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Geoffrey R. Stone

Geoffrey R. Stone

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DOMA Is Unconstitutional

Posted: 02/15/11 12:11 PM ET

A central question in the legal debate over the constitutionality of laws that discriminate against gays and lesbians (such as the federal Defense of Marriage Act) turns on the appropriate standard a court should apply in deciding whether the government's interest in treating gays and lesbians differently from other Americans is sufficiently weighty to justify the discrimination.

The Equal Protection Clause of the Fourteenth Amendment, which provides that no state shall deny any person "the equal protection of the laws," is the relevant constitutional text. But what does it mean?

A simple interpretation might suggest that the government may never treat people differently. But that is an implausible understanding of the text. All laws treat people differently. Speed limit laws treat people who drive 75 miles per hour differently than those who drive 45 miles per hour. People who have gone to medical school can practice medicine; others cannot. Citizens can vote; aliens cannot. In-state college students pay a lower tuition than out-of-state college students. People over 65 receive certain benefits that are not available to people under 65. And so on.

Surely, the Equal Protection Clause cannot mean that all such laws are unconstitutional. Recognizing this, the Supreme Court has held that most laws that treat some people differently from others are constitutional if the difference in treatment rationally furthers a legitimate government interest. As illustrated by the examples noted above, almost all laws pass this test.

But this does not exhaust the meaning of the Equal Protection Clause. The primary goal of the Clause, which was enacted in the wake of the Civil War, was to prohibit laws that discriminate against African-Americans. To effectuate that purpose, the Supreme Court has held that laws that discriminate against African Americans violate the Equal Protection Clause unless they pass "heightened scrutiny" -- that is, unless the discrimination is necessary to further an important government interest.

But is heightened scrutiny limited only to laws that discriminate against African Americans? That would be odd, because the text says nothing about limiting its core protection to African Americans. Rather, the text is open-ended, and it is therefore reasonable to assume that discrimination against African Americans was seen not as a singular problem, but as a paradigmatic one. That is, it is the paradigm of a certain type of discrimination that is especially problematic under the Equal Protection Clause.

Applying this understanding, the Supreme Court has concluded that the proper application of the Clause requires the use of heightened scrutiny to test the constitutionality of laws that discriminate against African-Americans or that discriminate against other groups in society that are similar to African Americans for purposes of the Equal Protection Clause.

What, though, does it mean to be "similar to African Americans for purposes of the Equal Protection Clause"? The Supreme Court has looked to several factors. First, it considers whether the group has been subjected to a history of discrimination. This is relevant both because such a history suggests that there may be prejudices at work in society that can taint the fairness of the political process, and because it is particularly unfair to heap additional burdens on groups that have been systematically discriminated against in the past.

Second, the Court considers whether the group can effectively protect itself in the political process. If a group does not have that ability, then it is especially vulnerable to the pernicious effects of prejudice and intolerance.

Third, the Court considers whether the group is objectively different in some meaningful way that would logically justify treating its members differently than others. For example, it is sensible to treat people born with severe learning disabilities differently in some ways than others, but it is not sensible to assume that race is relevant to an individual's capacity to function fully in society.

Finally, the Court considers whether the group's status is immutable. That is, African Americans cannot change their race. Therefore, laws that discriminate against African Americans are particularly unjust, because it is unfair to disadvantage people for characteristics that are largely beyond their control.

Considering all these factors, the Supreme Court has concluded, for example, that laws that discriminate against ethnic minorities and women are sufficiently similar to laws that discriminate against African Americans to justify testing them by heightened scrutiny.

What, though, of gays and lesbian? How do they fare under this analysis? The first three criteria seem clear. There can be no doubt that gays and lesbians have been subjected to a long and often tragic history of discrimination -- even to the point that they were declared to be criminals. They are certainly a political minority, even more so than African Americans and women, and historically they have been particularly powerless politically because they were forced into the closet and were therefore effectively unable to represent their interests in the political process. And there is no reason to believe that gays and lesbians are any less able to function well in society than anyone else -- even to the point that they are now permitted to serve openly in the military.

