Anda di halaman 1dari 291

1

UNITED STATES DISTRICT COURT


EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

APRIL DEBOER, individually and as
Parent and next friend of N.D.-R, R.D.-R,
and J .D.-R, minors, and J AYNE ROWSE,
individually and as parent and next friend
of N.D.-R, R.D.-R, and J .D.-R, minors,

Plaintiffs, No. 2:12-cv-10285-BAF-MJ H
HON. BERNARD A. FRIEDMAN
v. MAG. MICHAEL J . HLUCHANIUK

RICHARD SNYDER, in his official
capacity as Governor of the State of
Michigan, BILL SCHUETTE, in his
official capacity as Michigan Attorney
General, and LISA BROWN, in her
official capacity as Oakland
County Clerk,

Defendants.


MOTION OF AMICI CURIAE MICHIGAN LAW PROFESSORS
FOR LEAVE TO FILE BRIEF IN SUPPORT OF PLAINTIFFS

Amici curiae Michigan Law Professors (the Law Professors) respectfully
move the Court for an Order granting them leave to file the attached brief as amici
curiae in support of plaintiffs. In support of their motion, the Law Professors state
that they are not parties and are not related to any parties in this case. No counsel
for a party authored this brief in whole or in part, and no counsel for a party or
2:12-cv-10285-BAF-MJH Doc # 65 Filed 08/12/13 Pg 1 of 3 Pg ID 1001
2

party made a monetary contribution intended to fund the preparation or submission
of this brief.
Respectfully submitted,
/s/Alan M. Gershel
Brendan Beery (P59464) Alan M. Gershel (P29652)
Of Counsel Counsel of Record
Thomas M. Cooley Law School Thomas M. Cooley Law School
9445 Camden Field Pkwy. 2630 Featherstone
Riverview, FL 33578 Auburn Hills, MI 48236
Phone: (813) 419-5100 ext. 5106 Phone: (248) 751-7800 ext. 7765
beeryb@cooley.edu gershela@cooley.edu

Daniel R. Ray (P63758) Gina M. Torielli (P45275)
Of Counsel Of Counsel
Thomas M. Cooley Law School Thomas M. Cooley Law School
3475 Plymouth Rd. 3475 Plymouth Road
Ann Arbor, MI 48105 Ann Arbor, MI 48105
Phone: (734) 372-4900 ext. 8775 Phone: (734) 372-4900 ext. 8732
rayd@cooley.edu toriellg@cooley.edu

Frank C. Aiello (P63151) Emily S. Horvath (P60186)
Of Counsel Of Counsel
Thomas M. Cooley Law School Thomas M. Cooley Law School
2630 Featherstone 300 S. Capitol Ave.
Auburn Hills, MI 48236 Lansing, MI 48933
Phone: (248) 751-7800 ext. 7764 Phone: (517) 371-5140 ext. 2819
aiellof@cooley.edu horvathe@cooley.edu

Karen L. Chadwick (P33163) Marjorie B. Gell (P46974)
Of Counsel Of Counsel
Thomas M. Cooley Law School Thomas M. Cooley Law School
3475 Plymouth Rd. 111 Commerce Ave. SW
Ann Arbor, MI 48105 Grand Rapids, MI 49503
Phone: (734) 372-4900 ext. 8730 Phone: (616) 301-6800 ext. 6823
chadwick@cooley.edu gellm@cooley.edu

Dated: August 12, 2013
2:12-cv-10285-BAF-MJH Doc # 65 Filed 08/12/13 Pg 2 of 3 Pg ID 1002
3


CERTIFICATE OF SERVICE

I hereby certify that on August 12, 2013, I electronically filed the foregoing
document(s) with the Clerk of the Court using the ECF system, which will provide
electronic notice and copies of such filing to the parties: Motion of Amici Curiae
Michigan Law Professors for Leave to File Brief in Support of Plaintiffs, and Brief
of Michigan Law Professors as Amici Curiae in Support of Plaintiffs.
/s/Alan M. Gershel (P29652)
Thomas M. Cooley Law School
2630 Featherstone
Auburn Hills MI 48236
Phone: (248) 751-7800 ext. 7765
gershela@cooley.edu

2:12-cv-10285-BAF-MJH Doc # 65 Filed 08/12/13 Pg 3 of 3 Pg ID 1003
1

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

APRIL DEBOER, individually and as
Parent and next friend of N.D.-R, R.D.-R,
and J .D.-R, minors, and J AYNE ROWSE,
individually and as parent and next friend
of N.D.-R, R.D.-R, and J .D.-R, minors,

Plaintiffs, No. 2:12-cv-10285-BAF-MJ H
HON. BERNARD A. FRIEDMAN
v. MAG. MICHAEL J . HLUCHANIUK

RICHARD SNYDER, in his official
capacity as Governor of the State of
Michigan, BILL SCHUETTE, in his
official capacity as Michigan Attorney
General, and LISA BROWN, in her
official capacity as Oakland
County Clerk,

Defendants.


