couples kissing or hugging in public places. Also, LGBTQ activists fight for the right to participate in peaceful demonstrations, including prides, create public organizations, have access to information and medical care, etc.

Anti-discrimination laws

LGBTQ organizations also advocate for the mentioning of sexual minorities members in anti-discrimination laws (or the adoption of separate anti-discrimination laws on sexual minorities). They also seek direct mentioning of sexual orientation and gender importance in relevant articles of the Constitution guaranteeing equal rights to all citizens regardless of gender, age, religion, and nationality.

The right to register a marriage

Writing a gay marriage civil rights essay will be very relevant because, in recent years, there has been a growing movement in support of same-sex unions. The fact of marriage registration assigns the following rights to the homosexual family:

joint property;
inheritance;
social and medical insurance;
preferential taxation and lending;
the right to a name;
the right not to testify in court against the spouse;
the right to act as a trustee on behalf of the spouse in the case of his/her incapacity because of health problems;
the right to joint parenthood and the upbringing of foster children;
other rights of which unregistered couples are deprived.

Advocates of same-sex unions point out that the registration of marriage is a legal action which is independent of the religious norm (in most modern states, legal and church registration of marital relations occur separately) and that the law should follow social changes leading to the elimination of inequality between people as it happened during the last centuries when the existing prohibitions on registration of marriages were gradually abolished, for example, for spouses belonging to different confessions or races.

In a research paper about same-sex marriage countries such as the Netherlands, Belgium, Spain, Canada, South Africa, Norway, Sweden, Portugal, Iceland, and Argentina among others may be listed as those which granted gay couples the full right to marry. Same-sex partnerships alternative to marriage are legal in many states, for example, Andorra, Australia, Austria, Brazil, Great Britain, Hungary, Germany, Denmark, Israel, Ireland, Colombia, Luxembourg, New Zealand, Slovenia, Uruguay, Finland, France, Croatia, Czech Republic, Switzerland, and Ecuador.

The LGBT movement seeks the right for the adoption of a child of one of the partners by his or her spouse, the possibility of adopting children from orphanages by same-sex families, and the right of equal access to reproductive technologies for gay and heterosexual couples. It should be noted in a same-sex parenting research paper that these issues are considered separately in many countries where LGBTQ people are given broad rights.

In accordance with the legislation of some states, only one partner can adopt a child, becoming a caretaker or foster parent. Laws do not contain references to sexual orientation as grounds for refusal of adoption or guardianship, but gay couples often face failures in practice. Sexual orientation is also not a restriction on access to reproductive technologies, but the same-sex family may have problems with establishing the child’s parenthood. That is why the research paper on gay parenting should touch upon the acute problem.

Social activities

LGBT movement members are engaged in social activities such as the organization of various cultural events, for instance, film festivals, sports competitions, musical concerts, photo exhibitions, theater performances, installations, flash mobs, etc. Their aim is a social adaptation of the LGBT community, development of its cultural potential and building a dialogue with the rest of society. As a rule, most of such events are of the educational nature, which should be described as a positive factor in argumentative essay on gay rights.

In addition, the representatives of the LGBT community release numerous books and magazines and take part in various radio- and television translations. Moreover, it is worth mentioning that they offer special services, namely accessible and high-quality psychological, legal, and medical assistance, hotlines, and self-help groups to the members of their community.

Useful tips on how to write a quality LGBT discrimination essay

An important part of many international exams is essay writing. Preparing this type of academic paper might be a difficult task since it requires excellent knowledge of the subject, creative thinking, and adherence to certain rules. Using our advice, you will create a perfect essay about gay and lesbian rights.

Preparation

Start to think about human sexuality research paper topics as soon as the assignment has been given to you. The saved time will give you the opportunity to collect as much information as you need to write a persuasive paper.

If you are given the freedom of choice, rely on your own preferences and knowledge about the phenomena under consideration. The topic of homosexuality is much wider and more interesting than it seems at first glance. You can write:

research paper on gay adoption;
essay about issues that LBTQ community has to face;
gay rights court cases essay;
paper about the nature of human sexuality;
work about homosexuality and domestic violence, etc.

Having completely concentrated on a chosen issue, you will soon notice that the necessary data and facts appear exactly when you need them. A similar effect occurs when learning a new word. It suddenly begins to appear more often than before. Since the brain is tuned for a certain type of information, you will, first of all, pay attention to it.

Try to draw up an approximate gay rights essay outline. Systematize all the material you have. This will help you to determine the future direction of the work. Write down the main questions to be answered. In the process of studying the topic, the outline will be replenished with new and more specific items.

Do not be afraid to start writing the gay and lesbian rights essay

It is said that even experienced writers sometimes feel insecurity and fear before they take on new work. So it is necessary to overcome your concerns regarding your writing skills and start working. You can start with anything. Do not think about style and spelling for now. The main thing is to move from a dead point. Having written the thesis, begin to elaborate on the structure of your gay rights pros and cons essay.

If you are printing a text on the computer, you can rearrange the fragments of an essay as you need. If you keep notes on the paper, leave a few blank lines after each important idea in order to complete it later. Try to adhere to the classical structure, especially if you were instructed to do so: introduction, main part, conclusion.

Introduction for gay rights essay

This part usually provides general information on what you are going to write in a paper and lists the expository essay on gay rights key points if you are writing this type of essay. Specify what questions on the chosen topic you are going to cover. Do not forget that essay is usually considered a short paper, and therefore, only the necessary details should be mentioned.

From a well-written introduction of gay rights expository essay, it becomes clear to a reader that you understand the topic and intend to answer all the questions posed. It is of critical importance to mention the conducted studies related to the point and give reference to respective sources. The ideal size of this part of the essay is no more than 10% of the entire work. For example, if the paper is to be of 2000 characters, the length of the introduction paragraph should not exceed two hundred characters.

At the beginning of the essay, use such phrases as ‘This paper is devoted to...’, ‘This essay will consider...’, etc. Next, you need to repeat or slightly modify the wording of the main question. For instance, if you prepare a should gay couples have the same adoption rights as straight couples essay, you can write something like ‘This paper considers the preconditions for giving same-sex and gay families equal rights regarding the adoption of children.’ Definitions should be clear, without any ambiguous interpretations.

In the main part of your assignment, you need to present all arguments supported by examples and relevant citations. Based on the logic of the narrative, the text, including the body section, should be divided into paragraphs. Therefore, it is necessary to make up the gay rights movement outline for essay in such a way that the main part can smoothly flow to the conclusion.

You must draw conclusions based on all the ideas presented in the previous sections. This way, you will be able to answer the main question considered in the paper. If this information was already mentioned in the research paper topics about homosexuality, describe the consequences and prospects of the issue under study and suggest different solutions to it. You can surely share your views. However, make sure to support them with reliable arguments.

Below we have listed some helpful tips that can assist you in writing a good conclusion:

It is not enough just to sum up and logically complete the paper. You have to tell how the written content is applicable to real life.
Restate the theses presented in the introduction of gay rights expository essay in other words in a conclusion paragraph.
You need to emphasize the key ideas that were expressed in the body of the text. It will be particularly necessary if the volume of the paper is large enough. The conclusion of a short gay rights pros and cons essay may do without listing the main ideas.
You can use a relevant quote or a spectacular question at the end of the paper to encourage the reader to further reflections.

What should you avoid while writing a conclusion?

Many students lower the quality of their work by making commonplace mistakes. If you are interested in writing a top-notch paper, make sure to avoid them. Here are some of the recommendations on how to make your paper engaging:

Express your opinion confidently, without apologizing and justifying yourself. Phrases like ‘Of course, I’m not an expert’ are inadmissible.
Do not pay too much attention to minor facts.
Do not question the arguments given earlier. That means you should not contradict yourself.

Most teachers believe that the final part is the most important one in the essay. Conclusion is an illustration of how well you have learned the material and managed to cover the essence of essay topics about gay rights. If, after writing the concluding paragraph, you notice that some corrections are needed throughout the rest of the paper, make sure to adjust the text accordingly. This will only improve the quality of the writing piece.

Below you can see the approximate proportions of the ideal essay:

introduction – up to 10% of the total volume;
main body – approximately 70% of writing;
conclusion – no more than 15% of the text.

You may not rush to choose a title among all the gay rights movement essay titles. This task can be left for the final stage of work when all thoughts are formulated in the paper, and you can summarize them in a thesis based on which a concise title should be created.

Stylistics of an essay

Do not abuse cumbersome verbal constructions. Refrain from jargon and abbreviations unless you are writing a satirical essay over gay rights. The optimal form of writing presupposes using concise and comprehensible phrases. Sometimes they can be alternated with more voluminous sentences. Your main goal is a simple and apprehensible presentation of the essence of the material. Write in such a way that the reader can easily follow the course of your reasoning without being distracted by unnecessary details.

Sometimes it is worth challenging both sides

If you consider complex persuasive essay topics on gay rights, keep in mind that there are two sides to every coin. That means that each phenomenon has negative and positive aspects. The list of contradicting arguments will help in the development of theses. In addition, arguing on the opposite side of your opinion, you will learn what points should be reviewed in more detail.

For example, you write a gay adoption research paper. In order to substantiate both the pros and cons of adoption by gay couples, it is necessary to consider not only arguments for but also those against the adoption of children by same-sex families. You will have to think of the answers to the questions like ‘Will the parents cope with their responsibilities?’ If you find good answers to these questions, be sure that you will be able to support your point of view.

It is advised to expose your writing to a scrupulous analysis. It is much better than trying to adapt real facts to own goals, present false information to the readers, and mislead them. Perhaps you will be able to convince an inexperienced novice. However, if the teacher who is well-versed in all argumentative essay topics on gay rights will check the paper, you will need a strong argumentation with consideration of solid facts to justify your ideas. Therefore, do your best to make your paper really unique.

Use these instructions, and it will be easy for you to work with any LGBT topics for research papers.

For a long time, gays, lesbians, transsexuals, and bisexuals were forced to live hiding their true nature, silently enduring persecution, contempt, humiliation, blackmail, and even murders. They had to suffer from the common opinion about their ‘inferiority.’ Being victims and objects of ridicule and gossip in all social circles, gay people were rejected by everyone and everywhere.

People governed by stereotypes and prejudices denied the rights of LGBTQ community. But we all need to understand that everyone has the right to respected, regardless of skin color, language, income, culture, religious beliefs, political ideology, or sexual preferences.

As stated in the UNESCO Declaration of Principles on Tolerance (1995), “ Tolerance is harmony in difference. It is not only a moral duty, it is also a political and legal requirement. Tolerance, the virtue that makes peace possible, contributes to the replacement of the culture of war by a culture of peace.”

We hope that you will be able to convey these important thoughts to readers of your essay on gay rights. Following all the above rules written by our best paper writers, you will get the highest score. Good luck!

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Home — Essay Samples — Sociology — LGBT — The Importance of Accepting the LGBT

The Importance of Accepting The LGBT

Categories: LGBT

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Published: Jul 17, 2018

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Classroom Q&A

With larry ferlazzo.

In this EdWeek blog, an experiment in knowledge-gathering, Ferlazzo will address readers’ questions on classroom management, ELL instruction, lesson planning, and other issues facing teachers. Send your questions to [email protected]. Read more from this blog.

‘We All Have LGBTQ Students, Whether We Know It or Not’

(This is the second post in a two-part series. You can see Part One here .)

The new question-of-the-week is:

What can teachers do to most effectively support LGBTQ students?

In Part One , Jennica Leather, Silvina Jover, and Jennifer Orr shared their suggestions. Jennica and Silvina were also guests on my 10-minute BAM! Radio Show . You can also find a list of, and links to, previous shows here.

Today, Alaina Kommer, Nicholas Flippen, and Rocio del Castillo, Ed.D., contribute their thoughts.

Alaina Kommer is a visual arts teacher and the coordinator of the Humanitas Magnet for Interdisciplinary Studies at Grant High School in Valley Glen, Calif.:

We all have LGBTQ students, whether we know it or not. When a class discussion brushes against the topic of gender or sexuality, those students will hang on to your every word. They’re listening to hear if you’re someone they can trust or not. How can you let them know that you’re an ally?

When you introduce yourself to your class, include your pronouns. Let your students know that you will respect their pronouns, too. If you aren’t used to using they/them as a singular pronoun, practice this summer. Modeling this practice for your students will have a huge impact.

Do you currently include LGBTQ authors, artists, scientists, and activists in your syllabus? Consider adding more. When you introduce them to your class, let your students know that they are part of the LGBTQ community. It’s important for all students to learn about the contributions of LGBTQ people to the arts and sciences.

Pay attention to the way that gender roles show up in your language. Do you have different expectations for your male and female students? You may think that you don’t, but gender roles are deeply ingrained in our culture. I’ve heard teachers tell male students that they’re whining like a girl and tell female students that they need to be more ladylike. Female students often groan when a teacher asks for “a few strong guys” to move tables around. Removing those biases from our language will make classrooms more egalitarian for all students.

Intersectionality

Nicholas Flippen teaches special education to high school students with severe and profound multiple cognitive and physical disabilities:

Mount Airy, N.C., is a small, conservative town most well known as Mayberry to those who have seen The Andy Griffith Show. It is located in the Bible Belt, meaning churches are on every corner, most of which were known to spew hate toward the LGBTQIA+ community. It was where I grew up and where my family still lives.

In 2012, Amendment One was being introduced in North Carolina, which defined marriage as being that of one man and one woman. This failed to recognize civil unions and domestic partnerships. Many people supported it, and it became clear how my community felt about the matter. To say this made my decision to come out difficult would be an understatement.

Being faced with a difficult situation regarding my sexuality made me cry one day, and a teacher pulled me aside to check on me. I had not told this teacher anything about the situation or my sexuality, so I was taken aback when he suggested that the situation was stemming from my struggle with my sexuality. While this came from a place of caring, I felt violated and uneasy being addressed in this way.

After that encounter, I met one teacher who made a profound impact on my life during high school. Our first assignment was to write an introduction about ourselves and address something we thought nobody else knew about us. I wrote about being gay and being terrified of anyone finding out. That was the first time I ever told anyone.

Her response was phenomenal and helped shape how I would come out in the very near future. She simply wrote a comment saying she would be happy to meet with me anytime to talk. Even further than that, she gave me her phone number and let me know that I could call or text if I wanted to reach out. Assuring me that she was an ally and someone I could trust gave me so much comfort. It was both liberating and terrifying to admit such a secret to someone. Interacting with teachers such as her made me hopeful that I, too, could become such an educator in the future.

Having only spent four years teaching so far, I have encountered many students who are struggling with their sexuality or gender identity. These experiences remind me how comfortable one teacher made me feel at a time when I thought I would never feel secure as myself. She simply made a connection with me and presented herself as a beacon for help in a noninvasive way.

Students who are struggling with their sexual and gender identities have valid and just reasons for feeling scared. Historically, queer people have been oppressed, hurt, and killed for being who they are. Where most teachers make the mistake is imposing their help or assuming sexual or gender identities. These judgments can make a student feel unfairly judged, wrongly identified, and completely invalidated.

As an educator, it is important to be mindful that your students’ experience is unique to them. Their perception of their world is their reality, and keeping that in mind when positioning yourself as an ally is important. The most effective strategy to support LGBTQIA+ students is to present yourself on day one as a teacher who supports all students as my teacher did when she established herself as someone I could trust. It is equally important to be specific in addressing the type of language you will and will not allow in your classroom in regards to LGBTQIA+ students. As educators, we know the power that words can hold.

Educators must also make active efforts to include queer history and perspectives so they are not weeklong features but an integral component to their content. When kids see themselves, they feel validated, comfortable, and visible. Too often, queer perspectives are marginalized or erased. Understanding intersectionality is paramount to being able to empathize with our queer students. For example: black queer students experience higher rates of both suicide and homicide, more specifically, black transgendered women.

Show your entire class how much you truly care and support the LGBTQIA+ community by your words, actions, and policies. Queer students will appreciate it and feel safe, whether they ever tell you or not.

‘Be an Ally’

Dr. Rocio del Castillo began her career as a school psychologist in Peru and has dedicated her professional career to being an advocate for educational equity and social justice. Rocio currently serves as assistant superintendent for special services in Huntley Community School District 158 (Illinois) and as an adjunct professor:

The goal of education is to promote equity in learning opportunities while fostering an environment of acceptance and respect among those who are in our schools. Research shows that the education environment is a space where LGBTQ+ students suffer greater discrimination and stigmatization. In the introduction to its new guide, Best Practices for Serving LGBTQ Students , Teaching for Tolerance claims that according to data from the Gay, Lesbian & Straight Education Network GLSEN , an organization that provides resources, research, and advocacy in support of queer youth, more than half of LGBTQ students feel unsafe at school. Fewer than 25 percent of those students see positive representations of queer people in their classrooms; more than half hear negative remarks about their sexuality or gender identity from school staff.