The only criteria on which there is any question is the fourth, but there is a general consensus today that one's sexual orientation is not a matter of choice. Although there are those who dispute this proposition, the great weight of the evidence cuts the other way. If you are a heterosexual, imagine if you suddenly had to lead your life as a homosexual. All of your instincts would cut strongly in the opposite direction. You might be able to force yourself to engage in sex with people of the same sex, but it would seem wholly unnatural and, more importantly, you would continue (secretly) to be attracted to persons of the opposite sex, even if you could no longer legally act on those attractions. This is pretty much what sexual orientation means, and in its deepest sense the orientation itself seems to be beyond one's own control. One can (perhaps) change one's conduct, but not one's orientation.

Thus, like laws that discriminate against African Americans, ethnic minorities and women, laws that discriminate against gays and lesbians must be tested by heightened scrutiny under the Equal Protection Clause. And, as a practical matter, tested by that standard, it is difficult to think of any interest furthered by the Defense of Marriage Act that would enable that misguided law to pass constitutional muster.

 
 
 
A central question in the legal debate over the constitutionality of laws that discriminate against gays and lesbians (such as the federal Defense of Marriage Act) turns on the appropriate standard a ...
A central question in the legal debate over the constitutionality of laws that discriminate against gays and lesbians (such as the federal Defense of Marriage Act) turns on the appropriate standard a ...
 
 
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the crustybastard
I could be worse, and have been.
01:09 AM on 02/25/2011
Well done, professor!
Syllogizer
Barely Left of Pobedonostsev
03:12 PM on 02/23/2011
Maybe Stone find it "hard to see", but many of us do not: we can see a government interest justifying the heightened scrutiny. The problem is that the government has already mostly abandoned that interest. Which one? The interest of securing the upbringing of future citizens by creating the societal conditions conducive to healthy family life, with the child being able to exercise the UN guaranteed right of knowing both mother and father, having both provide a healthy environment for the child to grow up in.

But now as it is, both state and federal governments have considered the individual right of the parents to divorce as being more important than the rights of the child. No surprise then, that the government now no longer sees the need to keep marriage 'marriage'.
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the crustybastard
I could be worse, and have been.
01:11 AM on 02/25/2011
So only children born into families with both biological parents have any rights worth promoting?
02:32 PM on 02/23/2011
An interesting notion that the "executive" branch charged with executing laws passed by the elected representatives of the people, without direction from the judiciary charged with interpreting constitutionality, can simply change the law with the stroke of a pen. So, when President Palin is in charge, she will just be able to state that the ACA health law is unconstitutional, and drop its defense in court? Why didn't you say so in the first place? You could have saved us all a lot of time and energy.
12:12 AM on 02/18/2011
To David N Taiwan. I couldn't respond to your last comment as the thread ran out of room I hope you see this reply to that comment. That was well stated, insightful and in a sincere spirit. I respect the integrity woven through your words to much to lie to you and say I now wholeheartedly support SSM. It would just be too destructive to the ideology that, as they say, makes me, me. But your heartfelt convictions will be the last post I respond to regarding DOMA and related issues. I will not be a stumbling block to you. I must confess a short while before I read this I had enjoyed a hamburger at the local DQ. Good luck to ya.
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David N Taiwan
67 YO American in Taiwan
12:36 AM on 02/18/2011
Noted.

Thank you.
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BeninOakland
Don't tell me you love me. Let me guess.
03:15 PM on 02/17/2011
Mr Greenlee I wish i had time to write. You seem to be a nicesincere person. But misguided and not really thinking.

you wrote: " In my opinion you aren’t harming Christians in their personal lives but you’re harming the fabric of overall society."If i am not hurting anyone, how am i harming society? Please be specific. You don't just get to say it. Let's have some proof. how does my living my life, with the same legal rights, protections, and responsibilities as heterosexuals, harm ANYONE? Yet denying me legal marriage does a great deal of demonstrable harm to me, my partner, and our families.

The homophobia of the world has done incalcuble harms to gay people for centuries, people who have done nothing to deserve it, except to be different. Do you want to talk about immorality, about crimes against nature? Let's talk about THAT immorality, the crimes against OUR natures.