BRIEF OF MICHIGAN LAW PROFESSORS
AS AMICI CURIAE IN SUPPORT OF PLAINTIFFS

I. Statement of Interest of Amici Curiae.

These amici are professors of law who teach law in Michigan, and who
research and publish scholarly articles on various federal and state constitutional
and other legal issues. Amici have a common professional interest in one of the
issues presented in this case: does a state constitutional provision that denies
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 1 of 35 Pg ID 1004
2

recognition to a class of citizens based upon sexual orientation also deny that class
equal protection of the laws under the controlling rational basis standard?
1

II. Introduction and Summary of Argument.

Discrimination based on immutable traits or characteristics is always an
uncomfortable subject, especially when that discrimination is justified by appeals
to family, children, and religion. But the lesson should by now be clear, since it
was delivered more than a century ago. There is no caste here, and our
Constitution neither knows nor tolerates classes among citizens. Plessy v.
Ferguson, 163 U.S. 537, 559 (1896) (Harlan, J ., dissenting). Mich. Const. art. I,
25 (the amendment or the MMA) violates the equal protection principle of the
Fourteenth Amendment to the Constitution.
We have been here before. Beneath the surface of the proffered justifications
for the amendment, we find a state constitutional provision that irrationally
subordinates a relatively powerless minority because of disdain for the
characteristic sexual orientation that defines it. The Supreme Courts decisions
in Romer v. Evans, 517 U.S. 620 (1996), and United States v. Windsor, 570 U.S.

1
Amici appear in their individual capacities. Institutional affiliations are listed here
for identification purposes only. No counsel for a party authored this brief in
whole or in part, or made a monetary contribution intended to fund the preparation
or submission of this brief.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 2 of 35 Pg ID 1005
3

___, 133 S. Ct. 2675 (2013) lead the way, and that way is clear.
2
The MMA fails
the rational basis standard described in those cases for two reasons.
First, the amendment was motivated by the same kind of discriminatory
animus the Supreme Court found in Romer and Windsor. This animus is evident in
statements made by the drafters and principal proponents of the MMA. Further,
because the MMA was one of more than a dozen anti-same-sex marriage initiatives
put up nationwide for a vote during the 2004 elections, the amendment was part of
a pattern and practice of discrimination against gays and lesbians designed to
assure their continuing legal and political inferiority.
Second, the amendment is a facially overbroad, status-based enactment, one
that punishes same-sex couples not for being morally blameworthy but because of
who they are. Gays and lesbians are set apart from all others on the basis of a
single characteristic sexual orientation and their relationships are denied any
recognition under Michigan law. The MMA makes same-sex relationships
invisible in the eyes of the State and deprives citizens in those relationships of the
benefits and protections, as well as the burdens, of Michigan law. Little need be

2
Lawrence v. Texas, 539 U.S. 558 (2003), is also instructive. There, the Supreme
Court ruled that Texas had no legitimate government interest that would justify
criminalizing the consensual, private, intimate conduct of adults. As a decision
grounded in substantive due process, though, it does not speak directly to the
circumstance faced by plaintiffs here.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 3 of 35 Pg ID 1006
4

said about such a law except that [i]t is not within our constitutional tradition to
enact laws of this sort. Romer, 517 U.S. at 633.
III. Controlling Law.