Here are some approaches to support our LGBTQ+ students and to ensure they feel welcome, safe, represented, and included in our classrooms.

Inform and educate yourself.

Learn about the experiences and stories of LGBTQ+ people. That’s an important way to understand the issues that affect their lives.
Identify available resources to support respect for sexual diversity and gender identity, as well as the organizations and groups that offer them.
Talk with LGBTQ+ students to learn about their reality firsthand. Having a personal connection allows you to question prejudices and stereotypes.
Read, learn about, reflect, listen, propose, and participate. Knowing and embracing diversity transforms lives.
Recognize and overcome your biases. We’ve all been socialized in homophobia, transphobia, and biphobia. Know your fears, prejudices, and stereotypes around the issue. The more you do, the easier it will be to transform yourself in order to transform the reality in your classroom. Question the stereotypes and reflect on the ideas and realities that you associate with LGBTQ+ people.
Sponsor affinity groups where students and teachers can have discussions based on identity. They are essential for embracing diversity.
Demonstrate a clear position against discrimination in general and in favor of diversity. Put up signs that identify your classroom as a safe space. For more information, download GLSEN Safe Space Kits.

Use inclusive language.

Discrimination begins with linguistic practices. Make it a goal that every person who hears you feels recognized positively in your speech.
Avoid always speaking from the masculine point of view and treating the rest of the people as if everyone were heterosexual.
Respect every person’s desire to be treated with the gender and name with which they identify and with their preferred pronouns.

Create safe spaces and inclusive pedagogy.

Be sure that the students see themselves reflected in what they are learning.
It is very important to deconstruct myths and stereotypes around sexuality, gender, and sexual orientation and to work on these issues in a cross-disciplinary way.
Promote coeducational games, encourage the use of recreation spaces undivided by sex, and incentivize reading stories without gender stereotypes. Go to Ready, Set, Respect! GLSEN’s Elementary School Toolkit for more information.
Avoid making groups using sex as a criterion. Use creativity and divide students on the basis of other characteristics, such as age, birth month, birth order, numbers, alphabetical order, etc.
In your classes, introduce role models for different sexual orientations and gender identities. There are many outstanding figures in history, science, literature, religion, and art who have loved and desired persons of their same sex or who have lived beyond the gender norms of their time period. Go to GLSEN LGBTQ History for more information.
Support celebrations of LGBTQ+ Pride day, as well as other awareness-raising events.
Remember that silence reinforces harassing behaviors and attitudes for homophobia, transphobia, and biphobia. For more information, see Parents, Families, Friends, and Allies United with LGBT People (PFLAG).

Respect each student’s identity and journey.

Do not focus your attention and relationships with LGBT people exclusively on their sexual orientation, sexual identity, or way of expressing their gender. There are many more facets to their personality which should not be overshadowed.
Respect every student’s privacy and ask for permission before sharing the information given to you with others, including their families. For more information, check Family Acceptance Project.
Speak with your LGBT students about the challenges implied by possibly coming out of the closet. For more information, check GLSEN : Coming Out
Ask your LGBT students about their fears and hopes for the future. Recognize that the prejudice experienced by LGBTQ+ students can contribute to anxiety, depression, substance abuse, and other mental-health problems. For more information, check American Psychological Association .

Thanks to Alaina, Nicholas, and Rocio for their contributions!

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Read the Florida Supreme Court’s Ruling on the Abortion Ban

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The Florida Supreme Court overturned decades of legal precedent in ruling that the State Constitution’s privacy protections do not extend to abortion, effectively allowing Florida to ban the procedure after six weeks of pregnancy.

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Supreme Court of Florida No. SC2022-1050 PLANNED PARENTHOOD OF SOUTHWEST AND CENTRAL FLORIDA, et al., Petitioners, VS. STATE OF FLORIDA, et al., Respondents. No. SC2022-1127 PLANNED PARENTHOOD OF SOUTHWEST AND CENTRAL FLORIDA, et al., Petitioners, VS. STATE OF FLORIDA, et al., Respondents. April 1, 2024 GROSSHANS, J. The Florida Constitution guarantees "the right to be let alone and free from governmental intrusion into . . . private life.” Art. I,

§ 23, Fla. Const. In this case, we are asked to determine if there is a conflict between the rights secured by this provision and a recently amended statute that shortens the window of time in which a physician may perform an abortion. See ch. 2022-69, § 4, Laws of Fla. (codified at section 390.0111(1), Florida Statutes (2022)). The parties have presented thoughtful arguments as to the scope of this provision, which has traditionally been referred to as the “Privacy Clause." Those legal arguments on the Privacy Clause's meaning are, in our view, distinct from the serious moral, ethical, and policy issues that are implicated in the subject matter of this case. Our analysis focuses on the Privacy Clause’s text, its context, and the historical evidence surrounding its adoption. After considering each of these sources and consistent with longstanding principles of judicial deference to legislative enactments, we conclude there is no basis under the Privacy Clause to invalidate the statute. In doing so, we recede from our prior decisions in which-relying on reasoning the U.S. Supreme Court has rejectedwe held that the Privacy Clause guaranteed the right to receive an abortion through the end of the second trimester. See generally In re T.W., 551 So. 2d 1186 (Fla. 1989); N. Fla. Women's Health & - 2

Counseling Servs., Inc. v. State, 866 So. 2d 612 (Fla. 2003); Gainesville Woman Care, LLC v. State, 210 So. 3d 1243 (Fla. 2017). For this reason, petitioners are not entitled to the temporary injunction granted by the trial court, and we approve the outcome reached by the First District Court of Appeal below.1 I This case involves a constitutional challenge to an amended Florida statute prohibiting abortions “if the physician determines the gestational age of the fetus is more than 15 weeks." § 390.0111(1), Fla. Stat. (2022); ch. 2022-69, § 8, Laws of Fla. (providing effective date of July 1, 2022). This prohibition does not apply if any of the following occurs: (a) Two physicians certify in writing that, in reasonable medical judgment, the termination of the pregnancy is necessary to save the pregnant woman's life or avert a serious risk of substantial and irreversible physical impairment of a major bodily function of the pregnant woman other than a psychological condition. (b) The physician certifies in writing that, in reasonable medical judgment, there is a medical necessity for legitimate emergency medical procedures for termination of the pregnancy to save the pregnant woman's life or avert a serious risk of imminent substantial and 1. We have jurisdiction. See art. V, § 3(b)(3), Fla. Const. (express-and-direct conflict). - 3

irreversible physical impairment of a major bodily function of the pregnant woman other than a psychological condition, and another physician is not available for consultation. (c) The fetus has not achieved viability under s. 390.01112 and two physicians certify in writing that, in reasonable medical judgment, the fetus has a fatal fetal abnormality. § 390.0111(1)(a)-(c). Prior to this change, the statute had restricted only late-term abortions. ² After this new law took effect, seven abortion clinics and one medical doctor (collectively Planned Parenthood)³ sued the State and others. Planned Parenthood alleged that the statute violated the Privacy Clause, which was added to the Florida Constitution in 1980. Located within the Declaration of Rights, the clause provides in full: 2. Specifically, the statute said, "No termination of pregnancy shall be performed on any human being in the third trimester of pregnancy unless one of [two] conditions is met." § 390.0111(1), Fla. Stat. (2021) (emphasis added). 3. The eight plaintiffs are Planned Parenthood of Southwest and Central Florida; Planned Parenthood of South, East, and North Florida; Gainesville Woman Care, LLC; A Woman's Choice of Jacksonville, Inc.; Indian Rocks Woman's Center, Inc.; St. Petersburg Woman's Health Center, Inc.; Tampa Woman's Health Center, Inc.; and Dr. Shelly Hsiao-Ying Tien. - 4

SECTION 23. Right of privacy.-Every natural person has the right to be let alone and free from governmental intrusion into the person's private life except as otherwise provided herein. This section shall not be construed to limit the public's right of access to public records and meetings as provided by law. With the complaint, Planned Parenthood filed a motion for temporary injunction, asking the trial court to block enforcement of the statute until it could rule on the merits of the constitutional challenge. In part, Planned Parenthood claimed that it was substantially likely to prevail in the lawsuit because it could demonstrate that the statute violates the Privacy Clause. In addition, Planned Parenthood argued that pregnant Floridians would be irreparably harmed absent a temporary injunction because the statute "would prohibit [them] from obtaining essential medical care and force them to remain pregnant and continue enduring the risks of pregnancy against their will." The statute, Planned Parenthood said, would also cause irreparable harm to itself and its staff by subjecting them to potential punitive consequences and interfering with the doctor-patient relationship. The State opposed Planned Parenthood's request for a temporary injunction. It argued that Planned Parenthood lacked - 5

standing to assert the privacy rights of its patients and, on the merits, could not establish any of the four requirements for a temporary injunction, let alone all four.4 After the State submitted its response, the U.S. Supreme Court issued a landmark decision on abortion in a case involving a Mississippi statute. See Dobbs v. Jackson Women's Health Org., 597 U.S. 215 (2022). In that decision, the Court ruled that the federal constitution does not guarantee a right to abortion. Id. at 231, 235-63, 292, 295. Based on this holding, the Court overturned Roe v. Wade, 410 U.S. 113 (1973), and Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833 (1992)—cases which had recognized a broad right to abortion under federal law. Dobbs, 597 U.S. at 292, 302 (expressly overruling Roe and Casey). In overruling those decisions, Dobbs "returned to the people and their elected representatives" "the authority to regulate abortion." Id. at 292. 4. Under Florida law, a party seeking a temporary injunction must prove four things: “(1) a substantial likelihood of success on the merits, (2) the unavailability of an adequate remedy at law, (3) irreparable harm absent entry of an injunction, and (4) that the injunction would serve the public interest." Fla. Dep't of Health v. Florigrown, LLC, 317 So. 3d 1101, 1110 (Fla. 2021). - 6

Several days after Dobbs issued, the trial court in this case held an evidentiary hearing on Planned Parenthood's motion for temporary injunction. Planned Parenthood called one witness and offered several exhibits. The State also presented witness testimony and documentary evidence. Deeming Planned Parenthood's evidence persuasive, the trial court entered a temporary injunction. It found that Planned Parenthood had third-party standing and satisfied all four temporary-injunction elements. In finding a likelihood of success on the merits, the court relied on our abortion jurisprudence. See generally T.W., 551 So. 2d at 1191-94 (Privacy Clause encompasses abortion); N. Fla. Women's Health, 866 So. 2d at 639 (reaffirming T.W.); Gainesville Woman Care, 210 So. 3d at 1246, 1253-55 (relying on T.W.). The court concluded that the statute was subject to strict scrutiny under that case law and determined that it either did not serve compelling interests or, in the alternative, was not the least restrictive means of achieving those interests. For the harm factor, the court ruled that both Planned Parenthood and its patients would suffer sufficient harm to support the requested relief. Rounding out its analysis, the court found no -7

adequate remedy at law and that an injunction would serve the public interests. The State appealed to the First District, triggering an automatic stay of the temporary injunction.5 Planned Parenthood asked the trial court and later the district court to vacate the automatic stay. Both courts, however, denied relief. State v. Planned Parenthood of Sw. & Cent. Fla., 342 So. 3d 863, 865-66 (Fla. 1st DCA 2022). As relevant here, in denying Planned Parenthood's motion to vacate, a divided panel of the First District held that Planned Parenthood could not establish irreparable harm as a result of the stay. Id. at 868-69. A few weeks later, the district court relied on essentially that same reasoning in reversing the temporary injunction—again, one judge dissented. State v. Planned Parenthood of Sw. & Cent. Fla., 344 So. 3d 637, 638 (Fla. 1st DCA 2022) ("[T]he non-final order granting the temporary injunction is reversed as [Planned Parenthood] could not assert irreparable harm on behalf of persons not appearing below."); id. (Kelsey, J., dissenting). 5. Fla. R. App. P. 9.310(b)(2) (automatic-stay provision triggered by filing of timely notice of appeal in certain situations). -8

Following these adverse rulings, Planned Parenthood asked us to review the First District's decisions, arguing that they conflict with our precedent. Accepting this jurisdictional argument, we granted review. II Planned Parenthood asks that we quash the district court's decisions and reinstate the temporary injunction. Relying on our precedent, it argues that the right to an abortion is secured by our constitution’s Privacy Clause. The State disputes Planned Parenthood's interpretation of the provision's text and asks us to reconsider our Privacy Clause jurisprudence or, at the very least, the abortion-related decisions. It argues that T.W.—our first case recognizing a right to abortion under the Privacy Clause-is flawed 6. In its brief, the State argues that Planned Parenthood lacks standing to challenge the new law. However, at oral argument, the Solicitor General urged us to decide this case on the merits. Oral Arg. at 50:52-51:06 (“We do think that the Court can assume for the sake of argument that the Plaintiffs have standing here and instead reach the merits. . . . That, I think, is what the Court should do.”). We view these statements as an abandonment of the State's standing argument. Thus, we proceed directly to the merits without passing upon any theory of standing articulated by the parties. - 9

in numerous respects, including that it failed to meaningfully consider the actual text of the provision at issue, failed to consider the history of the provision, and failed to give deference to the statute challenged in that case. Mindful of these fundamental concerns, we agree that our holding in T. W. should be reexamined.7 In T. W., this Court assessed a Privacy Clause challenge to a law that required unmarried minors to obtain parental consent or a substitute for consent to have an abortion. We held the challenged law to be incompatible with the protections afforded by the Privacy Clause, concluding that the right to abortion was embodied within the provision. T.W., 551 So. 2d at 1188, 1192-96; id. at 1197, 1201 7. As our discussion will show, we also emphasize the uniqueness of the competing interests implicated in abortion and the fact that the Supreme Court repudiated Roe and its underlying understanding of privacy. Because these factors relate to T. W. in a particularized way, we do not take up the State's invitation now to revisit the question of whether the Privacy Clause protects only "informational privacy" interests. Our jurisprudence before and after T. W. has understood the Privacy Clause to encompass certain decisional or autonomy rights, and today we do not revisit our precedents outside the abortion context. - 10

(Ehrlich, C.J., concurring specially).8 In the majority opinion, we discussed Roe v. Wade at length and ultimately adopted its definition of privacy along with its trimester and viability rules. See id. at 1190-94. Integral to the majority's analysis, T. W. emphasized recent Florida cases (primarily from the district courts) equating privacy with the right of personal decision-making in the specific context of refusing unwanted medical treatment. Id. at 1192. We also relied on Winfield v. Division of Pari-Mutuel Wagering, 477 So. 2d 544 (Fla. 1985)-a case involving privacy in financial institution records—to conclude that the provision “embraces more privacy interests" and "extends more protection to the individual in those interests, than does the federal Constitution." T.W., 551 So. 2d at 1192. Building on that, this Court made the following broad pronouncement: 8. Three justices, however, concluded that the challenged statute could be given a constitutional construction, though they accepted or assumed that the Privacy Clause conferred a right to abortion. T.W., 551 So. 2d at 1201-02 (Overton, J., concurring in part and dissenting in part); id. at 1202-04 (Grimes, J., concurring in part and dissenting in part); id. at 1204-05 (McDonald, J., dissenting). - 11 -