A good argument couldbe made that homobigotry has hurt our society greatly,if, among many other things, it led to the disaster known as Bush II,

It's a sin not to believe in Jesus, according to numerous Christians. Shall we legally disadvantage Jews and Hindus the way you are willing to disadvantage gay people? Did not the immorality of the Jews in refusing to recognize Jesus lead to 2000 years of virulent anti-semitism,justified by religion?

and if you quote leviticus, don';t leave out the deathpenalty part. Unless, of course, you don't REALLY believe the word of god.
11:20 PM on 02/17/2011
Thank you for your considerate words, this is not the first time I've been accused of not thinking. In answer to original question asked of me about harm done to Christians, the result of no personal harm inflicted on Christians pertained to forgiveness. I didn't say that no one was being harmed and I agree there's unmerited harm done to persons in SmSx rltnshps. About being specific, I've done my best to not rattle off statistics relating to societal moral issues and same sex rltnshps or my firsthand experience with person(s) SmSx rltnshps. If that is truly your wish I will accommodate you. Would you believe them if I did? I would like a constructive exchange regarding immorality and its consequences. I don't think our idea of crimes against nature is the same, as I view SSM as an assault on nature. I'll need your help in how homobigotry has hurt our society greatly, except with the obvious products of any bigotry, and not sure how that led to disaster you believe to be Bushll. I'ts not a sin to exercise freewill and not believe in Jesus, but there are consequences in this life and the next. Religious freedom is constitutionally protected, I don't think any of us want that to change. About the 2000 years, are you making my argument pertaining to consequences of a nation turning it's back on God? I wasn't asked about death penalty, I was asked about slavery in the bible that I believe.
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BeninOakland
Don't tell me you love me. Let me guess.
12:05 PM on 02/18/2011
I would believe anything demonstrably the truth. You are entitled to your opinions, not your facts. you are not allowed to say something, and then pretend you didn't. you said homosexuality harms the fabric of society, but have provided not even a single example,

you're entitled to believe homosexuality is immoral, I actually have no problem, though I think it's silly, misinterpretation of scripture, wrongheaded, and ultimately very destructive to people you don't know, know nothing about, and who have done you no harm except to exist..

I am a tax paying, law abiding, productive, contributing member of society, well thought of by friends, colleagues, family, neighbors, and my pastor. I am in a stable long term relationship. We have seen each other through illness, crisis. My marriage benefits society in exactly the same way as any heterosexual's. Exactly how have i harmed society?

Homosexuality an assault on nature? Pure ignorance at best, unmitigated bias at worse. It has existed in every society for all time, been observed in thousands of species. It is normal and natural.

how does homophobia harm society? How many children were fed/educated for the $80Million spent on prop. 8? How many kids have been bullied into suicide? How many gay people have been attacked for the crime of walking down the street? The reality of childmolestation-- primarily in the family-- has been hidden by the belief that gay men are the abusers. How many soldiers died becuase of DADT and no arabic translators?
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eyecon
Retired CEO & Quality-Mgmt Consultant
08:14 PM on 02/16/2011
Before I log off, let me quote the trial judge in the criminal trial that became the predicate for Loving v Virginia. I sort of has a familiar ring to it:

"Almighty God created the races white, black, yellow, malay and red, and he placed them on separate continents. And but for the interference with his arrangement there would be no cause for such marriages. The fact that he separated the races shows that he did not intend for the races to mix."

There is little doubt why loving was decided 9-0.
Syllogizer
Barely Left of Pobedonostsev
03:02 PM on 02/23/2011
You say "little doubt", but since the citation you give has so LITTLE to do with it, I have to doubt that YOU understand why Loving v. Virginia was decided 9-0.

The REAL reason is that it was just too obvious to all the justices, that the RIGHT to marriage was the right for any man to marry any woman, and has nothing to do with the race of either man or woman. But it is undeniable (though you deny it), that the justices really did base their argument on the fact that they were man and woman. Otherwise ALL their passages about marriage being such a fundamental right would have been legally groundless.
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the crustybastard
I could be worse, and have been.
01:25 AM on 02/25/2011
You haven't read the case, have you?
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eyecon
Retired CEO & Quality-Mgmt Consultant
08:01 PM on 02/16/2011
DOMA is a dishonest construct. First of all it does nothing to defend marriage - not that marriage needs defending in the first place. More importantly, there does not exist a legitimate argument that marriage equality has any effect, whatsoever, on "traditional" marriage. Indeed, given that the divorce rate in Massachusetts continues to decline I could make an argument that marriage equality benefits traditional marriage.