Under Supreme Court and Sixth Circuit precedents, classifications based on
sexual orientation are subject to rational basis review.
3
In most cases, of course,
rational basis review means the government wins. Courts usually defer when the
political process classifies citizens, provided that the classification is not drawn
against suspect or quasi-suspect groups. As the Supreme Court said in New
Orleans v. Dukes, 427 U.S. 297, 303 (1976) (per curiam), [O]ur decisions
presume the constitutionality of statutory discriminations and require only that
the classification challenged be rationally related to a legitimate state interest.
But when evidence shows disparate treatment of a politically unpopular
group, more careful judicial review is required. The Second Circuit, applying
intermediate scrutiny in Windsor, said that several courts have read the Supreme
Courts recent cases in this area to suggest that rational basis review should be
more demanding when there are historic patterns of disadvantage suffered by the

3
Amici recognize, and fully support, plaintiffs good faith argument to extend
intermediate scrutiny to sexual orientation classifications. See, e.g., Plaintiffs
Combined Brief in Opposition to Defendants Motion to Dismiss Count II, Doc.
No. 46 (filed Dec. 5, 2012), at 5-7 [hereinafter Plaintiffs Combined Brief]. We
simply acknowledge here that neither the Supreme Court nor the Sixth Circuit
have, to this point, seen fit to examine those classifications under strict or
intermediate scrutiny.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 4 of 35 Pg ID 1007
5

group adversely affected by the statute. Windsor v. United States, 699 F.3d 169,
180 (2d Cir. 2012) (quoting Massachusetts v. United States, 682 F.3d 1, 10-11 (1
st

Cir. 2012)), affd, United States v. Windsor, 570 U.S. ___, 133 S. Ct. 2675 (2013).
Or, as the First Circuit put it in the Massachusetts case, the Supreme Court
has now several times struck down state or local enactments without invoking any
suspect classification. In each, the protesting group was historically disadvantaged
or unpopular, and the statutory justification seemed thin, unsupported or
impermissible. Massachusetts, 682 F.2d at 10.
The history of this more demanding review is traced to United States
Dept. of Agriculture v. Moreno, 413 U.S. 528 (1973), where the Supreme Court
stated that animus is not a legitimate state interest. [I]f the constitutional
conception of equal protection of the laws means anything, it must at the very
least mean that a baredesire to harm a politically unpopular group cannot
constitute a legitimate government interest. Id. at 534. Not surprisingly, the idea
that the government cannot target an unpopular group and then seek judicial cover
in rationality review has found a meaningful place in cases involving anti-gay
discrimination.
4


4
A similar analysis can be seen in Cleburne v. Cleburne Living Center, Inc., 473
U.S. 432 (1985), involving denial of a group home permit for a facility to house
mentally disabled persons. J ustice White concluded that requiring the permit in
this case appears to us to rest on an irrational prejudice against the mentally
retarded . Id. at 450.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 5 of 35 Pg ID 1008
6

Romer v. Evans, 517 U.S. 620 (1996), was the first Supreme Court decision
to apply the Moreno rule to a case involving the rights of gays and lesbians. A
Colorado ballot measure denied gays and lesbians the protection of municipal anti-
discrimination ordinances. J ustice Kennedy, citing Moreno, wrote that laws of the
kind now before us raise the inevitable inference that the disadvantage imposed is
born of animosity toward the class of persons affected. Romer, 517 U.S. at 634.
More recently, in Windsor, the Supreme Court ruled invalid, under the equal
protection component of the Fifth Amendment Due Process Clause, 3 of the
federal Defense of Marriage Act. Citing Moreno, J ustice Kennedy instructed that
[i]n determining whether a law is motivated by an improper animus or purpose,
discriminations of an unusual character especially require careful consideration.
Windsor, 133 S. Ct. at 2693 (quoting Romer, 517 U.S. at 633). The Sixth Circuit,
too, has applied the animus rule to claims involving gays and lesbians. A mere
desire to effectuate ones animus against homosexuals can never be a legitimate
governmental purpose . Davis v. Prison Health Services, 679 F.3d 433, 438
(6
th
Cir. 2012) (quoting Stemler v. City of Florence, 126 F.3d 856, 874 (6
th
Cir.
1997)).
Decisions like these did not employ rational basis review in its minimalist
form; instead, the Court rested on the case-specific nature of the discrepant
treatment, the burden imposed, and the infirmities of the justifications offered.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 6 of 35 Pg ID 1009
7