Florida's privacy provision is clearly implicated in a woman's decision of whether or not to continue her pregnancy. We can conceive of few more personal or private decisions concerning one's body that one can make in the course of a lifetime, except perhaps the decision of the terminally ill in their choice of whether to discontinue necessary medical treatment. Of all decisions a person makes about his or her body, the most profound and intimate relate to two sets of ultimate questions: first, whether, when, and how one's body is to become the vehicle for another human being's creation; second, when and how-this time there is no question of "whether"-one's body is to terminate its organic life. [Laurence H.] Tribe, American Constitutional Law 133738 (2d ed. 1988). The decision whether to obtain an abortion is fraught with specific physical, psychological, and economic implications of a uniquely personal nature for each woman. See Roe, 410 U.S. at 153. The Florida Constitution embodies the principle that “[f]ew decisions are more personal and intimate, more properly private, or more basic to individual dignity and autonomy, than a woman's decision . . . whether to end her pregnancy. A woman's right to make that choice freely is fundamental.” T.W., 551 So. 2d at 1192-93 (second alteration in original) (some citations omitted). This pronouncement was flawed in several respects. T. W. associated the language of the Privacy Clause with Roe's understanding of privacy; but it did not justify how that concept of privacy aligned with our constitution's text—i.e., “the right to be let alone and free from government intrusion into private life." T. W. - 12 -

also did not ask how Florida voters would have understood the text of the provision and how that understanding would be informed by Florida's long history of proscribing abortion. As a result of its analytical path, T. W. did not look to dictionaries, contextual clues, or historical sources bearing on the text's meaning. Instead, overlooking all these probative sources, it adopted Roe's notions of privacy and its trimester framework as matters of Florida constitutional law.9 Compounding these errors, the T.W. majority failed to apply longstanding principles of judicial deference to legislative enactments and failed to analyze whether the statute should be given the benefit of a presumption of constitutionality. Since Roe featured prominently in T. W., we think it fair to also point out that the T. W. majority did not examine or offer a reasoned response to the existing criticism of that decision or consider 9. In his dissent, Justice Labarga emphasizes "that T. W. was decided on state law grounds." Dissenting op. at 90. We agree that T.W. was not applying federal law to the challenged statute. However, T.W. relied heavily on Roe in interpreting the meaning of our constitution's Privacy Clause. Indeed, T. W. cited Roe over twenty times, it accepted Roe's concept of privacy without analysis, and it enacted a viability-trimester system that closely paralleled Roe's, without citing to any Florida precedent supporting that framework. - 13 -

whether it was doctrinally coherent. This was a significant misstep because Roe did not provide a settled definition of privacy rights. Controversial from the moment it was released, “Roe's constitutional analysis was far outside the bounds of any reasonable interpretation of the various constitutional provisions to which it vaguely pointed." Dobbs, 597 U.S. at 268. What's more, Roe "failed to ground its decision in text, history, or precedent.” Id. at 270. This left even progressive legal scholars baffled at how such a right could be gleaned from the constitution's text. Akhil R. Amar, Intratextualism, 112 Harv. L. Rev. 747, 778 (1999) ("As a precedent-follower, Roe simply stringcites a series of privacy cases involving marriage, procreation, contraception, bedroom reading, education, and other assorted topics, and then abruptly announces with no doctrinal analysis that this privacy right is broad enough to encompass' abortion. . . . But as the Court itself admits a few pages later [in the opinion], the existence of the living fetus makes the case at hand ‘inherently different’ . . . from every single one of these earlier-invoked cases. And as a precedent-setter, the Court creates an elaborate trimester framework that has struck many critics as visibly (indeed, nakedly) . . . more legislative than - 14 -

judicial." (footnotes omitted)); see also Laurence H. Tribe, Foreword: Toward a Model of Roles in the Due Process of Life and Law, 87 Harv. L. Rev. 1, 4 (1973) (noting that "[o]ne reads the Court's explanation [of the viability line] several times before becoming convinced that nothing has inadvertently been omitted”). Indeed, just three years after T.W. (and well before Dobbs), the U.S. Supreme Court abandoned Roe's position that the right to abortion was grounded in any sort of privacy right. See Casey, 505 U.S. at 846 (joint opinion) (“Constitutional protection of the woman's decision to terminate her pregnancy derives from the Due Process Clause of the Fourteenth Amendment."); cf. Dobbs, 597 U.S. at 279 ("The Court [in Casey] abandoned any reliance on a privacy right and instead grounded the abortion right entirely on the Fourteenth Amendment's Due Process Clause."). This demonstrates the tenuous connection between “privacy” and abortion an issue that, unlike other privacy matters, directly implicates the interests of both developing human life and the pregnant woman. In light of T. W.'s analytical deficiencies and subsequent U.S. Supreme Court decisions rejecting the Roe framework on which - 15 -

T.W.'s reasoning depended, our assessment of the challenged statute requires us to examine the Privacy Clause and, for the first time in the abortion context, consider the original public meaning of the text as it was understood by Florida voters in 1980.10 III A We begin by recognizing the standard that governs our review. Because this case requires us to review both “the constitutionality of a statute and the interpretation of a provision of the Florida Constitution," our review is de novo. Lewis v. Leon Cnty., 73 So. 3d 151, 153 (Fla. 2011) (citing Crist v. Fla. Ass’n of Crim. Def. Laws., Inc., 978 So. 2d 134, 139 (Fla. 2008)); see also Florigrown, LLC, 317 So. 3d at 1110. We have long recognized that “statutes come clothed with a presumption of constitutionality and must be construed whenever possible to effect a constitutional outcome." Lewis, 73 So. 3d at 10. We decided two other significant cases involving abortion after T. W., but in those cases, we did not provide additional doctrinal justifications for T.W.'s adoption of Roe's privacy framework. - 16

153 (citing Fla. Dep't of Revenue v. City of Gainesville, 918 So. 2d 250, 256 (Fla. 2005)). Indeed, nearly a century ago, we said: (1) On its face every act of the Legislature is presumed to be constitutional; (2) every doubt as to its constitutionality must be resolved in its favor; [and] (3) if the act admits of two interpretations, one of which would lead to its constitutionality and the other to its unconstitutionality, the former rather than the latter must be adopted . . . Gray v. Cent. Fla. Lumber Co., 140 So. 320, 323 (Fla. 1932); see also Savage v. Bd. of Pub. Instruction for Hillsborough Cnty., 133 So. 341, 344 (Fla. 1931); Chatlos v. Overstreet, 124 So. 2d 1, 2 (Fla. 1960); In re Caldwell's Estate, 247 So. 2d 1, 3 (Fla. 1971); Franklin v. State, 887 So. 2d 1063, 1073 (Fla. 2004); Florigrown, LLC, 317 So. 3d at 1111; Statler v. State, 349 So. 3d 873, 884 (Fla. 2022). And to overcome the presumption of constitutionality, “the invalidity must appear beyond reasonable doubt." Franklin, 887 So. 2d at 1073 (quoting State ex rel. Flink v. Canova, 94 So. 2d 181, 184 (Fla. 1957)); see also Waybright v. Duval Cnty., 196 So. 430, 432 (Fla. 1940) ("[W]e will . . . determine if, beyond a reasonable doubt, violence was done [to] any provisions of the organic law in the passage of the challenged act, and in doing so will not deal with the - 17 -

merits of the measure, that being the exclusive concern of the Legislature."). B Our approach to interpreting the constitution reflects a commitment to the supremacy-of-text principle, “recognizing that '[t]he words of a governing text are of paramount concern, and what they convey, in their context, is what the text means. Coates v. R.J. Reynolds Tobacco Co., 365 So. 3d 353, 354 (Fla. 2023) (alteration in original) (quoting Levy v. Levy, 326 So. 3d 678, 681 (Fla. 2021)) (interpreting statutory text); see also Advisory Op. to Governor re Implementation of Amend. 4, The Voting Restoration Amend. (Amendment 4), 288 So. 3d 1070, 1081 (Fla. 2020) (interpreting constitutional text). The goal of this approach is to ascertain the original, public meaning of a constitutional provision-in other words, the meaning as understood by its ratifiers at the time of its adoption. See City of Tallahassee v. Fla. Police Benevolent Ass'n, Inc., 375 So. 3d 178, 183 (Fla. 2023) ("[W]e give the words of the constitution their plain, usual, ordinary, and commonly accepted meanings at the time they were written.”). In construing the meaning of a constitutional provision, we do not - 18 - 999

seek the original intent of the voters or the framers. Instead, we ask how the public would have understood the meaning of the text in its full context when the voters ratified it. See Amendment 4, 288 So. 3d at 1081-82. To answer this question of public meaning, we consider the text, see Alachua Cnty. v. Watson, 333 So. 3d 162, 169-70 (Fla. 2022), contextual clues, see id., dictionaries, see Somers v. United States, 355 So. 3d 887, 891 (Fla. 2022), canons of construction, see Conage v. United States, 346 So. 3d 594, 598-99 (Fla. 2022), and historical sources, including evidence related to public discussion, see Tomlinson v. State, 369 So. 3d 1142, 1147-51 (Fla. 2023); Dist. of Columbia v. Heller, 554 U.S. 570, 614 (2008). IV With these background principles fixed, we now focus our attention on the Privacy Clause itself. Article I, section 23 is entitled: "Right of privacy." Our constitution, though, tells us that in construing the meaning of constitutional text, we are not to use titles and subtitles. See art. X, § 12(h), Fla. Const. Accordingly, we look at the operative text, which guarantees the right “to be let - 19 -

alone and free from governmental intrusion into the person's private life." Art. I, § 23. As is apparent at first glance, the provision does not explicitly reference abortion at all. Thus, if Planned Parenthood is to prevail, we must find that the public would have understood the principle embodied in the operative text to encompass abortion, even though the clause itself says nothing about it. To this end, the parties have marshaled era-appropriate dictionary definitions of key terms in the Privacy Clause. Based on the dictionaries we consulted, we know that in 1980 the right to be "let alone" could be defined as the right to be left "in solitude," free from outside "interfer[ence]” or “attention." See Let Alone, Oxford English Dictionary 213 (1st ed. 1933) (reprinted in 1978). And the latter phrase "free from governmental intrusion” into “private life”—can convey a similar meaning. “Intrusion” meant “[i]llegal entry upon or appropriation." Intrusion, American Heritage Dictionary of the English Language 688 (1st ed. 1969); see also Intrusion, American Heritage Dictionary 674 (2d Coll. ed. 1982) (same); Intrude, American Heritage Dictionary of the English Language 687 (1st ed. 1969) ("To interpose (oneself or something) - 20 -

without invitation, fitness, or leave."); Intrude, American Heritage Dictionary 674 (2d Coll. ed. 1982) (similar). And the word "private" carried the idea of being "[s]ecluded from the sight, presence, or intrusion of others," the chief example being “a private bathroom." Private, American Heritage Dictionary of the English Language 1042 (1st ed. 1969); Private, American Heritage Dictionary 986 (2d Coll. ed. 1982) (same). These accepted definitions do not seem to us to be natural ways of describing the abortion procedures of 1980. The decision to have an abortion may have been made in solitude, but the procedure itself included medical intervention and required both the presence and intrusion of others. See, e.g., Roe, 410 U.S. at 172 (Rehnquist, J., dissenting) (“A transaction resulting in an operation such as [abortion] is not 'private' in the ordinary usage of that word."); Thornburgh v. Am. Coll. of Obstetricians & Gynecologists, 476 U.S. 747, 792 (1986) (White, J., dissenting) (noting that even the Roe majority recognized a "pregnant woman cannot be isolated in her privacy” because “the termination of a - 21

pregnancy typically involves the destruction of another entity: the fetus" (quoting Roe, 410 U.S. at 159)).11 Next, we see if contextual clues could offer guidance. Looking at the complete text of the provision allows us to consider the physical and logical relation of its parts, as they might have been viewed by a voter. See Lab'y Corp. of Am. v. Davis, 339 So. 3d 318, 324 (Fla. 2022). 11. The dissent cites Griswold v. Connecticut, 381 U.S. 479 (1965) (invalidating on privacy grounds a state law criminalizing the use of contraception in the marital context), to support the assertion that the involvement of others does not prevent an activity or procedure from being a private matter. Dissenting op. at 67-68 (stressing that the law at issue in Griswold “operate[d] directly on an intimate relation of husband and wife and their physician's role in one aspect of that relation" (quoting Griswold, 381 U.S. at 482)). But the Court in Griswold "only invalidated the section of the state law which prohibited the use of contraception, rather than outlawing the manufacture, distribution, or sale of contraceptives." Alyson M. Cox & O. Carter Snead, “Grievously and Egregiously Wrong": American Abortion Jurisprudence, 26 Tex. Rev. L. & Pol. 1, 16-17 (2022). Indeed, as we noted above, Roe itself acknowledged that abortion was "inherently different" from the situations involved in cases like Griswold. Roe, 410 U.S. at 159. Thus, we do not share the dissent's concern "that parties will rely on the majority's reasoning that the involvement of 'others' in an abortion procedure defeats privacy—in attempts to undermine the broad privacy protections that are extended in the medical context.” Dissenting op. at 68. - 22

The first sentence sets forth the protected right, i.e., "to be let alone and free from governmental intrusion into . . . private life." The second sentence then provides that “[t]his section shall not be construed to limit the public's right of access to public records and meetings as provided by law." Art. I, § 23. By its terms, this latter sentence covers “public records and meetings.” That phrase which relates only to accessing public informationdoes not implicate or apply to the subject of abortion. We do not give great weight to this observation, but we note it here to emphasize that contextual clues do not lend support to a claim that voters clearly understood abortion to be part and parcel of the rights recognized in the Privacy Clause. V Dictionary definitions and immediate context, although informative, do not provide a full picture of the text's meaning. We also consider the historical background of the phrases contained within the operative text. See Tomlinson, 369 So. 3d at 1146 ("[W]hen (as often happens) a word had more than one accepted meaning at that time, we decide which one is the law by looking to the context in which it appears, and what history tells us about - 23 -

how it got there."); Antonin Scalia & Bryan Garner, Reading Law: The Interpretation of Legal Texts 33 (2012) ("[C]ontext embraces not just textual purpose but also . . . a word's historical associations acquired from recurrent patterns of past usage . ."); see also Heller, 554 U.S. at 605 (noting the critical importance in constitutional interpretation of examining “a variety of legal and other sources to determine the public understanding of a legal text in the period after its enactment or ratification"); TransUnion LLC v. Ramirez, 594 U.S. 413, 424 (2021) (relying on historical sources in determining constitutional text's meaning); N.Y. State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1, 26-27 (2022) (historical sources integral to Court's holding). A Before examining the Privacy Clause's specific history and public debate, we explore the settled use of the "right to be let alone" in the context of Florida law, cognizant that technical meanings might bear upon the public understanding of the constitutional text. 12 12. In construing constitutional provisions that have an acquired meaning, “[w]e cannot understand these provisions unless - 24

The phrase "to be let alone" carries with it a rich legal tradition. In Cason v. Baskin, we discussed the common-law right to privacy and explained that in substance it was "the right to be let alone, the right to live in a community without being held up to the public gaze if you don't want to be held up to the public gaze." 20 So. 2d 243, 248 (Fla. 1944) (quoting Laurence H. Eldredge, Modern Tort Problems 77 (1941)).¹3 This right “to be let alone,” which was we understand their history; and when we find them expressed in technical words, and words of art, we must suppose these words to be employed in their technical sense." Thomas M. Cooley, A Treatise on the Constitutional Limitations which Rest upon the Legislative Power of the States of the American Union 93-94 (7th ed. 1903). Indeed, “[t]he technical sense in these cases is the sense popularly understood, because that is the sense fixed upon the words in legal and constitutional history where they have been employed for the protection of popular rights." Id. at 94 (emphasis added). 13. We recognize that this phrase “the right to be let alone” is likely sourced from the seminal 1890 law-review article, The Right to Privacy. Samuel D. Warren & Louis D. Brandeis, The Right to Privacy, 4 Harv. L. Rev. 193 (1890); cf. Stall v. State, 570 So. 2d 257, 265 (Fla. 1990) (Kogan, J., dissenting) (recognizing significance of this article). The authors of that article elaborated on the "right to be let alone" and free from “intrusion upon the domestic circle." Warren & Brandeis, supra, at 195-96 (borrowing label for this right from a tort treatise by Judge Thomas Cooley). The right, however, “had little to do with the autonomy of an individual to make decisions . . . free from government control." Jeffrey M. Shaman, The Right of Privacy in State Constitutional Law, 37 Rutgers L.J. 971, 990 (2006). It described a "different sort of privacy"-one - 25 -

often used interchangeably with the "right to privacy," was a prominent feature in Florida tort law. See, e.g., Battaglia v. Adams, 164 So. 2d 195, 197 (Fla. 1964) (“An unauthorized use of a person's name in this respect is recognized as a violation of his right of privacy."); Jacova v. S. Radio & Television Co., 83 So. 2d 34, 36 (Fla. 1955) (reiterating that Florida recognized a common-law claim for invasion of privacy and noting that "[when] one, whether willingly or not, becomes an actor in an occurrence of public or general interest,” “he emerges from his seclusion, and it is not an invasion of his right of privacy' to publish his photograph with an account of such occurrence" (quoting Metter v. L.A. Exam'r, 95 P.2d 491, 494 (Cal. Ct. App. 1939))); Harms v. Mia. Daily News, Inc., 127 So. 2d 715, 717 (Fla. 3d DCA 1961) (noting in the tort context that "[t]he "directed to keeping personal information from being exposed to the public, rather than to keeping decision-making within the control of an individual." Id. To Warren and Brandeis, the “right to be let alone" and free from “intrusion" safe-guarded against the publication of private facts. Warren & Brandeis, supra, at 195-96, 207-12. - 26