That, too, would be baloney because of the sample size and the potential confusion of correlation and causation. However, in this debate there's enough cold cuts floating around to feed Somalia for a decade at least. Not to mention hyperbole ;-)

The purpose of DOMA is to destroy "full faith and credit" without appearing to destroy full faith and credit and to do so explicitly and solely as it applies to gay people. Thus all marriages consummated in Massachusetts are valid in Mississippi except the ones that Mississippi doesn't like. - the gay ones. It is odious and discriminatory per se.
Syllogizer
Barely Left of Pobedonostsev
03:04 PM on 02/23/2011
Well, you could make the argument, but it would still be fallacious: it is an obvious fallacy (post hoc ergo propter hoc) argue that "marriage equality benefits traditiona­l marriage". You even combine it with another fallacy, the non representative sample, by taking only one SMALL state, Massachussetts.
09:51 AM on 02/24/2011
But what is the evidence that says the opposite? That same-sex marriage harms traditional marriage?

Yep, you got it. None.
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Christopher Erwin Hogan
03:19 PM on 02/16/2011
"Why did Clinton sign this law?"

Clinton did what he HAD to do, otherwise the congress back then would have amended the U.S. Constitution to ban marriage from gay people. If that had happened, then even the U.S. Supreme Court would not be able to strike it down, and there would be absolutely NO marriage equality in ANY state until a later congress repealed it with 2/3 majority in both houses and 3/4 of the state legislatures. So DOMA was the lesser of two evils, because with a constitutional amendment in place the first gay people to get married would probably not have even been born yet.
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LeftRight
TANSTAAFL
09:25 PM on 02/16/2011
Actually, there was no way that they would have been able to amend the Constitution for that, it's too difficult to amend it. Between needing 2/3 of BOTH houses of Congress or 2/3 of the states applying to Congress and then needing 3/4 of the states to approve it....
Syllogizer
Barely Left of Pobedonostsev
03:05 PM on 02/23/2011
True. Christopher's post is typical of the misinformation about this issue, the misinformation rife both here in HP and elsewhere on the Internet.
03:00 PM on 02/16/2011
Legally, argument for same sex marriage makes sense within the scope of consenting adults. What many seem to forget including Christians, is that Christians view everything from a biblical moral perspective. What Christians fear is that as biblical morality weakens and fails so will our country. Their fears aren’t completely unjustified. Man’s God given freedom was ignored in favor of profit; result-the Civil War and racial inequalities. Increase in adultery and sexual promiscuity; result-climbing divorce rate and collapse of stable family models leading to increase in juvenile crime and teen suicide. Removal of God from public schools, U.S. education now failing&students fear for their safety in the classroom. Christians feel the need to enter the legal and political arena because we see a pattern of self-destruction and must respond. Homosexuality is an element within that pattern. The question is do we want God within our borders? If we do then it’s necessary to form our lives and laws within a TRUE Christian ideology. TRUE being one built on the biblical truth, “the greatest of these is love.” Christians if your actions aren’t motivated by love for you fellow man(no pun intended) then they are damaging and divisive. If you’d rather brandish God’s sword than demonstrate His charity, rethink your approach. At least in same sex relations there aren’t unwanted pregnancies leading to abortions. Morally I don’t support SSM, legally??????? Anyone else as confused about moral legalities and legal moralities?
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Ioan Lightoller
Proud Gay Pagan Man, Living Happily With Husband
05:03 PM on 02/16/2011
This country just happens to be a nation of many faiths--or none at all. I understand wanting to live your faith, but why should I not be allowed to legally marry my husband? Because your holy book says so? I am a Pagan and my coven priestess would love to legally marry us, but she cannot--because of DOMA. What harm are we doing to Christians? None so far as I can see--but they want the right to be able to say if my Canadian marriage should one day be able to be accepted along with all the striaght Canadian marriages. Homosexuality harms no one. Again, I ask, why should YOUR faith determine my life? And how would my getting my Canadian marriage recognition harm you or anyone else?
11:55 PM on 02/16/2011
This issue is a struggle for me because I believe in a persons right to live their life absent of gov’t intrusion, but the laws of the country in which I live portray what I believe to be right and wrong. That holy book is not mine, its God’s. If I don’t believe that I may as well disown my conscience. In my opinion you aren’t harming Christians in their personal lives but you’re harming the fabric of overall society. Your personal choice is not subject to my condemnation or acceptance, but my choices are. I can no more be passive about homosexuality then I could be if you were being assaulted for engaging in it. If you convince me to abandon what God has put in my heart, you’ve convinced me to betray God. I can no more do that than you can abandon your partner. So I can empathize with your emotional plea but I can’t endorse the legalization of SSM. If it becomes the law of the land I will abide by it, but I will not agree with it. My faith doesn’t determine the path of your life, it determines mine. It’s my intent that my faith be used in humble service to others and to God. It’s just God is my priority.
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talkstocoyotes
08:58 AM on 02/17/2011
This is a common pattern: an insistence that granting taxpaying citizens civil rights should be considered in the context of what a religious group's beliefs are. Ironically, some of the people who insist that this should determine civil law (invariably after they've "struggled" with it are the same ones who are seriously spooked over the specter of Sharia law. At the base, that's not an objection to a religious group dictating civil law for everybody; it's just a reaction to what the objector considers to be competition.
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persuter
06:04 PM on 02/16/2011
Mr. Greenlee, you are simply making up causes which fit into your theory. The Bible is packed full of slavery and was repeatedly used to justify it - your insistence that the Bible somehow obviously disallows slavery and that everyone "ignored" it in favor of profit is completely ahistorical. Similarly, your identification with the "removal of God from public schools" and the U.S. education system "now failing" is simply completely without any basis in fact.