Massachusetts, 682 F.2d at 10. The J ustices themselves are well aware of this
more searching form of rational basis review, Lawrence v. Texas, 539 U.S. 558,
580 (2003) (OConnor, J ., concurring), and at least one J ustice has urged the Court
to acknowledge more formally this second order rational basis review.
Cleburne v. Cleburne Living Center, Inc., 473 U.S. 432, 459-60 (1985) (Marshall,
J ., concurring in part and dissenting in part).
The Supreme Courts decisions in Moreno, Romer, and Windsor should be
understood as modifying the burden of persuasion in cases involving politically
unpopular groups. In the typical rational basis case, the challenger has the burden
of showing that no legitimate interest justifies the law or that the means adopted
are not rationally related to some legitimate end. See, e.g., Dukes, 427 U.S. at 303.
But even on rational basis review, when the law targets a politically
unpopular group, the Supreme Court has said, [W]e insist on knowing the relation
between the classication adopted and the object to be attained. Romer, 517 U.S.
at 632. In a case like Romer or Windsor, once the challenger has shown that a law
targets a politically unpopular group, Moreno, 413 U.S. at 534, the burden shifts
to the state to satisfy a more careful means-ends inquiry. Stated a bit differently, by
insisting on knowing the relation between the classification drawn and the interest
to be obtained, the Supreme Court has mandated that, in cases involving politically
unpopular minorities, the burden of persuasion rests with the State.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 7 of 35 Pg ID 1010
8

In this case, Michigan bears the burden of proffering some legitimate
interest for the MMA, and it must show that isolating gays and lesbians serves that
interest. Since the State has failed to offer any such proof, this Court is left with
the inevitable inference that the disadvantage imposed is born of animosity
toward the class of persons affected. Romer, 517 U.S. at 634.
If a court finds historic patterns of disadvantage suffered by the group
adversely affected by [a] statute, Massachusetts, 682 F.3d at 11, it should
undertake[] a more careful assessment of the justifications than the light scrutiny
offered by conventional rational basis review. Id. When animus is at work, the
burden falls on the State to prove that the government had in mind some object
other than harming a politically unpopular group. We turn to that analysis.
IV. Michigan Does Not Have a Legitimate Purpose for the MMA.
A. MMA Was Motivated by Discriminatory Animus.
1. History of Discrimination.
Since a baredesire to harm a politically unpopular group, Moreno, 413
U.S. at 534, is not a legitimate state interest, the question here is whether such a
desire motivated those who wrote and supported the MMA. It did. Therefore, the
amendment does not rationally relate to any legitimate state interest and it is
unconstitutional.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 8 of 35 Pg ID 1011
9

Many courts have recognized the incontrovertible evidence that gays and
lesbians have suffered a long history of invidious discrimination. See, e.g.,
Massachusetts, 682 F.3d at 11 (As with the women, the poor and the mentally
impaired, gays and lesbians have long been the subject of discrimination.); High
Tech Gays v. Defense Indus. Security Clear. Office, 895 F.2d 563, 573 (9
th
Cir.
1990) ([H]omosexuals have suffered a history of discrimination .); Ben-
Shalom v. Marsh, 881 F.2d 454, 465-66 (7
th
Cir. 1989) (Homosexuals have
suffered a history of discrimination and still do, though possibly now in less
degree.); Golinski v. United States Office of Pers. Mgmt., 824 F.Supp.2d 968, 985
(N.D. Cal. 2012) (There is no dispute in the record that lesbians and gay men
have experienced a long history of discrimination.). See also Rowland v. Mad
River Local School Dist., 470 U.S. 1009, 1014 (1985) (Brennan, J ., dissenting from
denial of certiorari) (quoting Plyler v. Doe, 457 U.S. 202, 216, n. 14 (1982))
([H]omosexuals have historically been the object of pernicious and sustained
hostility, and it is fair to say that discrimination against homosexuals is likelyto
reflect deep-seated prejudice rather thanrationality.)
More specifically, J udge Walker, whose opinion in Perry v.
Schwarzenegger, 704 F.Supp.2d 921 (N.D. Cal. 2010), affd sub nom Perry v.
Brown, 671 F.3d 1052 (9
th
Cir. 2012), was reinstated when the Supreme Court
vacated and remanded the Ninth Circuit opinion in Hollingsworth v. Perry, 570
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 9 of 35 Pg ID 1012
10

U.S. ___, 133 S. Ct. 2652 (2013), created a thorough record with findings and
conclusions like these:
Gays and lesbians have been victims of a long history of discrimination.
Id. at 981.

Public and private discrimination against gays and lesbians occursin the
United States. Id.

Well-known stereotypes about gay men and lesbiansimagine [them] as
disease vectors or as child molesters who recruit young children into
homosexuality. Id. at 982-83.