right of privacy is defined as the right of an individual to be let alone and to live a life free from unwarranted publicity"). 14 Significantly, throughout the decades in which the "right to be let alone" was developed and applied in Florida, two distinct propositions were true in the law and harmonious: first, the right "to be let alone” existed and had a discernable and enforceable meaning; and second, the Legislature had the authority to comprehensively regulate abortion before and after viability. Indeed, from at least 1868 to 1972, abortion was for the most part prohibited in our state. 15 And although litigants, prior to the 14. Florida law in this respect appears consistent with that of other jurisdictions. See W.E. Shipley, Annotation, Right of Privacy, 14 A.L.R.2d 750 (1950) (noting acts of intrusion into one's private affairs may also constitute violations of the right of privacy, such as eavesdropping, examination of private records or papers, or publications of personal material identified with the complainant as would using the complainant's name or likeness in almost any form of distributive publication). 15. See ch. 1637, subc. 3, § 11, subc. 8, § 9, Laws of Fla. (1868) (outlawing most abortions); Rev. St. 1892, §§ 2387, 2618 (same); §§ 782.10, 797.01, Fla. Stat. (1941) (repealed 1972) (same); §§ 782.10, 797.01, Fla. Stat. (1971) (repealed 1972) (same). In 1972, this Court determined that the abortion statute in effect at that time was unconstitutionally vague. State v. Barquet, 262 So. 2d 431, 438 (Fla. 1972). Immediately following that decision, the Legislature passed a more specific law, still banning abortion at all times during pregnancy except in certain limited circumstances. - 27 -

adoption of the Privacy Clause, sought to curtail government action by arguing they had the "right to be let alone," we are not aware of litigants invoking that particular right to challenge abortion restrictions in Florida. We also stress that this “right to be let alone” was modified by a limiting principle: the right did not permit an individual to inflict harm on herself or others. See State v. Eitel, 227 So. 2d 489, 491 (Fla. 1969) (rejecting a challenge to helmet laws based on a right "to be let alone," stressing that "no person is an entirely isolated being" and that “it is impossible for a person to do anything seriously or permanently hurtful to himself, without mischief reaching at least to his near connections, and often far beyond them") (cleaned up). Indeed, our Privacy Clause jurisprudence outside the abortion context recognizes that the right does not authorize harm to third parties. See, e.g., Beagle v. Beagle, 678 So. 2d 1271, 1276 (Fla. 1996) (parents' privacy right to raise their children yields to need to protect children from harm). Because the "right to be let alone" was limited in this way, it is not surprising that when litigants Ch. 72-196, § 2, Laws of Fla. (codified at section 458.22 of the Florida Statutes (Supp. 1972)) (repealed 1976). - 28

challenged the 1972 abortion statute in this Court, they did not do so based on the "right to be let alone." Instead, they argued a right to privacy grounded in substantive due process under the Fourteenth Amendment to the United States Constitution. See Barquet, 262 So. 2d at 434. B We also acknowledge that the public understanding of the term "privacy" was, to some extent, informed by the U.S. Supreme Court's 1973 decision in Roe v. Wade. Following that decision, the phrase “right to privacy” gained new connotations that, for the first time, included the choice to have an abortion. See Roe, 410 U.S. at 154 ("We, therefore, conclude that the right of personal privacy includes the abortion decision .”). In Planned Parenthood's view, this aspect of federal privacy jurisprudence should control our analysis here. Specifically, Planned Parenthood argues that Florida voters would have internalized Roe's definition of privacy when they voted for the privacy amendment. Indeed, Planned Parenthood has repeatedly asserted that the public understanding of this privacy definition was so engrained by 1980 that even without a specific mention of the term abortion, the Privacy Clause unequivocally - 29 -

included such a right by implication. Agreeing with this argument, the dissent cites case law, newspaper articles, a news clip, and more to support the contention that Americans, and Floridians in particular, would have naturally understood privacy to encompass abortion. 16 Though this argument has some force, we cannot agree with Planned Parenthood or the dissent that the backdrop of Roe conclusively establishes how a voter would have understood the provision. In Roe, the Supreme Court did not consider language comparable to the operative text of Florida's Privacy Clause-that is, the “right to be let alone.” That phrase is found only once in Roe, and that single mention is in Justice Stewart's concurrence quoting Katz v. United States, 389 U.S. 347 (1967), in support of the proposition that there is no federal right to privacy. Roe, 410 U.S. 16. This evidence consists primarily of media coverage surrounding the Roe decision and subsequent evidence that discussed the abortion debate and associated a right of privacy with abortion. We accept that Roe had some bearing on the public's understanding of privacy rights in 1980. But, unlike the dissent, we do not find that it is dispositive. We are unwilling to disregard other probative evidence of public meaning, much of which is focused specifically on the amendment itself. The dissent, in our view, gives little attention to such evidence. - 30

at 167 n.2 (Stewart, J., concurring). So, while the Roe majority may have deemed abortion to be part of a “right to privacy," it would require an analytical leap to say that the public would have instinctively associated “the right to be let alone and free from governmental interference into one's private life" with abortion. E.g., Louis Henkin, Privacy and Autonomy, 74 Colum. L. Rev. 1410, 1424 (1974) (decisional autonomy “is not at all what most people mean by privacy,” which instead concerns “my freedom from official intrusion into my home, my person, my papers, my telephone”). This point is reinforced by the fact that the specific phrase used in the Privacy Clause had a consistent meaning in Florida law and had never once been interpreted to cover abortion rights. And as a final point here, we reiterate that Roe did not settle the scope of privacy rights as Planned Parenthood insists. As we discussed earlier, Roe's privacy-based reasoning was questioned soon after the opinion issued and was eventually rejected in a decision that completely detached abortion rights from the concept of privacy. See Casey, 505 U.S. at 846 (joint opinion). Thus, even if it is possible that voters would have understood the Privacy Clause to protect certain individual autonomy interests, it is by no means - 31

clear that those interests would have included the controversial subject of abortion, which uniquely involves the interests of prenatal life. Consequently, while Roe is relevant to our analysis of public meaning, it is not dispositive. Having considered dictionary definitions, context, and technical meanings that could have informed the original public meaning, we now turn to a critical piece of our historical analysis where we answer the following relevant questions: How did this provision make its way to the ballot, what was the focus of the debate surrounding its adoption, and how were the issues framed for the voters? C The origin of our Privacy Clause traces back to the work of a constitution revision commission in the late 1970s. As part of its work, the commission held public meetings throughout Florida and listened to the public's views and concerns. See Daniel R. Gordon, Upside Down Intentions: Weakening the State Constitutional Right to Privacy, a Florida Story of Intrigue and a Lack of Historical Integrity, 71 Temp. L. Rev. 579, 588 (1998); Transcript of Fla. C.R.C. proceedings at D:003272-73 (Jan. 9, 1978) (discussion of - 32 -

committee's work regarding privacy proposal). Eventually, the commission agreed upon the following language: Every natural person has the right to be let alone and free from governmental intrusion into his private life except as otherwise provided herein. Patricia A. Dore, Of Rights Lost and Gained, 6 Fla. St. U. L. Rev. 609, 650 n.248 (1978) (quoting Fla. C.R.C., Rev. Fla. Const. art. I, § 23 (May 11, 1978)). That proposed amendment, along with roughly 80 others, was submitted to the public as a package deal in the 1978 election. Gordon, supra, at 588. This package, in addition to containing the privacy proposal, also included amendments ensuring access to (1) public records, (2) meetings of non-judicial public bodies, (3) judicial hearings and records, and (4) proceedings and records of the judicial nominating commissions. Gerald B. Cope, Jr., To Be Let Alone: Florida's Proposed Right of Privacy, 6 Fla. St. U. L. Rev. 671, 675-77 (1978). Of note, proposals specifically addressing state abortion rights were rejected by the commissioners and never made it to the ballot. See Fla. Const. Revision Comm'n, Summary of Proposed Revisions to the Florida Constitution 1-2 (Sept. 27, 1977) (available in the Florida State University College of Law Research - 33 -

Center); cf. Mary Ann Lindley, A New Constitution Takes Shape, Palm Beach Post-Times, Apr. 9, 1978, at D1. For our purposes, though, we focus on statements made by commissioners in describing the reason or need for the proposal.17 On this subject, Justice Overton said: [W]ho, ten years ago, really understood that personal and financial data on a substantial part of our population could be collected by government or business and held for easy distribution by computer operated information systems? There is a public concern about how personal information concerning an individual citizen is used, whether it be collected by government or by business. The subject of individual privacy and privacy law is in a developing stage. . . . It is a new problem that should probably be addressed. Transcript of Fla. C.R.C. proceedings D:000020-21 (July 6, 1977). 17. See McDonald v. City of Chicago, 561 U.S. 742, 828-29 (2010) (Thomas, J., concurring in part and concurring in the judgment) (“When interpreting constitutional text, the goal is to discern the most likely public understanding of a particular provision at the time it was adopted. Statements by legislators can assist in this process to the extent they demonstrate the manner in which the public used or understood a particular word or phrase. They can further assist to the extent there is evidence that these statements were disseminated to the public. In other words, this evidence is useful not because it demonstrates what the draftsmen of the text may have been thinking, but only insofar as it illuminates what the public understood the words chosen by the draftsmen to mean.”). - 34 -

Justice Overton was not alone in this respect. Commissioner Jon Moyle (sponsor of the privacy proposal) spoke of government surveillance, technological advances, and society's dependence on such technology—characterizing them as threats to an individual's privacy. Transcript of Fla. C.R.C. proceedings at D:003273, 327678 (Jan. 9, 1978). He also noted that records about private life were becoming more common. Id. at D:003277-81. According to him, states were “very much involved in the business of keeping records about their residents.” Id. at D:003276. But the states, in his view, had not done “their part” in protecting such records. Id. at D:003277. In line with Commissioner Moyle's sentiments, Commissioners Lew Brantley and Dexter Douglass both noted specific government-surveillance efforts as sources of privacy concerns. Id. at D:003325 (remarks of Lew Brantley); id. at D:003336 (remarks of Dexter Douglass). This historical survey is illustrative of the commission's focus in terms of privacy. Various commissioners publicly expressed concern for informational privacy. However, as best as we can tell from their statements, that pressing concern did not extend to abortion. - 35

The proposals failed, and less than two years later, we held that there was no state constitutional right of privacy that would prevent public disclosure of confidential papers prepared by a consultant for an electric authority. Shevin v. Byron, Harless, Schaffer, Reid & Assocs., Inc., 379 So. 2d 633, 639 (Fla. 1980); cf. Laird v. State, 342 So. 2d 962, 963 (Fla. 1977) (no constitutional right of privacy to smoke marijuana in confines of home). Months after Shevin was decided, the Legislature revived the idea of a privacy clause and ultimately agreed on a proposal that said: Every natural person has the right to be let alone and free from governmental intrusion into [the person's] private life except as otherwise provided herein. This section shall not be construed to limit the public's right of access to public records and meetings as provided by law. Editorial, Guaranteeing Our Privacy, Boca Raton News, Oct. 29, 1980, at 6A (setting forth language to appear on 1980 ballot); Patrick McMahon, State Constitutional Amendments, St. Petersburg Times, Oct. 30, 1980, at 22 (noting ballot title). In overwhelming numbers, legislators from both political parties voted to approve it for placement on the ballot. Out of the - 36

138 legislators who voted on it, only 6 did not support the proposal. See Lorraine Cichowski, House Votes to Propose Guaranteeing Right to Privacy, Fort Myers News-Press, May 7, 1980, at 8B; Jim Walker, Senators Clash over Privacy Amendment, Tampa Tribune, May 15, 1980, at 6-A. Of additional note, during the floor debate, there was virtually no discussion of abortion. And when abortion was brought up, the Senate sponsor assured other senators that the proposal would have no effect on that subject. Audio Tape: Proceedings of the Fla. S., Tape 2 at 17:40 (May 14, 1980) (available at Fla. Dep't of State, Fla. State Archives, Tallahassee, Fla., Series S1238, Box 57). As best as we can tell, no commissioner or legislator ever claimed (at least publicly between 1977-80) that abortion was part of the rights guaranteed by the Privacy Clause.¹8 See, e.g., Gordon, 18. To the extent that Planned Parenthood relies on Representative Jon Mills's later statement in the 1990s that he subjectively hoped that the privacy proposal would cover abortion, such reliance is misplaced. See Heller, 554 U.S. at 577 (proper approach to interpretation does not consider hidden or secret meaning "that would not have been known to ordinary citizens in the founding generation”). Similarly, Planned Parenthood and one amicus misplace reliance on how voters handled two later proposed amendments—one in 2004 and the other in 2012. The understanding of voters over 20 years after the privacy amendment offers little value in determining what the voters in 1980 would have understood the privacy proposal to mean. Indeed, at oral - 37 -

supra, at 590 n.148 ("Nowhere did revision commissioners in 1978 refer to abortion . ."). Indeed, Planned Parenthood does not claim otherwise. D Like the history of the privacy proposal, the public debate surrounding the amendment also did not focus on abortion. Once the privacy proposal was approved for placement on the ballot in 1980, the public engaged in significant and robust debate over whether that proposal should be approved. Advocates for homosexual rights, proponents of legalized marijuana use, and various editorial boards advocated in favor of the amendment. Mary Hladky, Commissioners Table Vote on State Privacy Amendment, Fort Lauderdale News, Oct. 1, 1980, at 8B; Mary Lavers, Privacy Amendment Advocated by Kunst, Tampa Times, Oct. 23, 1980, at 10-A; Associated Press, Privacy Amendment Caught in Swirl of Controversy, Sentinel Star (Orlando), Oct. 24, 1980, at 2-C; Editorial, Amendment 2-Vote Yes, argument, Planned Parenthood conceded as much. See Oral Arg. at 22:59-23:02 (“2012 isn't evidence of what [the privacy amendment] meant in 1980.”). - 38 -

Bradenton Herald, Nov. 1, 1980, at A-4; Craig Matsuda, State Questions Are a Mix of Roads, Water, Privacy, Miami Herald, Nov. 2, 1980, at 8E; Amendments, St. Petersburg Times, Nov. 1, 1980, at 12B. These groups presented sweeping views of what the amendment would accomplish. Some, for instance, claimed that the amendment would decriminalize marijuana as well as certain intimate sexual conduct occurring inside the confines of a home. Julius Karash, Psychologist Stumps for Amendment, News-Press Local, Oct. 3, 1980, at B1; Steve Piacente, Gay Rights Activist Speaks for Privacy Act, Tampa Tribune, Oct. 24, 1980, at 2-B. Opponents of the measure included some political conservatives, various law enforcement officers, an association of prosecutors, and the then-serving governor. Prosecutors Condemn Privacy Amendment, Florida Today, Oct. 28, 1980, at 4B; Attorneys' Group Fights Privacy Amendment, Palm Beach Post, Oct. 28, 1980, at B26; Amendments under Attack as Vote Nears, Bradenton Herald, Oct. 29, 1980, at B-5; Graham Hit on Privacy, Florida Today, Oct. 29, 1980, at 6B; Amendment Opposition by Graham Criticized, Palm Beach Post, Oct. 29, 1980, at A11; Lawyer Raps Constitution Revision Plan, Fort Lauderdale News, Oct. 29, 1980, at 17A; Michael - 39 -

Harrell, Advertisement, Fort Lauderdale News, Oct. 29, 1980, at 16A; Amendments, St. Petersburg Times, Nov. 1, 1980, at 12B. Some opponents expressed concern that the open-ended language would permit courts to expansively interpret the amendment. Sensing that growing concern, House sponsors of the privacy proposal weighed in on the public debate. Taking to the newspapers, they reassured the public that concerns about whether the amendment would accomplish sweeping policy changes were unfounded. For instance, sponsors said that the proposed amendment arose from concerns “about technological advances that could enable the government to compile extensive computer files on citizens." Privacy Amendment Caught in Swirl of Controversy, supra, at 2-C; see also Associated Press, Privacy Measure Stirs Controversy, Pensacola News-Journal, Nov. 2, 1980, at 14C. Indeed, one sponsor said that the proposal was "necessary to ward off a growing government whose curiosity about people's private lives also is increasing." R. Michael Anderson, Amendment Guaranteeing Right to Privacy Debated, Florida Times-Union Jacksonville Journal, Oct. 26, 1980, at B-1. That same sponsor characterized the proposal as "quite conservative," predicting that - 40 -