Christians have always been in the legal and political arena. Perhaps you've heard of the Scopes Monkey trial, for example? Prohibition? The idea that they are only entering it now is simply, again, completely ahistorical.
01:17 AM on 02/17/2011
You are correct! If I said Christians are just now entering into law and politics, I was not only mistaken, but, shouldn't have roped that elephant, wrong! As far as slavery, you're right again. The bible is full of slavery. Slavery to men and slavery to sin. However freedom is given to all men at their birth, the same point they become enslaved to sin. Ironic ain't it? What happens after that is a result of what man does. Even so God addressed the humane treatment of the bondservant and slave. A good starting point is Leviticus 25:39( I hope I'm allowed to list that) It wasn't my intent to make up cause and effect scenarios to further a theory. Surely no one does that, certainly not Darwin. Why would anybody put monkeys on trial? I was only trying to demonstrate the possible reasonableness behind the cause and effect scenario through certain very real points in our history. Speaking for no one but myself I do believe in the negative effects I listed but I haven't created a correlative chart, that might be a good project. There has always been God's laws and for sometime man's laws and occasionally they clash. I am subject to God's laws. I choose to obey man's laws. I've even enforced man's laws. Thats ironic too ain't it? I wish we had more time and space to discuss this. I appreciate your input and willingness to dialogue.
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alterego55
Flash your citations or leave!
02:48 PM on 02/16/2011
Geoffry, this is a most excellent analysis. I've bookmarked it for future reference.
MrStat1
I believe in the rule of law
01:44 PM on 02/16/2011
It doesn't matter what this guy thinks. The only opinion that matters is from the Supreme Court, not some college professor.
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Busbydav
If you liked it then you shoulda put 3 rings in it
02:19 PM on 02/16/2011
You do realize he is the one arguing the case right?
02:21 AM on 02/17/2011
You made me laugh. I didn't realize he was, appreciate the heads up
Syllogizer
Barely Left of Pobedonostsev
03:16 PM on 02/23/2011
He is? Then based on his article, I can predict with confidence: the Opus Dei enlightened Justices will see through the fallacies and sophistries of Stone's argument and rule against him.
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Jason N
Proud Firebagger Lefty
02:59 PM on 02/16/2011
Than I assume if the SCOTUS votes 5-4 that DOMA is unconstitutional, or that gay marriage bans are as well, you'll support those decisions and not call them "activist judges shoving immorality down our throat"?
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thinkingwomanmillstone
great, green, globs of greasy grimey GOPerspeak.
04:06 PM on 02/16/2011
of course not. and btw MrStat1, He's not just "some college professor"...he's a pre-eminent constitutional law professor.
04:19 PM on 02/16/2011
You know, either way they vote, they'll be labeled activist judges. It'd be nice if we could put it to a vote. I'd rather the country decide than a handful of folks that literally are in an ivory tower. I'm a simple-minded person and now and then it shows. However, I am interested in what the rest of the country thinks.
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blueken
Finger Picking blues man
01:40 PM on 02/16/2011
From a stand up comic on Letterman the other night: "God loves homosexuals just as much as heterosexuals, he loves them exactly the same. Now you might say "How dare you pretend to know what God thinks?" To you I would say "Good point" think about it.
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thinkingwomanmillstone
great, green, globs of greasy grimey GOPerspeak.
04:07 PM on 02/16/2011
perfect f/f
04:26 PM on 02/16/2011
You can read his "ruling" handed down by His Supreme Court. Just sayin'.
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the crustybastard
I could be worse, and have been.
02:33 AM on 02/25/2011
Do you suppose that God made a few people gay just to test those few gay people? Doesn't it seem more likely he made a few people gay to test the masses of the faithful?