Religious beliefs that gay and lesbian relationships are sinful or inferior to
heterosexual relationships harm gays and lesbians. Id. at 985.

Similarly, in Pedersen v. Office of Pers. Mgmt., 881 F.Supp.2d 294 (D.
Conn. 2012), the court found that the federal government categorically
discriminated against homosexuals in immigration until 1990, barring all gay and
lesbian noncitizens from entering the United States. Id. at 316. In the past, the
federal government labeled homosexuals mentally ill. Id. at 317. Homosexuals
are among the most frequent victims of hate crimes. Id. State and local
governments, too, have discriminated against gays and lesbians:
The DOJ also points to the long history of discrimination by state
and local governments against gays and lesbians in (i) public
employment; (ii) the denial of child custody and visitation rights; (iii)
the ability to associate freely; and (iv) legislative efforts including local
initiatives to repeal laws that protect homosexuals from discrimination.
Id.

2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 10 of 35 Pg ID 1013
11

The Second Circuit found it easy to conclude that homosexuals have
suffered a history of discrimination, Windsor, 699 F.3d at 182, a history that is
not much in debate. Id. In the DOMA cases, the Bipartisan Legal Advisory
Group conceded that gays and lesbians have suffered discrimination since at least
the 1920s. Id. Ninety years of discrimination, the Windsor appeals panel
concluded, is entirely sufficient to document a history of discrimination. Id.
(quoting Pedersen, 881 F.Supp.2d at 318).
2. Statements by Drafters and Supporters of the MMA.
Since the MMA is the first-ever constitutional provision to impose upon a
group of Michigan citizens a special legal disadvantage, its discrimination[] of an
unusual character demands the careful consideration J ustice Kennedy described
in Windsor. Here is what some of the authors and principal sponsors of the MMA
have had to say about gays and lesbians generally, and same-sex marriage more
particularly.
a. Gary Glenn/Michigan American Family Association
The Michigan American Family Association (MI-AFA) describes itself as
Michigans leading voice for the preservation of traditional values and institutions
such as marriage between one man and one woman. Brief of Amicus Curiae
American Family Association of Michigan, in National Pride at Work, Inc. v.
Granholm, available at 2007 WL 3325618 at *1. Gary Glenn, MI-AFAs president,
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 11 of 35 Pg ID 1014
12

claims to have co-authored the MMA. Id. Because it was the initial proponent, a
co-author, and a leading advocate of the Amendment, MI-AFA felt itself well
suited to assist the [Michigan Supreme] Court in confirming the intent of the
authors of the Amendment and as understood by the citizens who approved it. Id.
The point of the MMA, [a]s Glenn explained in scores of public
appearances, debates, and media interviews in 2004[,] was government
recognition. Id. (emphasis in original). The purpose of the MMA was to make all
relationships between same-sex partners legally invisible to the State. Any law that
seeks to make an entire class of citizens a nullity to place those citizens beyond
the states recognition must be constitutionally infirm. A clearer denial of equal
protection of the laws is impossible to imagine.
Other comments attributed to Glenn and the MI-AFA help to contextualize
their beliefs about gays and lesbians. According to Glenn, [N]ew studies have
found that children raised by homosexual couples are far more likely to live in
poverty, be on welfare and unemployed, and be involved in criminal activity.
5
To

5
American Family Association of Michigan, Marriage amendment coauthor warns
children will be harmed and taxpayers hit with increased social costs if federal
judge overturns vote of the people, available at http://www.afamichigan.org/2013/
03/07/marriage-amendment-coauthor-warns-children-will-be-harmed-and-
taxpayers-hit-with-increased-social-costs-if-federal-judge-overturns-vote-of-the-
people-2/ (last visited August 4, 2013) [hereinafter Marriage Amendment
Coauthor]. Note that this webpage was published on March 7, 2013. The study it
relies on for these claims the Regnerus study was actually discredited in J uly of
2012. See note 7, infra.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 12 of 35 Pg ID 1015
13

support these claims, Glenn cited what is now widely known as the Regnerus
study.
6
Unsurprisingly, the Regnerus study suffers significant, disqualifying
problems uncovered by the same journal that published it.
7

According to an M-Live article, Glenn has opined that gays and lesbians do
not make for the best and brightest employees.
8
This is so, he is reported to have
said, because being the best and brightest is not defined by engaging in
homosexual behavior, specifically because its not bright to engage in behavior
medically associated with dramatically increased personal health risks.
9
Glenn
reportedly called a Holland, Michigan anti-discrimination ordinance a
homosexual activists discriminatory special rights ordinance, arguing that it
threatens marriage and religious freedom.
10