"Florida judges wouldn't use it to overturn many existing laws." Privacy Amendment Caught in Swirl of Controversy, supra, at 2-C. And the other sponsor called expansive views of the proposed amendment “garbage.” See id. Of note, in looking at the extensive discussion surrounding the privacy amendment, little to nothing was said about abortion in print or in public comment. The debate-as framed to the publicoverwhelmingly associated the Privacy Clause's terms with concerns related to government surveillance and disclosure of private information to the public. Consistent with this observation, prolife and prochoice groups did not join in the fray. These groups are not politically bashfulnot now, and not in 1980. If the public understanding of the privacy proposal was that it included a silent-but almost unfettered-right to abortion, we would expect such groups to have engaged in the robust public debate. But based on all sources brought to our attention, we simply see no evidence of that. See James W. Fox, Jr., A Historical and Originalist Defense of Abortion in Florida, 75 Rutgers U. L. Rev. 393, 443-44 (2023) (acknowledging that these groups were silent on this topic; but - 41 -

discounting significance of such fact); cf. Oral Arg. at 13:02-13:39 (counsel for Planned Parenthood acknowledging that silence in the historical record). The dissent downplays the significance of this scope-of-debate evidence. Dissenting op. at 86. Accepting the logic of a law review article, the dissent claims that “[a]bortion would only have been debated if its coverage within the right to privacy were in dispute or were not yet established in law." Dissenting op. at 86 (quoting Fox, supra, at 442-43). We, however, cannot agree with this speculation. A person's understanding of the amendment's purpose would certainly inform whether he or she supported the adoption of the amendment. And, critically, it would inform how that person would persuade others to adopt their position. The debate over the privacy amendment was vigorous, yet there is virtually no evidence that anyone publicly connected the privacy amendment proposal with abortion rights. And as referenced by the dissent, newspapers during this same period were still discussing the controversy surrounding abortion, so it was far from a settled issue. Dissenting op. at 81-82 (noting that "Florida newspapers" in 1980 "covered statements by pro-choice activists and by pro-life activists" - 42 -

involving the abortion debate). We are unwilling to presume, as the dissent does, that abortion was so intertwined with the term "privacy" and so unquestionably accepted by society that its complete absence from the public debate surrounding this amendment should be expected. In sum, the scope of the privacy-proposal debate, both in terms of topics and participants, underscores that the public would not have understood, or assumed, the language of the Privacy Clause to encompass abortion. E Finally, we consider two additional sources of historical evidence, both of which show a contemporaneous understanding that the Privacy Clause did not enshrine abortion rights in our constitution. The first is concurrent legislative action. There were several Florida statutes passed between 1978 and 1980 regulating or restricting access to abortion in substantial ways. See ch. 78382, §§ 2, 4-10, Laws of Fla. (empowering Department of Health and Rehabilitative Services to create rules regulating abortion clinics; setting forth licensing requirement and framework; prohibiting abortion by unlicensed clinics); ch. 79-302, § 1, Laws of - 43 -

Fla. (requiring parental consent for unmarried minors); ch. 80-208, § 1, Laws of Fla. (fetal remains to be disposed of in "sanitary and appropriate manner"; establishing crime for violations of this standard); ch. 80-413, § 1, Laws of Fla. (additional regulations on abortion clinics; imposing standard governing disposal of fetal remains); cf. Amicus Brief of Former State Representative John Grant at 25-28 (noting concurrent legislation on abortionparticularly the abortion law passed during the same session as the privacy proposal). Based on this significant body of abortion regulation—some of which would be struck down as violative of Roe¹⁹ it seems unlikely to us that the Legislature in 1980 would put to the people a proposal crafted to imperil that recent work. The second source of evidence is what legislators of the time expressed with respect to adding a right-to-life amendment to the U.S. Constitution. See Fla. S. Comm. on HRS SM 737 (1978) Staff Analysis 1 (Fla. May 9, 1978) (available at Fla. Dep’t of State, Fla. State Archives, Tallahassee, Fla.); Fla. H.R., H.M. 388, 11th Sess. (Fla. 1979) (available at Dep't of State, Fla. State Archives, 19. See, e.g., Fla. Women's Med. Clinic, Inc. v. Smith, 536 F. Supp. 1048, 1059 (S.D. Fla. 1982). - 44 -

Tallahassee, Fla.); Fla. S., S.M. 118, 11th Sess. (Fla. 1979) (available at Fla. Dep't of State, Fla. State Archives, Tallahassee, Fla.). Of significance here, twenty-seven legislators who voted for the privacy proposal had, within the prior two years, openly supported the adoption of a federal amendment to "protect unborn human[s]” in response to Roe v. Wade. Compare H.R. Journal, 12th Sess., at 318 (Fla. 1980), with H.R. Journal, 11th Sess., at 48 (Fla. 1979); compare S. Journal, 11th Sess., at 21 (Fla. 1979), with S. Journal, 12th Sess., at 313 (Fla. 1980). To us, it seems quite unlikely that so many legislators would have tried to remove abortion rights as a matter of federal constitutional law only to restrict legislative power on abortion just two years later by way of a state constitutional amendment. F We pause to summarize the textual, contextual, and historical evidence we have discussed so far. The Privacy Clause of the Florida Constitution does not mention abortion or include a word or phrase that clearly incorporates it. Era-appropriate dictionary definitions and contextual clues suggest that abortion does not naturally fit within the rights at issue. Reliable historical sources, - 45 -

like the technical meaning of the terms contained in the provision, the origin of the amendment, and the framing of the public debate, similarly do not support a conclusion that abortion should be read into the provision's text. Roe is also relevant to our analysis of the public meaning of the Privacy Clause. But speculation as to Roe's effect on voter understanding does not overcome the combined force of the substantial evidence we have examined above. Thus, we cannot conclude that in 1980 a voter would have assumed the text encompassed a polarizing definition of privacy that included broad protections for abortion. VI We have established the background legal principles that govern our review and analyzed the original public meaning of the Privacy Clause as it relates to the subject of abortion. Now, we must address how those considerations apply here-namely, can Planned Parenthood demonstrate conflict between the challenged statute and the constitutional protections secured by the Privacy Clause? The statute we review prohibits abortions after 15 weeks of pregnancy, subject to certain exceptions. This statute "come[s] - 46 -

clothed with a presumption of constitutionality and must be construed" if possible "to effect a constitutional outcome." Crist, 978 So. 2d at 139. To overcome this presumption, the challenger must establish invalidity (or conflict) "beyond reasonable doubt." Id. Based on our analysis finding no clear right to abortion embodied within the Privacy Clause, Planned Parenthood cannot overcome the presumption of constitutionality and is unable to demonstrate beyond a reasonable doubt that the 15-week ban is unconstitutional. 20 This conclusion brings us into tension with our precedent, primarily T. W. in which we derived a right to abortion from the Privacy Clause's text and invalidated a statute on that basis. 551 So. 2d at 1188; see also N. Fla. Women's Health, 866 So. 2d at 639 (reaffirming T.W.); Gainesville Woman Care, 210 So. 3d at 1253-56, 20. Even if we gave significantly greater weight to Roe's effect on the original public meaning of the Privacy Clause (as urged by the dissent) and gave less weight to the other meaningful sources of evidence discussed above, we would still be left without a definition of privacy and considerable ambiguity as to the breadth of the provision. In that instance, we would reach the same conclusion, because a statute is presumed constitutional unless shown to be invalid beyond a reasonable doubt. Franklin, 887 So. 2d at 1073. The dissent fails to address what effect, if any, this longstanding principle of law should have here. - 47 -

1260 (relying on T.W.). In deciding how to resolve that tension, we again emphasize that T. W. failed to acknowledge the longstanding principle that statutes are presumed to be constitutional. This error led the Court to read additional rights into the constitution based on Roe's dubious and immediately contested reasoning, rather than evaluate what the text of the provision actually said or what the people of Florida understood those words to mean. The decision to extend the protections of the Privacy Clause beyond what the text could reasonably bear was not ours to make. As a result, we removed substantial authority from the people's elected representatives to regulate abortion-a profoundly unique and complicated issue that affects society in many significant ways. Accordingly, for the reasons given above, we find T.W. to be clearly erroneous. Based on our established test for assessing stare-decisis issues, we now ask whether there is a valid reason not to recede from T.W. See State v. Poole, 297 So. 3d 487, 506-07 (Fla. 2020) (outlining a two-part framework on stare-decisis issues). We have said that reliance is a critical consideration. Id. But as noted by the State, the Supreme Court's reasoning in Dobbs shows why reliance does not justify keeping T.W. In conducting a - 48 -

stare-decisis analysis in that case, the Supreme Court stressed that "[t]raditional reliance interests arise where advance planning of great precision is most obviously a necessity.'” Dobbs, 597 U.S. at 287 (first quoting Casey, 505 U.S. at 856 (joint opinion); and then citing Payne v. Tennessee, 501 U.S. 808, 828 (1991)). The Court went on to state that “those traditional reliance interests [a]re not implicated because getting an abortion is generally ‘unplanned activity,' and ‘reproductive planning could take virtually immediate account of any sudden restoration of state authority to ban abortions."" Id. at 288 (quoting Casey, 505 U.S. at 856). Finally, the Court rejected application of a more malleable and undefined form of reliance that focused on the relative social and economic effects of abortion. Id. at 288-89. In its view, this type of reliance was irrelevant to a proper stare-decisis framework. Id. We think that this analysis from Dobbs is in keeping with Poole. Indeed, in Poole, we expressed wariness for tests that are "malleable and do not lend themselves to objective, consistent, and predictable application." 297 So. 3d at 507 (criticizing North Florida Women's Health's multi-factor stare-decisis framework). And in the years since Poole issued, we have not employed the more malleable - 49 -

form of reliance that Dobbs declined to apply—the same sort of societal reliance interests now being advanced by Planned Parenthood. Apart from arguing reliance, Planned Parenthood does not offer any other valid reasons for keeping T.W. Accordingly, because Planned Parenthood has failed to demonstrate a valid reason for retaining T. W., we recede from it. We also recede from Gainesville Woman Care and North Florida Women's Health, which both applied T.W.'s flawed reasoning and offered no additional doctrinal justification for locating a right to abortion in the Privacy Clause. VII We now return to the specific facts of this case. Below, the trial court granted a temporary injunction, finding that Planned Parenthood would likely succeed in its constitutional challenge. Our holding, however, displaces the doctrinal justification for the trial court's decision. Planned Parenthood cannot demonstrate a likelihood of success on the merits of its claim, which alleged that the newly enacted statute was facially invalid under the Privacy Clause of the Florida Constitution. And since Planned Parenthood fails on this prong, it is not entitled to a temporary injunction. - 50 -

Although we do not adopt the reasoning of the First District, we approve the result it reached below. It is so ordered. MUÑIZ, C.J., and CANADY, COURIEL, and FRANCIS, JJ., concur. SASSO, J., concurs with an opinion. LABARGA, J., dissents with an opinion. NOT FINAL UNTIL TIME EXPIRES TO FILE REHEARING MOTION AND, IF FILED, DETERMINED. SASSO, J., concurring. I join the majority opinion because it correctly holds that the Florida Constitution does not contain a right to elective abortion. I write separately to explain why I believe it is appropriate to reach that decision considering the standing arguments raised by the State in the lower court proceedings and on appeal and as highlighted by Amici in this Court. In doing so, I will start with some observations regarding this Court's standing jurisprudence. I will then explain why I agree with the majority's decision to accept the State's waiver of any standing arguments here. Finally, I will explain why I believe, in the proper case, this Court should reconsider its standing precedent. - 51 -

I. Standing is the legal doctrine that defines when a litigant has a stake in a controversy sufficient to obtain judicial resolution of that controversy. The doctrine keeps us in our constitutional lane by ensuring we do not become “roving commissions assigned to pass judgment on the validity of the [State's] laws." See Broadrick v. Oklahoma, 413 U.S. 601, 611 (1973). At the federal level, standing requirements are derived from Article III of the United States Constitution's Case or Controversy Clause. Constitutional in origin, standing is therefore a jurisdictional prerequisite to a plaintiff's right to sue in federal court. See Indus. Servs. Grp., Inc. v. Dobson, 68 F.4th 155, 167 (4th Cir. 2023) ("It is axiomatic that standing is a threshold jurisdictional issue that must be determined before a court can consider the merits of a case." (citing Steel Co. v. Citizens for a Better Env't, 523 U.S. 83, 88 (1998))). For that reason, federal courts have the ability, and indeed the obligation, to address standing sua sponte even if a defendant has not raised the issue. See United States v. Hays, 515 U.S. 737, 742 (1995) ("[W]e are required to address [standing] even if the courts - 52 -

below have not passed on it, and even if the parties fail to raise the issue before us." (first alteration in original) (quoting FW/PBS, Inc. v. City of Dallas, 493 U.S. 215, 230-31 (1990))); Cent. States Se. & Sw. Areas Health & Welfare Fund v. Merck-Medco Managed Care, L.L.C., 433 F.3d 181, 198 (2d Cir. 2005) ("Because the standing issue goes to this Court's subject matter jurisdiction, it can be raised sua sponte."). Likewise, the question of standing is not subject to waiver. Hays, 515 U.S. at 742. At the state level, it is different. As it relates to standing, the Florida Constitution is textually distinct from the Federal Constitution because it does not contain an explicit cases and controversies clause. It should go without saying, then, that federal law does not control standing requirements in state courts. See ASARCO Inc. v. Kadish, 490 U.S. 605, 617 (1989) (noting that the constraints of Article III do not apply to state courts, and accordingly state courts are not bound by the limitations of a case or controversy). Even so, this Court has at times reflexively adopted federal standing tests without examining whether the Florida Constitution demands similar requirements. See, e.g., State v. J.P., 907 So. 2d 1101, 1113 n.4 (Fla. 2004) (adopting three-part standing - 53 -

test established by the United States Supreme Court in Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992)); Alterra Healthcare Corp. v. Est. of Shelley, 827 So. 2d 936, 941 (Fla. 2002) (adopting thirdparty standing test recognized by the United States Supreme Court). We have not done so consistently, though. At times, we have concluded that standing in Florida is less restrictive than at the federal level. For example, in Department of Revenue v. Kuhnlein, 646 So. 2d 717, 720 (Fla. 1994), we said that the doctrine of standing does not exist in Florida "in the rigid sense employed in the federal system." See also Coal. for Adequacy & Fairness in Sch. Funding, Inc. v. Chiles, 680 So. 2d 400, 403 (Fla. 1996) (noting that in Florida, unlike the federal system, the doctrine of standing has not been rigidly followed). Consistent with this observation, we have sometimes applied state-specific standing rules. See, e.g., Johnson v. State, 78 So. 3d 1305, 1314 (Fla. 2012) (holding a litigant has standing if "he or she reasonably expects to be affected by the outcome of the proceedings, either directly or indirectly” (quoting Hayes v. Guardianship of Thompson, 952 So. 2d 498, 505 (Fla. 2006))). Other times we have, either explicitly or implicitly, - 54 -

bypassed a standing analysis altogether. See, e.g., J.P., 907 So. 2d at 1113 ("Because the Second District never determined whether these juveniles have standing to assert the constitutional rights of their parents, we decline to rule on these claims." (footnote omitted)).21 Our inconsistent approach is especially evident in the context of third-party standing. Traditionally, this Court considered as well-settled the rule that one who is not himself denied some constitutional right or privilege cannot be heard to raise constitutional questions on behalf of some other person who may at some future time be affected. See, e.g., Steele v. Freel, 25 So. 2d 501, 503 (Fla. 1946). Eventually, though, we carved out exceptions. For example, in Jones v. State, 640 So. 2d 1084 (Fla. 1994), we determined that criminal defendants could raise the privacy rights 21. Despite the inconsistent application of various tests to determine whether a party has standing to pursue its claims, our standing precedent has been steady in one respect. We have always held that standing can be waived. See, e.g., Krivanek v. Take Back Tampa Pol. Comm., 625 So. 2d 840, 842 (Fla. 1993); Cowart v. City of West Palm Beach, 255 So. 2d 673, 675 (Fla. 1971). However, this is somewhat logically inconsistent, because we oftentimes have adopted federal standards ostensibly derived from the Federal Constitution without adopting the corresponding rule that standing is jurisdictional in nature and therefore not subject to waiver. - 55 -

of the female minors with whom they had sexual relations because the criminal defendants "st[oo]d to lose from the outcome of this case and yet they ha[d] no other effective avenue for preserving their rights." Id. at 1085 (referencing Stall v. State, 570 So. 2d 257 (Fla. 1990), for "vicarious standing" requirements). Later, in Alterra, we applied a federal test to determine when parties can sue on behalf of rights belonging to others. 827 So. 2d at 941-42. The test, as laid out in Alterra, goes like this: a litigant may bring an action on behalf of a third party if 1) the litigant suffered an “injury in fact,” thus giving him or her a "sufficiently concrete interest" in the outcome of the issue in dispute; 2) the litigant has a close relation to the third party; and 3) there is some hindrance to the third party's ability to protect his or her own interests. Id. (quoting Powers v. Ohio, 499 U.S. 400, 410-11 (1991)). But we applied this test in Alterra without explicitly adopting it as doctrine and without addressing our previous application of the Stall standard in Jones. Only a year after Alterra was decided, we again backed away from applying federal standing tests at all in Allstate Insurance Co. v. Kaklamanos, 843 So. 2d 885 (Fla. 2003). There, we reiterated - 56

that the doctrine of standing does not exist in Florida "in the rigid sense employed in the federal system." Id. at 895 (quoting Kuhnlein, 646 So. 2d at 720). This made room for our conclusion that an insured could maintain an action against the insurer for nonpayment of personal injury protection automotive insurance benefits even though the insured had not paid the medical bills in question and the medical provider had not instituted legal action against the insured for nonpayment. Id. at 897. And later, we appeared to cabin Alterra to the employment context in Weaver v. Myers, 229 So. 3d 1118, 1129 (Fla. 2017). In that same case, we also cited favorably the “vicarious standing" test from Jones, a case that preceded Alterra.2² Id. 22. Our doctrinal inconsistency in third-party standing cases is not the only aspect of our standing jurisprudence that has been unclear. For example, as noted above we adopted the three-part standing test established by the United States Supreme Court in Lujan v. Defenders of Wildlife, 504 U.S. 555, in J.P. But a few years later in Johnson, we stated broadly that “standing ‘requires a would-be litigant to demonstrate that he or she reasonably expects to be affected by the outcome of the proceedings, either directly or indirectly.'" 78 So. 3d at 1314 (quoting Hayes, 952 So. 2d at 505). We did so without any reference to our previous adoption of the Lujan test and over the dissenting justices' observation that the moving party would have met that standing requirement. And although we have, with more consistency, adhered to the Rickman v. Whitehurst, 74 So. 205 (Fla. 1917), rule when litigants have - 57 -