"Whatsoever you do to the least of my brothers, that you do unto me."

Just sayin'.
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01:11 PM on 02/16/2011
BFD, Congressmen now admit most of what they do is not authorized by the Constitution. There seems to be contempt for the Constitution in today's government. It's viewed as a quaint anachronism which must be paid lip service before being ignored.
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01:10 PM on 02/16/2011
The main purpose of government is to regulate society. If everyone who wanted to marry was able to marry we wouldn't need the governemnt. But we depend on government regulations to keep a well ordered society. If government just allowed everyone who wanted to marry why shouldn't they also let people sell what ever kind of food they wanted even it was spoiled? How would we stop the Berrnie Madoffs if everyone just was able to trade stocks as they wanted without regulations? Government is needed to place limits on people so they don't just do anything they want. This has to be a fact in a well regulated democratic society. If not then we live in anarchy.
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01:34 PM on 02/16/2011
Exactly which assertion in your bloviated post would you like dismantled first?
01:43 PM on 02/16/2011
That is quite possibly the dumbest false analogy/slippery slope argument I have read in a long time.
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StevenWells
Objects in the avatar are larger than they appear
02:08 PM on 02/16/2011
Ya think?

He may actually be onto something. I know that the only reason my partner of 30 years and I wish to get married is to cause anarchy.

Now, where's that "sarcasm" button?
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Busbydav
If you liked it then you shoulda put 3 rings in it
02:21 PM on 02/16/2011
Oh it gets better just wait...Dana1982 replied to my post below and used an analogy of cigarette smokers vs those who wish to smoke pot. I keep waiting for it to show up. Moderation is soooo slow lately!
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12:44 PM on 02/16/2011
What infuriates me and many others is the persistent intellectual dishonesty of people who oppose gay legal equality (or who simply hate gays, but won't admit their true motivation - to put it in other words). For this bigotry to be maintained our society's values demand that the "transgression" of being gay be placed in the sphere of morality (the US isn't Nazi Germany, where they were far more murderous toward their gay citizens, but where they were also entirely intellectually honest in making no pretensions that sexual orientation isn't biologically based) and moral judgment demands, as a necessary precondition, the possibility of choice (Hating people based on immutable characteristics doesn't fly in our society, so it must be maintained that gays "choose it" and choose to face a life of prejudice, dehumanization and rejection for some utterly inexplicable reason). Not all gay people "fail" to conform to heterosexual gender norms in their behavior ( behavior in the broadest sense - how people literally, physically move, what they say, how they say it, the interests that they express, etc. etc.) or their basic appearance (some of us gays just LOOK gay and we all know it) but many do. This is the knowledge of every junior high kid (Remember?) but in indulging the antigay bigots' point of view we, as adults in this society, are all supposed to pretend that we never knew it.
Syllogizer
Barely Left of Pobedonostsev
02:54 PM on 02/23/2011
You should be infuriated at your own persistent intellecdtual dishonesty instead. It is not about 'equality', no matter how often that political slogan is repeated.