6
Mark Regnerus, How different are the adult children of parents who have same-
sex relationships?, 41-4 Social Science Research, at 752 (J uly 2012), available at
http://www.sciencedirect.com/science/article/pii/S0049089X12000610 (last visited
August 4, 2013).
7
Tom Bartlett, Controversial Gay-Parenting Study Is Severely Flawed, Journals
Audit Finds, The Chronicle of Higher Education, J uly 26, 2012, available at
http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-
severely-flawed-journals-audit-finds/30255 (last visited August 4, 2013).
8
Shandra Martinez, Conservative Christian activist Gary Glenn says gay
employees are bad hires because of health risks, M-Live, J uly 6, 2011, available at
http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative
_christian_activis.html (last visited August 4, 2013).
9
Id.
10
Shandra Martinez, Gay rights debate made focus of Holland election with Gary
Glenns robocalls, M-Live, J uly 29, 2011, available at http://www.mlive.com/
news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html (last
visited August 4, 2013) [hereinafter Glenns Robocalls].
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 13 of 35 Pg ID 1016
14

A claim that Michigan has only become more hostile towards same sex
couples and is objectively the most hostile environment for non-hetero people to
live is testimony to the Michigan American Family Associations effective stand
for traditional family values.
11

b. The Catholic Church in Michigan
The Catholic Church in Michigan, via the Archdiocese of Detroit and
several Dioceses across the state, was the largest financial supporter of the MMA.
Nearly half of the funds supporting the amendments passage one million dollars
came from the Church,
12
which has expressed clearly its disapproval of
homosexuality and same-sex relationships: Homosexuality is a troubling moral
and social phenomenon, even in those countries where it does not present
significant legal issues.
13
According to the Church, the issue is particularly

11
American Family Association of Michigan, Testimony to AFA-Michigans
effective stand for traditional family values, available at http://www.afamichigan.
org/2012/02/11/testimony-to-afa-michigans-effective-stand-for-traditional-family-
values/ (last visited August 4, 2013).
12
See National Institute on Money in State Politics, Proposal 04-2: Same-sex
Marriage Ban (and subsidiary pages), available at http://www.followthemoney.
org/database/StateGlance/ballot.phtml?m=321 (last visited August 6, 2013)
[hereinafter Follow the Money]. The Archdiocese of Detroit was, by far, the
largest single contributor at $538,100. Id. The Dioceses of Lansing ($133,350),
Grand Rapids ($106,100), Saginaw ($87,500), Gaylord ($49,250), Kalamazoo
($47,450), and Marquette ($38,250), collectively donated another $461,900,
bringing the total support from the Church to $1,000,000. Id.
13
Congregation for the Doctrine of the Faith, Considerations Regarding Proposals
to Give Legal Recognition to Unions Between Homosexual Persons, available at
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 14 of 35 Pg ID 1017
15

troublesome in those countries that grant legal recognition to homosexual unions,
which may include the possibility of adopting children.
14
Even when the
government policy is one of de facto tolerance, but there is no legal recognition
of homosexual unions, the Church counsels that the immoral nature of these
unions must be clearly stated.
15
Government must be reminded
of the need to contain the phenomenon within certain limits so as to
safeguard public morality and, above all, to avoid exposing young
people to erroneous ideas about sexuality and marriage that would
deprive them of their necessary defences and contribute to the spread
of the phenomenon. Those who would move from tolerance to the
legitimization of specific rights for cohabiting homosexual persons
need to be reminded that the approval or legalization of evil is
something far different from the toleration of evil.
16


Like Glenn and the MI-AFA, the Church opposes government recognition of
same-sex relationships: Legal recognition of homosexual unions would obscure
certain basic moral values and cause a devaluation of the institution of marriage.
17