II. With that background in mind, I now return to this case. It serves as a prime example of the challenges our doctrinal inconsistencies create for litigants and lower courts. In the trial court, the State argued Planned Parenthood lacked standing to challenge HB 5 because none of the plaintiffs could assert a personal right to privacy—instead, the plaintiffs sought to assert the privacy rights of their patients and/or customers. Working off the Alterra test, the State then argued Planned Parenthood could not meet the requirements for overcoming the general bar to third-party standing. In doing so, though, the State conceded that the second prong of the Alterra test (the close relationship requirement) was satisfied. In response, Planned Parenthood accepted the State's framing of the issue, arguing it could satisfy the Alterra test. This framework carried over to the trial court's order granting the challenged government action, we continue to carve out exceptions without a textual explanation justifying a new exception. See, e.g., Dep't of Admin. v. Horne, 269 So. 2d 659 (Fla. 1972) (citing federal precedent to carve out exception for "ordinary citizens and taxpayers" to pursue constitutional claims in certain circumstances even absent a showing of special injury to themselves). - 58 -

temporary injunction, where it applied the Alterra test and concluded that Planned Parenthood has "third-party standing to bring this suit on behalf of their actual and potential patients." Planned Parenthood of Sw. & Cent. Fla. v. State, No. 2022-CA-912, 2022 WL 2436704, at *17 (Fla. 2d Cir. Ct. July 5, 2022). But, in the First District, the court concluded that it did not need to address Petitioners' standing argument. Instead, the First District decided that Petitioners had not suffered irreparable harm sufficient to support the issuance of a temporary injunction. State v. Planned Parenthood of Sw. & Cent. Fla., 342 So. 3d 863, 867-68 (Fla. 1st DCA 2022). That takes us to the parties' briefing filed in this Court. The State reasserted its argument as to Planned Parenthood's standing to pursue its claims. But as the majority opinion notes, the State essentially conceded the issue of standing at oral argument, urging this Court to reach the merits. So why do we accept that concession? First, as the majority notes, this case has been litigated under the umbrella of this Court's abortion jurisprudence. See, e.g., Gainesville Woman Care, LLC v. State, 210 So. 3d 1243, 1253-54 (Fla. 2017); N. Fla. Women's - 59 -

Health & Counseling Servs., Inc. v. State, 866 So. 2d 612, 620 (Fla. 2003); In re T. W., 551 So. 2d 1186, 1188-89 (Fla. 1989). And our abortion jurisprudence falls into the category of cases where we have, without explaining why, skipped over a standing analysis altogether. As a result, we have neither directly addressed standing nor applied the Alterra test in any of our abortion cases. Instead, to the extent standing was considered, we seem to have collapsed the analysis into the grounds for obtaining a temporary injunction without considering which standing test to apply or whether an abortion provider can meet that test. See Gainesville Woman Care, 210 So. 3d at 1247 (“Petitioners have established a substantial likelihood of success on the merits, one of the requirements of granting a temporary injunction, as well as all other grounds for the entry of a temporary injunction.” (emphasis added)). For that reason, addressing standing alone here would have only added to the inconsistencies in our cases. Second, both parties have asked us to apply the federal thirdparty standing test as applied in Alterra. But as explained above, we have applied that test once. And, for many reasons, I question the wisdom of perpetuating the standard here. For one, I do not - 60

think we should apply federal standards to textually distinct provisions of the Florida Constitution without considering whether that standard is independently justified on state law grounds. For another, reflexively adopting the federal third-party standing test is particularly troublesome because, in federal courts, it has been inconsistently applied and widely criticized. See, e.g., June Med. Servs. L. L. C. v. Russo, 140 S. Ct. 2103, 2142-46 (2020) (Thomas, J., dissenting) (noting the test's inconsistent application, criticizing the characterization of third-party standing as prudential in nature, and concluding that third-party standing is inconsistent with the case-or-controversy requirement of Article III). Finally, and critically, neither party has challenged our characterization of standing as waivable rather than jurisdictional. Similarly, no party has offered an alternative standard to apply in the absence of Alterra or an argument as to whether Planned Parenthood fails to meet any alternative standard. As a result, I believe this Court properly reaches the merits of this case. III. While the State's concession takes care of this case, in future cases we should reconsider our standing precedents. Most - 61

fundamentally, we should consider from where our standing requirements are derived (spoiler alert-it is not the Federal Constitution). For example, is standing in Florida derived only from article V's conception of "judicial power"? See, e.g., Sons of Confederate Veterans v. Henry Cnty. Bd. of Comm'rs, 880 S.E.2d 168, 185-86 (Ga. 2022) (concluding that standing requirement arises from the Georgia Constitution's judicial power provision). Or does the access to courts provision of article I, section 21 have anything to say as to standing? Once decided, we will need to clarify the scope of any standing requirements, such as whether parties may assert both legal and factual injuries or whether only a legal injury will suffice. See, e.g., F. Andrew Hessick, Standing, Injury in Fact, and Private Rights, 93 Cornell L. Rev. 275, 280-81 (2008) (noting that at common law "factual harm without a legal injury was damnum absque injuria and provided no basis for relief"). We will also need to examine whether standing requirements are truly subject to waiver, or instead whether they are jurisdictional in nature. And finally, we will need to provide a principled methodology to help litigants understand which tests to apply when. - 62 -

To decide these and other issues related to standing, we will need the benefit of the adversarial process and thorough briefing. For that reason, and in the proper case, I encourage parties to critically assess these and other standing issues and present argument to this Court should the opportunity arise. LABARGA, J., dissenting. When the United States Supreme Court's decision in Dobbs23 “returned to the people and their elected representatives” “the authority to regulate abortion,” the decision did not force the state of Florida into uncharted territory. Instead, as history reveals and the majority acknowledges, the right to an abortion as a matter of Florida law was decided decades ago following two significant postRoe24 developments: (1) Florida voters' 1980 approval of an amendment to the Florida Constitution expressly providing a right of privacy, and (2) this Court's 1989 decision in In re T. W., 551 So. 2d 1186 (Fla. 1989), holding that Florida's express right of privacy 23. Dobbs v. Jackson Women's Health Org., 597 U.S. 215, 292 (2022). 24. Roe v. Wade, 410 U.S. 113 (1973). - 63

encompasses the right to an abortion. Nonetheless, today's majority decision recedes from decades of this Court's precedent and holds that "there is no basis under [Florida's express right of privacy] to invalidate” “a recently amended statute that shortens the window of time in which a physician may perform an abortion." Majority op. at 2. I strongly dissent. The Right of Privacy Adopted by Florida voters in 1980, article I, section 23 of the Florida Constitution provides: “Every natural person has the right to be let alone and free from governmental intrusion into the person's private life except as otherwise provided herein. This section shall not be construed to limit the public's right of access to public records and meetings as provided by law." Contrary to the majority, I am convinced that in 1980, a Florida voter would have understood that the proposed privacy amendment “included broad protections for abortion." Id. at 46. The right of privacy is no novel concept. More than 100 years ago, former Michigan Supreme Court Justice and noted legal scholar Thomas Cooley described “[t]he right to one's person" as the right "to be let alone." Thomas M. Cooley, A Treatise on the Law of - 64 -

Torts or the Wrongs Which Arise Independent of Contract 29 (2d ed. 1888). When the right "to be let alone" was discussed by Samuel D. Warren and Louis D. Brandeis in their Harvard Law Review article The Right to Privacy, the article primarily discussed the tort of invasion of privacy. See Samuel D. Warren & Louis D. Brandeis, The Right to Privacy, 4 Harv. L. Rev. 193 (1890). However, the authors also made the following salient observation: THAT the individual shall have full protection in person and in property is a principle as old as the common law; but it has been found necessary from time to time to define anew the exact nature and extent of such protection. Political, social, and economic changes entail the recognition of new rights, and the common law, in its eternal youth, grows to meet the demands of society. Id. at 193. Thus, even in early considerations of the right of privacy, scholars recognized that the right would be one that would evolve over time and it did. During the twentieth century, political, social, and economic changes led to a host of changes in the legal landscape, resulting in an expansion of the right of privacy far beyond a right to be free from unwanted public exposure. Without question, one of the most significant legal developments was the United States Supreme Court's recognition in Roe of an implicit right of privacy - 65 -

guaranteeing the right to an abortion as a matter of federal law. However, the right of privacy in the context of decisional autonomy took hold several years earlier in Griswold v. Connecticut, 381 U.S. 479 (1965) (holding that a state statute prohibiting the use of contraceptives violated the right to marital privacy). It is relevant to the analysis of the public understanding of the right of privacy that Griswold's expansion of privacy to reach decisional autonomy occurred more than seven years before Roe and fifteen years before Florida voters' adoption of the right of privacy as a matter of state constitutional law. The State's argument, that the sole context for Florida's right of privacy is informational privacy, seems to have been a step too far even for the majority. Nonetheless, the majority concludes that the language of "shall not be construed to limit the public's right of access to public records and meetings as provided by law" provides context that "do[es] not lend support to a claim that voters clearly understood abortion to be part and parcel of the rights recognized" under the right of privacy. Majority op. at 23. What is more, it reaches this conclusion despite substantial evidence that - 66 -

overwhelmingly supports the conclusion that the public understood the right of privacy to encompass the right to an abortion. Abortion as a Private Matter Before turning to the public understanding of the right of privacy, I write to address the majority's suggestion that abortion is ultimately not a private matter because “the procedure itself include[s] medical intervention and require[s] both the presence and intrusion of others.” Id. at 21 (citing Roe, 410 U.S. at 172 (Rehnquist, J., dissenting)). The majority acknowledges that an abortion "include[s] medical intervention,” see id., but beyond merely “includ[ing] medical intervention,” Florida’s statutes regulating abortion—then and now-require that the procedure be performed by a physician. See § 390.0111(2), Fla. Stat. (2023) (requiring that a termination of pregnancy be performed by a physician); Wright v. State, 351 So. 2d 708 (Fla. 1977) (pre-1980 decision from this Court upholding the conviction of a registered nurse who performed an abortion in violation of statute requiring that the procedure be performed by a physician). The “others” required to be present and involved in the procedure are physicians and medical personnel. In the interest of - 67 -

patient privacy, medical matters, including countless forms of medical procedures, are broadly afforded confidentiality protections with narrowly tailored exceptions. And notably, the involvement of a physician was not fatal to the privacy issue in Griswold, where the United States Supreme Court said: "This law [prohibiting the use of contraceptives], however, operates directly on an intimate relation of husband and wife and their physician's role in one aspect of that relation.” 381 U.S. at 482 (emphasis added). As a matter of necessity, physicians and medical personnel are routinely involved in a wide range of medical procedures, decisions, and other medical matters. The majority attempts to limit today's decision to the issue of abortion. See majority op. at 10 note 7 ("[T]oday we do not revisit our precedents outside the abortion context."). However, I fear that parties will rely on the majority's reasoning that the involvement of "others" in an abortion procedure defeats privacy-in attempts to undermine the broad privacy protections that are extended in the medical context. - 68

The Public Understanding of Roe v. Wade and the Right of Privacy The majority "acknowledge[s] that the public understanding of the term 'privacy' was, to some extent, informed by the United States Supreme Court's 1973 decision in Roe v. Wade," observing that "[following that decision, the phrase ‘right to privacy' gained new connotations that, for the first time, included the choice to have an abortion." Majority op. at 29 (emphasis added). The majority continues: In Planned Parenthood's view, this aspect of federal privacy jurisprudence should control our analysis here. Specifically, Planned Parenthood argues that Florida voters would have internalized Roe's definition of privacy when they voted for the privacy amendment. Indeed, Planned Parenthood has repeatedly asserted that the public understanding of this privacy definition was so engrained by 1980 that even without a specific mention of the term abortion, the Privacy Clause unequivocally included such a right by implication. Though this argument has some force, we cannot agree with Planned Parenthood that the backdrop of Roe conclusively establishes how a voter would have understood the provision. Id. at 29-30 (emphasis added). The majority concludes that "[c]onsequently, while Roe is relevant to our analysis of public meaning, it is not dispositive.” Id. at 32. I could not disagree more. - 69 -

The majority correctly recognizes the significant impact of Roe but stops short of the reality that Roe, having fundamentally changed the landscape of abortion rights on a national scale by redefining the scope of the right of privacy, was key to the public understanding of the right of privacy. During the seven-year interval between Roe and Florida voters' adoption of the right of privacy, I find it inconceivable that Americans and more specifically, Floridians were not aware that the right of privacy encompassed the right to an abortion. I agree with the petitioners that "the public understanding of [Roe's] privacy definition was so engrained by 1980 that even without a specific mention of the term abortion, the Privacy Clause unequivocally included such a right by implication." Id. at 29-30. In fact, the majority notes the controversial impact of Roe's reasoning, which reinforces that the public would have understood the right of privacy encompassed the right to an abortion. See id. at 14 (stating that Roe "left even progressive legal scholars baffled at how such a right could be gleaned from the constitution's text," and quoting Dobbs, 597 U.S. at 268 (“Roe's constitutional analysis was far outside the bounds of any reasonable interpretation of the - 70 -

various constitutional provisions to which it vaguely pointed.")). Contrary to the majority's position, evidence of the discussion surrounding Roe's reasoning is probative that the public understood the right of privacy to encompass the right to an abortion, and to so conclude does not require the "analytical leap" that the majority suggests it does. See id. at 31. Roe's opponents strenuously disapproved of basing the right to an abortion on the right of privacy; just as strenuously, Roe's supporters agreed with the Supreme Court's analysis. The common denominator is the understanding that the right to an abortion was tied to the right of privacy. The Nationwide Understanding of Roe and the Right of Privacy A decision that triggered pervasive national coverage, Roe was publicly discussed and debated in a way that most judicial decisions-even those decided by the United States Supreme Court are not. Media outlets across the nation reported on the landmark decision. On the day that Roe was decided, Associated Press articles announcing the seminal decision were published on the front pages of newspapers nationwide, many explaining that the decision "was - 71 -

based predominantly on what [Justice] Blackmun called a right of privacy."25 The nightly news programs on the major television networks also reported on Roe to an audience of tens of millions of viewers. The CBS Evening News with Walter Cronkite-a news program with, at that time, a consistent audience of twenty million or more viewers-covered the decision in a segment lasting more than three minutes, noting that “[t]he nine justices made abortion 25. See, e.g., Associated Press, Abortion Law Out, Mexico Ledger, Jan. 22, 1973, at 1; Associated Press, Barry Schweid, Abortion Law Struck by Court, The Courier News (Blytheville), Jan. 22, 1973, at 1; Associated Press, Abortions Allowed During 1st 6 Months, The Daily Chronicle (Centralia), Jan. 22, 1973, at 1; Associated Press, Barry Schweid, Blackmun Cites 'Right of Privacy' Court Bars Restricting Three-Month Abortions, The Index-Journal (Greenwood), Jan. 22, 1973, at 1; Associated Press, Court Strikes Down Abortion Law, The Neosho Daily News, Jan. 22, 1973, at 1; Associated Press, Court Strikes Down Abortion Law, Aiken Standard, Jan. 22, 1973, at 1; Associated Press, Court Strikes Down Texas Abortion Law, The Daily Times-News (Burlington), Jan. 22, 1973, at 1; Associated Press, Barry Schweid, Decision Will Affect 44 States, Del Rio News-Herald, Jan. 22, 1973, at 1; Associated Press, High Court Upholds Medical Abortions, Waukesha Daily Freeman, Jan. 22, 1973, at 1; Associated Press, Key Abortion Ruling by Supreme Court, Santa Cruz Sentinel, Jan. 22, 1973, at 1; Associated Press, Rule on Abortions, The Sedalia Democrat, Jan. 22, 1973, at 1; Associated Press, States Can't Block Early Abortions, The Bismarck Tribune, Jan. 22, 1973, at 1; Associated Press, Supreme Court Upholds Women's Abortion Rights, Fairbanks Daily News-Miner, Jan. 22, 1973, at 1; Associated Press, Texas Law Struck Down, 7-2, The Vernon Daily Record, Jan. 22, 1973, at 1-2. - 72 -

largely a private matter." CBS Evening News with Walter Cronkite, featuring George Herman in Washington (CBS television broadcast Jan. 22, 1973), https://www.youtube.com/watch?v=dccagy905yk (available on the CBS News YouTube channel). Throughout the nation, local journalists also published articles announcing and explaining Roe, as did opinion writers in making their arguments.26 In some articles, even the titles emphasized that the right to an abortion was based on the right of privacy. See, e.g., Supreme Court: Right of Privacy Includes Abortion, The Georgia Bulletin, Feb. 22, 1973, at 2 (calling Roe "one of the biggest news stories of the year"); Chicago Daily News Services, 'Privacy' is Reason for Abortion Ruling, Omaha World-Herald, 26. See, e.g., Bonni McKeown, Abortion's Status in West Virginia: Legal Question Affects Availability, Beckley Post-Herald, June 21, 1976, at 5 (explaining that Roe invalidated most states' abortion laws based on the balancing of the state's interests versus a woman's right of privacy); Washington Post, Editorial, Abortion: 19th Century, The Evening Times (Sayre), Feb. 3, 1973, at 4 (same); Joseph Kraft, Opinion, The High Court Speaks Up for Privacy, The Greensboro Record, Jan. 29, 1973, at 20 (same); Joseph Kraft, Opinion, Ruling Revealed Conservative Court, The Montana Standard, Jan. 28, 1973, at 6 (same); Joseph Kraft, Opinion, The Abortion Ruling, The Roanoke Times, Jan. 27, 1973, at 6 (same); Mary Smith, Abortion Ruling Draws Varied Reactions Here, The Lawton Constitution, Jan. 23, 1973, at 4 (same). - 73 -

Jan. 23, 1973, at 18; Associated Press, 'Right of Privacy' Cited in Action Against States, Reno Gazette-Journal, Jan. 22, 1973, at 1. Roe and its extensive coverage informed legislators and their constituents that the right of privacy under the U.S. Constitution protected the right to an abortion. Far from an issue that faded after one or two news cycles, abortion remained a prevalent issue during the seven years between Roe and the 1980 adoption of Florida's privacy amendment. The three-trimester framework laid out in Roe balanced the state's interests against the mother's right of privacy, and based on that balancing test, abortion laws in multiple states, including Florida, were struck down on federal privacy grounds. See Fla. Women's Med. Clinic, Inc. v. Smith, 478 F. Supp. 233 (S.D. Fla. 1979) (holding unconstitutional, on federal privacy grounds, administrative rules implementing Florida abortion statute); Jones v. Smith, 474 F. Supp. 1160 (S.D. Fla. 1979) (granting, on federal privacy grounds, a preliminary injunction against the enforcement of Florida abortion statute); Coe v. Gerstein, 376 F. Supp. 695 (S.D. Fla. 1973) (holding Florida abortion statute unconstitutional on federal privacy grounds). - 74 -

As courts, legislatures, and the public continued to confront the topic of abortion, the media continued to cover Roe, noting the historical and legal context: “In the famous 1973 Roe vs. Wade case, the U.S. Supreme Court ruled that choosing abortion was part of a woman's right to privacy";27 "The Supreme Court legalized abortions in 1973, basing its landmark ruling on a woman's right to privacy."28 In 1980, only two months before Florida's privacy amendment vote, a United States district court judge struck down North Dakota's new abortion law regulating first trimester abortions, applying Roe and stating that "[t]he decision to obtain an abortion free from governmental interference is a fundamental right founded 27. Kevin M. Russell, Letter to the Editor, Does The Bill Regulating Abortions Deny Women Their Rights?, The Record (Hackensack), June 17, 1979, at 105. 28. Associated Press, Top Court to Decide Abortion Law Rule, Gettysburg Times, Nov. 28, 1979, at 6; Associated Press, Abortion Issue Back Before Supreme Court, The Index-Journal (Greenwood), Nov. 27, 1979, at 8; Associated Press, Abortion Issue Goes Back to High Court, News-Journal (Mansfield), Nov. 27, 1979, at 7; Associated Press, Abortion Issue is Back Before the Supreme Court, Poughkeepsie Journal, Nov. 27, 1979, at 6; Associated Press, High Court to Rule on Abortion Issue, Daily Sitka Sentinel, Nov. 27, 1979, at 2. - 75 -

in the right of privacy implicit in the Constitution." Leigh v. Olson, 497 F. Supp. 1340, 1343 (D.N.D. 1980); Associated Press, Most of Abortion Law Tossed Out, The Bismarck Tribune, Sept. 30, 1980, at 1 (front-page newspaper article in North Dakota quoting the court's decision). Following Roe, pro-choice advocates praised the decision for recognizing a woman's right of privacy, while Catholic bishops and other pro-life advocates spoke out against Roe, asserting that the decision let the right of privacy outweigh the right to life: “In effect, the Court is saying that the right of privacy takes precedence over the right to life." U.S. Bishops Issue Message on Abortion, Panama City News-Herald, Mar. 4, 1973, at 40; Bishops Reject High Court's Abortion Ruling, Issue Pastoral Applications for Catholics, The True Voice (Omaha), Feb. 16, 1973, at 1.29 at 29. See also Katherine Lunine, Letter to the Editor, Preserve Constitutional Rights, The Journal News (Hamilton), Feb. 1, 1977, 4 (showing that pro-choice actors argue that government interference with abortion is limited by a woman's right of privacy); Associated Press, Abortion Ban Voted by House, The Corbin TimesTribune, Sept. 17, 1976, at 12 (same); Associated Press, Betty Anne Williams, Anti-Abortionists Stage Ban Rally in Washington, The Robesonian (Lumberton), Jan. 22, 1976, at 2 (same); Associated Press, 'March for Life' Again Seeks Amendment to Ban Abortion, The Index-Journal (Greenwood), Jan. 22, 1976, at 3 (same); Associated - 76

Ultimately, whether they supported the Supreme Court's decision in Roe or not, Americans in 1980 would have understood that the right of privacy encompassed the right to an abortion. The Public Understanding of Florida Voters in 1980 More specifically, and especially relevant to the present case, Florida media coverage after Roe illustrates that in 1980 Florida voters would have understood the privacy amendment to encompass the right to an abortion. The wealth of primary sources from Florida strongly indicates what voters would have known. Newspapers across Florida began reporting on Roe the day it was decided: January 22, 1973. In explaining the decision, these articles discussed the federal right of privacy as the basis for the right to an abortion. Adam Richardson, The Originalist Case for Why the Florida Constitution's Right of Privacy Protects the Right to an Abortion, 53 Stetson L. Rev. 101, 125 (2023). Like newspapers throughout the nation, Florida newspapers published an Associated Press, Washington Rally Marks Abortion Anniversary, The Times Record (Troy), Jan. 22, 1976, at 3 (same); United Press International, High Court 7-2 Ruling on Abortion Praised, Condemned, Traverse City Record-Eagle, Jan. 23, 1973, at 24 (same). - 77 -

Press article quoting Roe's pronouncement that the right of privacy "is broad enough to encompass a woman's decision whether or not to terminate her pregnancy." See, e.g., Associated Press, Court Strikes Down Abortion Laws, The Pensacola News, Jan. 22, 1973, at 1; Associated Press, High Court KOs Ban on Abortion, Tallahassee Democrat, Jan. 22, 1973, at 1. Coverage of Roe and of this broad privacy right also made the front pages of newspapers in Orlando and Fort Myers. See Washington Post Dispatch, High Court Nullifies Abortion Laws, Sentinel Star (Orlando), Jan. 23, 1973, at 1; Associated Press, Six-Month Abortions Upheld, Fort Myers NewsPress, Jan. 23, 1973, at 1. In 1980, the right of privacy and its inextricable connection to the right to an abortion continued to permeate Florida news. When Justice Douglas died in January 1980, Florida newspapers reported his legacy with mention of his majority opinion in Griswold as a precursor to Roe. Richardson, supra, at 131; James W. Fox Jr., A Historical and Originalist Defense of Abortion in Florida, 75 Rutgers U. L. Rev. 393, 427-28 (2023). For example, a Miami Herald article noted that after Griswold, "the [United States Supreme] court moved to rule, in 1973, that a woman in early pregnancy has a - 78 -

constitutional right of privacy to choose abortion without government interference." Aaron Epstein, William O. Douglas: Champion of Underdogs, Unpopular Ideas, The Miami Herald, Jan. 27, 1980, at 5-E. Florida news coverage of the United States Supreme Court continued with reports of abortion cases―and their right of privacy issues. In discussing the Supreme Court's 1980 oral arguments in H. L. v. Matheson, 450 U.S. 398 (1981), which involved parental notification of abortion, the Miami Herald reported that “[o]ut of this conflict between a minor's right to privacy and her parents' obligation to care for her has emerged a constitutional issue that was accepted Monday for review by the U.S. Supreme Court." Aaron Epstein, Court Will Examine Parents' Notification for Minor's Abortion, The Miami Herald, Feb. 26, 1980, at 10-A. And explaining the Court's decision in Harris v. McRae, 448 U.S. 297 (1980), which upheld the Hyde Amendment's restrictions on the use of federal funds to pay for an abortion, the Pensacola News reported that the decision "had nothing to do with the legality of abortion itself" because “[t]he Supreme Court legalized abortion in its landmark 1973 decision” in which "the court said a woman's right to privacy - 79 -

makes her decision to have an abortion a matter only for her and her doctor during the first three months of her pregnancy." Associated Press, High Court Rules on Abortions, The Pensacola News, June 30, 1980, at 1. Florida newspapers covered major party platforms, including their stances on abortion. These articles linked the abortion issue with the right of privacy. The Fort Lauderdale News and other Florida newspapers published a syndicated column indicating that although the Republican platform did not yet have a consensus on abortion, the Supreme Court had made its determination in 1973 by, in the author's view, “forging from a ‘privacy right' a scythe to mow down state laws that expressed various community judgments about abortion." See George Will, Opinion, Bridges to Cross; Bridges to Burn, Fort Lauderdale News, July 17, 1980, at 18A; Richardson, supra, at 132 n. 177 (observing that the column ran in Florida Today, Fort Myers News-Press, Palm Beach Post, Pensacola News, Sentinel Star (Orlando), St. Lucie News Tribune, St. Petersburg Times, Stuart News, and Tallahassee Democrat). Covering the Democratic platform, the St. Petersburg Times reported that delegates had voted for a platform statement opposing "government - 80 -

interference in the reproductive decisions of Americans" and "restrictions on funding for health services for the poor that deny poor women especially the right to exercise a constitutionallyguaranteed right to privacy." Charles Stafford, Kennedy Stirs Democrats with Rousing Call to Arms, St. Petersburg Times, Aug. 13, 1980, at 1-A (quoting the statement under the label “ABORTION”). Florida newspapers also covered statements by pro-choice activists and by pro-life activists that demonstrate both groups' understanding of abortion as part of the right of privacy. See Associated Press, Planned Parenthood Waving the Flag, The Tampa Tribune, Oct. 4, 1980, at 7-D (“In recent years we have faced an increasingly vocal and at times violent minority which seeks to deny all of us our fundamental rights of privacy and individual decisionmaking."); Carol Jeffares, Her Love of Life Makes Her Stand, Fight for It, The Tampa Tribune, Sept. 20, 1980, at 5-Pasco ("The abortion law is based on the woman's right to privacy. It says ‘a woman's right to privacy supersedes the fetus's life." "); Richardson, supra, at 132. With inflammatory language, both pro-choice and pro-life letters to the editor in Florida newspapers further demonstrate this understanding. See Joyce Tarnow, Letter to the Editor, Vote Out - 81

Anti-Abortionists, Fort Lauderdale News, Jan. 29, 1980, at 26-A ("The U.S. Constitution guarantees each of us the right of privacy, the right of religious freedom and the right to pursue happiness however we define it. Compulsory pregnancy is a denial of each of these rights."); Hugh Pope, Letter to the Editor, The Tampa TribuneTimes, Nov. 2, 1980, at 2-C (“There cannot be a more compelling reason for intelligent and patriotic Americans to vote Republican than to save lives! Stripped of all its sugarcoated slogans-freedom of choice[,]' [] 'woman's right to privacy[,]' [] etc., etc., abortion is legalized murder.”). The foregoing primary sources from Florida and from across the United States are examples of many. These sources should not be overlooked, and their impact should not be undervalued. In a quest to uncover the original public meaning of the Florida Constitution's Privacy Clause, they reveal that Roe was widely known for its holding and for its reasoning. Thus, in 1980, Florida voters would have understood the right of privacy as encompassing the right to an abortion. I hasten to add that the coverage discussed above, specifically connecting Roe and the right to an abortion to the right of privacy, - 82 -

occurred at a time when Americans relied heavily on print media and national news broadcasts. Florida Courts Acknowledge Right of Privacy Under Roe By the time Florida voters adopted the privacy amendment in 1980, Florida court decisions had repeatedly acknowledged the right of privacy expanded under federal law by Roe. While these decisions did not conclude that a right of privacy existed on state law grounds, they do provide further support that the public would have understood the link between the right to an abortion and the right of privacy. In 1977, this Court stated that “Justice Blackmun's articulation in Roe v. Wade of the limited scope of the right to privacy remains the current state of the law." Laird v. State, 342 So. 2d 962, 965 (Fla. 1977) (emphasis added) (rejecting argument that a right of privacy protected the possession of marijuana in the home). Even the dissenting opinion in Laird observed: "A constitutional right to privacy has been clearly established by the United States Supreme Court in . . . Roe . . . .” Id. at 966 (Adkins, J., dissenting) (emphasis added). - 83 -

In Jones v. Smith, 278 So. 2d 339 (Fla. 4th DCA 1973), cert. denied, Jones v. Smith, 415 U.S. 958 (1974), a case involving the abortion context, the Fourth District Court of Appeal rejected the claim of a putative father that he was entitled to prevent the mother from obtaining an abortion. The district court rejected that argument, saying: The recent decisions of the United States Supreme Court in Roe v. Wade . . . and Doe v. Bolton [410 U.S. 179 (1973)], while dealing with the constitutionality of statutes, set forth what we perceive to be the essential and underlying factor in the determination of this appeal. That factor is the "right of privacy” of the mother. Id. at 341 (emphasis added). Additionally, in discussing the right of privacy, the district court noted an observation made by the United States Supreme Court in Union Pacific Railway Co. v. Botsford, 141 U.S. 250, 251 (1891): “As well said by Judge Cooley, The right to one's person may be said to be a right of complete immunity to be let alone."" 278 So. 2d at 342 (quoting Babbitz v. McCann, 310 F. Supp. 293, 299 (E.D. Wisc. 1970)). Moreover, in Wright, the statute at issue required that an abortion be performed by a physician and at an approved facility. The petitioner, a registered nurse, challenged the approved facility - 84 -

requirement on the basis that under Roe and other federal decisions, the requirement violated the right of privacy. 351 So. 2d at 710. This Court ultimately upheld the petitioner's conviction on the ground that the statute constitutionally prohibited nonphysicians from performing an abortion. Despite concluding that the approved facility requirement was unconstitutional, this Court rejected the petitioner's privacy argument, stating: “The right to privacy in the abortion decision, recognized in Roe . . . as belonging to the pregnant woman in consultation with her physician, gives way to state power to regulate as the embryo or fetus develops." Id. at 710.30 30. Other decisions not involving abortion-related issues also recognized the right of privacy established in Roe. See, e.g., Rodriguez v. State, 378 So. 2d 7, 8 n.2 (Fla. 2d DCA 1979) (“In Roe, the court balanced the fundamental right to privacy of a woman's decision whether or not to terminate pregnancy against state interest to limit that right to safeguard health and potential life.”); Franklin v. White Egret Condo., Inc., 358 So. 2d 1084, 1089 (Fla. 4th DCA 1977) (observing on motion for rehearing that “[t]he right to be free of unwarranted interference with the decision to have children has been identified on numerous occasions by the United States Supreme Court as one of the matters protected by the right of privacy"); Day v. Nationwide Mut. Ins. Co., 328 So. 2d 560, 562 (Fla. 2d DCA 1976) (“The decision to have an abortion during the first trimester has been held to be private and personal to the individual woman. The primary interest, at least in the early stages of pregnancy, is that of the woman and her right to privacy." (citations - 85