So, too, adoption by same-sex couples is out of the question since [a]llowing
children to be adopted by persons living in such unions would actually mean doing
violence to these children .
18
Same-sex marriages are harmful to the proper

http://www.catholicsinthepublicsquare.org/fr_cdf1.html (last visited August 5,
2013).
14
Id.
15
Id.
16
Id.
17
Id.
18
Id.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 15 of 35 Pg ID 1018
16

development of human society,
19
and all Catholics are obliged to oppose the
legal recognition of homosexual unions.
20
The Church issues a clear injunction:
[t]o vote in favor of a law so harmful to the common good is gravely immoral.
21

c. Family Research Council
The Family Research Council (FRC), which has benefitted from the
generosity of the DeVos and Prince families of Western Michigan,
22
was a major
financier of the amendment, with contributions totaling $376,397.
23
Like other
proponents of the MMA, the views of the FRC about gays, lesbians, and same-sex
couples are beyond doubt. For example, the organization has published The Top
Ten Harms of Same-Sex Marriage by author Peter Sprigg, which includes
alleged harms like these:
Taxpayers, consumers, and businesses would be forced to subsidize
homosexual relationships.
24



19
Id.
20
Id.
21
Id.
22
Family Research Council, History of the Family Research Council, available at
http://www.frc.org/historymission (last visited August 6, 2013). The DeVos and
Prince families were major contributors to the MMA campaign. Elsa Prince-
Broekhuizen was the largest individual donor, giving $75,000 through Citizens for
the Protection of Marriage. See Follow the Money, supra note 12.
23
Follow the Money, supra note 12. The FRC gave $190,000 through Citizens for
the Protection of Marriage, and another $186,397 directly. Id.
24
Peter Sprigg, The Top Ten Harms of Same-Sex Marriage, at 1, available at
http://downloads.frc.org/EF/EF11B30.pdf (last visited August 6, 2013).
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 16 of 35 Pg ID 1019
17

Freedom of conscience and religious liberty would be threatened.
25

Fewer people would remain monogamous and sexually faithful.
26

Demands for legalization of polygamy would grow.
27

Sprigg has compiled a list of the top ten myths about homosexuality,
together with what he claims to be the facts that defeat those myths. Sprigg often
cites to sources including scholarly or academic studies to support his facts.
But the inferences that Sprigg draws are not supportable. An example will
illustrate.
Myth No. 5 about homosexuality, says Sprigg, is that [h]omosexuals do
not experience a higher level of psychological disorders than heterosexuals.
28
This
supposed myth is not attributed to any source. The fact that counters this
supposed myth is that [h]omosexuals experience considerably higher levels of
mental illness and substance abuse than heterosexuals. A detailed review of the
research has shown that no other group of comparable size in society experiences
such intense and widespread pathology.
29


25
Id. at 2.
26
Id. at 4.
27
Id. at 7.
28
Peter Sprigg, The Top Ten Myths About Homosexuality, at 22, available at
http://downloads.frc.org/EF/EF10F01.pdf (last visited August 6, 2013) [hereinafter
Top Ten Myths].
29
Id.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 17 of 35 Pg ID 1020
18

To support this claim, Sprigg points to a comprehensive meta-analysis (the
King Review) that looked at data from 28 studies.
30
The King Review observed
that [lesbian, gay, and bisexual] people are subject to institutionalized prejudice,
social stress, social exclusion (even within families) and anti-homosexual hatred
and violence and often internalize a sense of shame about their sexuality.
31
After
concluding that homosexual and bisexual people suffer from more mental and
emotional pathologies than heterosexuals, the authors cautioned that there is no
evidence to suggest that homosexuality is itself a disorder that is thereby subject to
a higher co-morbidity than is found in heterosexuals.
32
Though the King Review
made no attempt to explain causal factors, the authors did conclude that it is likely
that the social hostility, stigma and discrimination that most [lesbian, gay, and
bisexual] people experience is at least part of the reason for the higher rates of
psychological morbidity observed.
33

Sprigg mentions none of this. In fact, he dismisses it out of hand.
Homosexual activists, he says, try to explain these problems as results of

30
See Michael King, et. al, A systematic review of mental disorder, suicide, and
deliberate self harm in lesbian, gay and bisexual people, available at
http://www.biomedcentral.com/content/pdf/1471-244X-8-70.pdf (last visited
August 6, 2013) [hereinafter the King Review].
31
Id. at 2.
32
Id. at 14.
33
Id.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 18 of 35 Pg ID 1021
19

homophobic discrimination.
34
Sprigg concludes that discrimination cannot be a
causal factor, because homosexuals show higher rates of these pathologies in the
Netherlands, which Sprigg describes as perhaps the most gay-friendly country in
the world.
35