Roe and the Privacy Amendment Debate According to the majority, the relative absence of the topic of abortion from the debate over Florida's proposed privacy amendment is evidence that the public did not understand that the right to an abortion was included in the scope of the proposed right of privacy. See majority op. at 41-42 (citing Fox, supra, at 443-44). However, Professor Fox explains why the topic of abortion was not a part of the amendment debate: Abortion would only have been debated if its coverage within the right to privacy were in dispute or were not yet established in law. But as of 1980 the protection of abortion through the right to privacy was the established law. It would hardly make sense for debates about section 23 to invest time and effort re-arguing the reasoning of Roe, let alone arguing that the terms “right to privacy," "right to be let alone," and "free from governmental intrusion" would plainly mean what they already meant in federal law. Fox, supra, at 442-43 (emphasis omitted). Indeed, Roe's extension of the right of privacy to the abortion context so dominated the abortion discussion that it would have been well understood that omitted)). Again, these cases are relevant to demonstrate that after Roe, and before voters adopted Florida's privacy amendment, the right to an abortion as a matter of a right of privacy would have been well understood. - 86 -

the right of privacy adopted by Florida voters included the right to an abortion. In re T.W. [S]tate courts cannot rest when they have afforded their citizens the full protections of the federal Constitution. State constitutions, too, are a font of individual liberties, their protections often extending beyond those required by the Supreme Court's interpretation of federal law. The legal revolution which has brought federal law to the fore must not be allowed to inhibit the independent protective force of state law-for without it, the full realization of our liberties cannot be guaranteed. William J. Brennan, Jr., State Constitutions and the Protection of Individual Rights, 90 Harv. L. Rev. 489, 491 (1977). Indeed, "[t]he citizens of Florida opted for more protection from governmental intrusion when they approved article I, section 23 of the Florida Constitution. This amendment is an independent, freestanding constitutional provision which declares the fundamental right to privacy." Winfield v. Div. of Pari-Mutuel Wagering, 477 So. 2d 544, 548 (Fla. 1985). The amendment "was intentionally phrased in strong terms . in order to make the privacy right as strong as possible." Id. It was in the context of Florida's broad right of privacy that almost thirty-five years ago, this Court held as a matter of state - 87 -

constitutional law that "Florida's privacy provision is clearly implicated in a woman's decision of whether or not to continue her pregnancy." T. W., 551 So. 2d at 1192. T.W. explained: “[W]e have said that the [privacy] amendment provides ‘an explicit textual foundation for those privacy interests inherent in the concept of liberty which may not otherwise be protected by specific constitutional provisions."" Id. (quoting Rasmussen v. S. Fla. Blood Serv., 500 So. 2d 533, 536 (Fla. 1987)). Unfortunately, the majority's decision to recede from T. W. and its progeny constitutes the rejection of a “decades-long line of cases hold[ing] that the Privacy Clause ‘embraces more privacy interests, and extends more protection to the individual in those interests, than [does] the federal Constitution."" Petitioners' Opening Brief at 41 (emphases omitted) (quoting T.W., 551 So. 2d at 1192). The decision is an affront to this state's tradition of embracing a broad scope of the right of privacy.31 31. In 2012, Florida reaffirmed this tradition when voters rejected a state constitutional amendment that would have narrowed protections for abortion rights in Florida by requiring that the protections be no greater than those provided under federal law. Additionally, the amendment would have overruled T. W. and other decisions concluding that Florida protections for abortion rights - 88 -

In deciding to reexamine T. W. and ultimately to recede from T.W. and its progeny, the majority states: "Since Roe featured prominently in T.W., we think it fair to also point out that the T. W. majority did not examine or offer a reasoned response to the existing criticism of that decision or consider whether it was doctrinally coherent. This was a significant misstep because Roe did not provide a settled definition of privacy rights." Majority op. at 13-14. I disagree. T. W. did acknowledge that "the workability of the trimester system and the soundness of Roe itself have been seriously questioned in Webster v. Reproductive Health Services, 492 U.S. 490 (1989).” T.W., 551 So. 2d at 1190. However, this Court correctly exceed those provided under federal law. In a decisive vote, more than fifty-five percent of Florida voters rejected the amendment. See Initiative Information: Prohibition on Public Funding of Abortions; Construction of Abortion Rights, Fla. Dep't of State, Division of Elections, https://dos.elections.myflorida.com/initiatives/initdetail.asp?accou nt=10&seqnum=82 (last visited Mar. 19, 2024). While the petitioners conceded during the oral argument in this case that Florida voters' rejection of the abortion amendment in 2012 was not relevant to the public understanding of the right of privacy adopted in 1980, the 2012 amendment rejection is still relevant to an understanding of Florida's tradition with respect to the right of privacy. - 89 -

observed that “[Roe] for now remains the federal law." See id. As such, this Court was not obligated in T.W. to “examine or offer a reasoned response to the existing criticism of [Roe] or consider whether it was doctrinally coherent." Majority op. at 13-14. It was "three years after T. W." and almost twelve years after Florida voters' 1980 adoption of the right of privacy that “the U.S. Supreme Court abandoned Roe's position that the right to abortion was grounded in any sort of [federal] privacy right." See id. at 15 (emphasis added) (citing Planned Parenthood of Se. Penn. v. Casey, 505 U.S. 833, 846 (1992)). Even then, the United States Supreme Court did not abandon Roe's “essential holding." Casey, 505 U.S. at 846. I reemphasize that T. W. was decided on state law grounds and with a clear understanding of the breadth of Florida's right of privacy as discussed in Winfield. To be certain, Roe was fundamental to the public understanding of the right of privacy as encompassing the right to an abortion. However, T. W. did not rely on Roe or the federal constitution to determine that Florida's right of privacy included the right to an abortion. See T.W., 551 So. 2d at 1196 ("We expressly decide this case on state law grounds and cite federal precedent only to the extent that it illuminates Florida - 90 -

law."). Because this Court based its decision squarely on Florida law, there is no basis for upending decades of precedent that give effect to Florida's broad right of privacy. Beyond Today's Decision The impact of today's decision extends far beyond the fifteenweek ban at issue in this case. By operation of state statute, the majority's decision will result in even more stringent abortion restrictions in this state. While not before this Court in the present case, it is an irrefutable effect of today's decision that chapter 202321, Laws of Florida, also known as the Heartbeat Protection Act, will take effect in short order. Chapter 2023-21 amends section 390.0111, Florida Statutes (among other statutes), and with limited exceptions, it bans abortions beyond the gestational age of six weeks. The Act provides that the ban will take effect thirty days after any of the following events: (1) a decision by this Court holding that Florida's constitutional right to privacy does not include a right to abortion; (2) a decision by this Court in the present case allowing the fifteen-week ban to remain in effect; (3) an amendment to the Florida Constitution clarifying that Florida's constitutional right of privacy - 91 -

does not include the right to an abortion; or (4) a decision from this Court after March 7, 2023, that recedes in whole or part from any of the following: T.W., North Florida Women's Health v. State, 866 So. 2d 612 (Fla. 2003), and Gainesville Woman Care, LLC v. State, 210 So. 3d 1243 (Fla. 2017). See ch. 2023-21, § 9, Laws of Fla. Today's decision implicates three of these four events, meaning that the Act's six-week ban will take effect in thirty days. “The document that the [majority] releases [today] is in the form of a judicial opinion interpreting a [provision of the Florida Constitution]. Bostock v. Clayton Co., 590 U.S. 644, 683 (2020) (Alito, J., dissenting). However, I lament that what the majority has done today supplants Florida voters' understandingthen and now that the right of privacy includes the right to an abortion. Conclusion "" The majority concludes that the public understanding of the right of privacy did not encompass the right to an abortion. However, the dominance of Roe in the public discourse makes it inconceivable that in 1980, Florida voters did not associate abortion with the right of privacy. - 92 -

Because of this, and with deep dismay at the action the majority takes today, I dissent. Application for Review of the Decision of the District Court of Appeal Direct Conflict of Decisions First District - Case No. 1D22-2034 (Leon County) Whitney Leigh White, Jennifer Dalven, and Johanna Zacarias of American Civil Liberties Union Foundation, New York, New York, for Petitioners Gainesville Woman Care, LLC, Indian Rocks Woman's Center, Inc., St. Petersburg Woman's Health Center, Inc., and Tampa Woman's Health Center, Inc., Autumn Katz and Caroline Sacerdote of Center for Reproductive Rights, New York, New York, for Petitioner A Woman's Choice of Jacksonville, Inc. Jennifer Sandman of Planned Parenthood Federation of America, New York, New York, for Petitioners Planned Parenthood of Southwest and Central Florida, Planned Parenthood of South, East, and North Florida, and Shelly Hsiao-Ying Tien, M.D., M.P.H. April A. Otterberg and Shoba Pillay of Jenner & Block LLP, Chicago, Illinois; and Daniel Tilley of American Civil Liberties Union Foundation of Florida, Miami, Florida; Benjamin James Stevenson, American Civil Liberties Union Foundation of Florida, Pensacola, Florida, and Nicholas L.V. Warren of American Civil Liberties Union Foundation of Florida, Inc., Tallahassee, Florida, for Petitioners - 93 -

Ashley Moody, Attorney General, Henry C. Whitaker, Solicitor General, Jeffrey Paul DeSousa, Chief Deputy Solicitor General, Daniel William Bell, Chief Deputy Solicitor General, Nathan A. Forrester, Senior Deputy Solicitor General, David M. Costello, Deputy Solicitor General, Darrick W. Monson, Assistant Solicitor General, Zachary Grouev, Solicitor General Fellow, John M. Guard, Chief Deputy Attorney General, James H. Percival, Chief of Staff, and Natalie P. Christmas, Assistant Attorney General, Office of the Attorney General Tallahassee, Florida, for Respondent Brad F. Barrios of Turkel Cuva Barrios, P.A., Tampa, Florida, for Amici Curiae Law Professors Jonathan B. Miller and Hilary Burke Chan of Public Rights Project, Oakland, California; and Matthew A. Goldberger of Matthew A. Goldberger, P.A., West Palm Beach, Florida, for Amici Curiae Current and Former Elected Representatives for Reproductive Justice Kimberly A. Parker, Lesley F. McColl, and Aleksandr Sverdlik of Wilmer Cutler Pickering Hale and Dorr LLP, Washington, District of Columbia, and Meghan G. Wingert of Wilmer Cutler Pickering Hale and Dorr LLP, New York, New York; and Sean Shaw of Swope Rodante, Tampa, Florida, for Amici Curiae American College of Obstetricians and Gynecologists, American Medical Association, and Society for Maternal-Fetal Medicine Miranda Schiller, Sarah M. Sternlieb, Robert Niles-Weed, and Elizabeth McLean of Weil, Gotshal & Manges LLP, New York, New York, Charlotte McFaddin and Caroline Elvig of Weil, Gotshal & Manges LLP, Washington, District of Columbia, and Edward Soto of Weil, Gotshal & Manges LLP, Miami, Florida, - 94 -

for Amicus Curiae Floridians for Reproductive Freedom Angela C. Vigil, Robert H. Moore, and Paul Chander of Baker & McKenzie LLP, Miami, Florida; and Francisca D. Fajana of LatinoJustice PRLDEF, New York, New York, and Emily M. Galindo of LatinoJustice PRLDEF, Orlando, Florida, for Amici Curiae LatinoJustice PRLDEF, Florida Access Network, National Latina Institute for Reproductive Justice, Esperanza United, and A.L. Brian J. Stack and Robert Harris of Stack Fernandez & Harris, P.A., Miami, Florida; and Sarah B. Gutman, Lilianna Rembar, and Caroline Soussloff of Cleary Gottlieb Steen & Hamilton, New York, New York, and Jennifer Kennedy Park of Cleary Gottlieb Steen & Hamilton, San Francisco, California, for Amici Curiae Sanctuary for Families, Legal Momentum, The National Organization for Women Foundation, The Rapid Benefits Group Fund, Women for Abortion and Reproductive Rights, Margaret A. Baldwin, JD, Professor Cyra Choudhury, Professor Donna K. Coker, Professor Zanita E. Fenton, Doctor Kathryn M. Nowotny, PhD, and Jodi Russell Eugene M. Gelernter and Caitlin A. Ross of Patterson Belknap Webb & Tyler LLP, New York, New York; and Courtney Brewer of The Mills Firm, P.A., Tallahassee, Florida, for Amici Curiae National Council of Jewish Women, Religious Coalition for Reproductive Choice, Catholics for Choice, Metropolitan Community Churches, National Council of Jewish Women - Greater Miami Section, National Council of Jewish Women - Palm Beach Section, National Council of Jewish Women - Sarasota Manatee Section, National Council of Jewish Women - Kendall Section, National Council of Jewish Women - Valencia Shores Section, Reconstructionist Rabbinical Association, Women's Rabbinic Network, Moving Traditions, Avodah, Bend the Arc: A Jewish Partnership for Justice, Jewish Council for Public Affairs, Jewish Orthodox - 95 -

Feminist Alliance, Union for Reform Judaism, Central Conference of American Rabbis, Men of Reform Judaism, Women of Reform Judaism, Rabbinical Assembly, Society for Humanistic Judaism, Muslim Women's Organization, Hindus for Human Rights, Sadhana: Coalition of Progressive Hindus, Women's Alliance for Theology, Ethics, and Ritual (WATER), SACRED (Spiritual Alliance of Communities for Reproductive Dignity), Faith in Public Life, and Florida Interfaith Coalition for Reproductive Health and Justice Jordan E. Pratt and Christine K. Pratt of First Liberty Institute, Washington, District of Columbia, for Amicus Curiae National Institute of Family and Life Advocates Alan Lawson, Paul C. Huck, Jr., Jason Gonzalez, Amber Stoner Nunnally, and Caroline May Poor of Lawson Huck Gonzalez, PLLC, Tallahassee, Florida, for Amicus Curiae Former State Representative John Grant Christopher Green, University, Mississippi; and Antony B. Kolenc, Naples, Florida, for Amici Curiae Scholars on original meaning in State Constitutional Law Lynn Fitch, Attorney General, Scott G. Stewart, Solicitor General, and Justin L. Matheny, Deputy Solicitor General, Mississippi Attorney General's Office, Jackson, Mississippi; and Samuel J. Salario, Jr. of Lawson Huck Gonzalez, PLLC, Tampa, Florida, for Amici Curiae Mississippi, Alabama, Arkansas, Georgia, Idaho, Indiana, Iowa, Kentucky, Louisiana, Missouri, Montana, Nebraska, North Dakota, Ohio, South Carolina, South Dakota, Texas, Utah, and West Virginia Stephen C. Emmanuel of Ausley McMullen, Tallahassee, Florida, - 96

for Amici Curiae Florida Conference of Catholic Bishops and the Florida Baptist Convention Jay Alan Sekulow, Jordan Sekulow, and Olivia F. Summers of American Center for Law & Justice, Washington, District of Columbia; and Edward L. White III of American Center for Law & Justice, Ann Arbor, Michigan, for Amicus Curiae Charlotte Lozier Institute Christopher E. Mills of Spero Law LLC, Charleston, South Carolina; and Chad Mizelle, Tampa, Florida, for Amicus Curiae American College of Pediatricians Edward M. Wenger of Holtzman Vogel Baran Torchinsky & Josefiak, PLLC, Washington, District of Columbia, for Amicus Curiae American Cornerstone Institute Carlos A. Rey, General Counsel, Kyle E. Gray, Deputy General Counsel, The Florida Senate, David Axelman, General Counsel, and J. Michael Maida, Deputy General Counsel, The Florida House of Representatives, Tallahassee, Florida, for Amicus Curiae The Florida Legislature Kenneth L. Connor of Connor & Connor, LLC, Aiken, South Carolina, for Amicus Curiae Liberty Counsel Action S. Dresden Brunner of S. Dresden Brunner, P.A., Naples, Florida, for Amicus Curiae The Prolife Center at the University of St. Thomas (MN) Patrick Leduc of Law Offices of Patrick Leduc, P.A., Tampa, Florida, - 97 -

for Amicus Curiae American Association of Pro-Life Obstetricians and Gynecologists Mathew D. Staver, Anita L. Staver, Horatio G. Mihet, and Hugh C. Phillips of Liberty Counsel, Orlando, Florida, for Amici Curiae Frederick Douglass Foundation, The National Hispanic Christian Leadership Conference, Fiona Jackson Center for Pregnancy, and Issues4life Foundation D. Kent Safriet of Holtzman Vogel Baran Torchinsky & Josefiak, PLLC, Tallahassee, Florida, for Amicus Curiae Susan B. Anthony Pro-Life America Denise M. Harle of Alliance Defending Freedom, Lawrenceville, Georgia, and Joshua L. Rogers of Alliance Defending Freedom, Scottsdale, Arizona, for Amicus Curiae Concerned Women for America - 98 -

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