Setting aside the metric Sprigg used to opine about the gay-friendliness of
the Netherlands, we are left to wonder how, exactly, this rules out the kind of
discrimination and hostility that play a key role in the mental and emotional health
of gays and lesbians. In other words, even if we concede for the sake of argument
that the Netherlands is, as Sprigg puts it, gay friendly, that does not rule out
discrimination and hostility against homosexuals in the Netherlands.
d. Other Evidence of Discriminatory Purpose
Throughout the campaign for the MMA, supporters claimed that it was
solely about marriage and would have no impact on domestic-partner benefits
offered by public employers. Citizens for the Protection of Marriage, a ballot
committee formed to support the amendment, published a campaign brochure that
said,
Proposal 2 is only about marriage. Marriage is a union between husband
and wife. Proposal 2 will keep it that way. This is not about rights or
benefits or how people choose to live their lives . It merely settles the
question once and for all what marriage is for families today and
future generations.

34
Top Ten Myths, supra note 28, at 25.
35
Id.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 19 of 35 Pg ID 1022
20


First Amended Complaint for Declaratory Relief 39, National Pride at Work, Inc.
v. Granholm, available at 2005 WL 6221787. Similar assurances were offered by
other MMA proponents. Id. at 40, 41. See also Glen Staszewski, The Bait-and-
Switch in Direct Democracy, 2006 Wis. L. Rev. 17, 24, n. 28 (2006) (compiling
statements by supporters about scope of MMA) [hereinafter Bait-and-Switch].
Only after the MMA became law did its advocates begin speaking truthfully
about its discriminatory purpose. As soon as the election results were reported,
one of the coauthors of Proposal 2, and perhaps its most outspoken proponent,
reportedly declared that [b]enefits to homosexuals are a formal recognition of a
homosexual relationship as equal or similar to marriage . Bait-and-Switch,
supra, at 26-27 (quoting Stacey Range, Proposal 2 Supporters Taking Aim at
Benefits, Lansing St. J ., Nov. 4, 2004, at 6 (quoting Gary Glenn)).
The Michigan Attorney General concluded that municipalities providing
benefits to the domestic partners of gay and lesbian employees violated the MMA.
See Constitutionality of City Providing Same-Sex Domestic Partnership Benefits,
Op. Atty. Gen. No. 7171 (Mar. 16, 2005), available at 2005 WL 639112.
Ultimately, the Michigan Supreme Court agreed. See National Pride at Work, Inc.
v. Granholm, 481 Mich. 56, 748 N.W.2d 524 (2008).
This outcome was not an accident.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 20 of 35 Pg ID 1023
21

The story of [the MMA] is outrageous because the collateral
consequences at issue were apparently intended by some of the
initiative proponents, and their actions seem premeditated. Moreover,
the initiative proponents expressly addressed the relevant interpretive
issue prior to the election and therefore appear to have affirmatively
misled the voters. Finally, some of the same individuals who claimed
that the amendment would not affect the legality of domestic
partnership benefits are involved in the effort to eliminate them. Bait-
and Switch, supra, at 20.

e. Summary
Given the pervasive hostility that gays and lesbians face, none of this is a
surprise. Proponents of the MMA were obviously motivated by a baredesire to
harm, Moreno, 413 U.S. at 534, gays, lesbians, and same-sex couples. The most
prominent and vocal MMA proponent, Gary Glenn, was and still is proud to
prevent the State from so much as recognizing same-sex relationships. The biggest
financial supporter of the amendment, the Catholic Church in Michigan, claims
that same-sex relationships are evil and that they pose a grave threat to children
who might be adopted into those relationships.
Does the animus and irrational fear underlying the MMA lead to an equal
protection violation? If rendering same-sex relationships a legal nullity does not
violate the equal protection principle of the Fourteenth Amendment, then amici are
not clear what does. This must be what J ustice Kennedy meant when he said that
[i]t is not within our constitutional tradition to enact laws of this sort. Romer,
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 21 of 35 Pg ID 1024
22

517 U.S. at 633. There is no legitimate interest in politically and legally
subordinating same-sex couples. The MMA is unconstitutional.
3. Nationwide Pattern of Anti-Same-Sex Marriage Laws.
Michigan is one of 35 states that have passed what is commonly called a
defense of marriage law, or DOMA.
36
These state DOMAs, at a minimum,
define marriage as the union of one man and one woman. The 2004 presidential
election year was the most active for state DOMAs; a total of thirteen states,
including Michigan, put constitutional amendments on the ballot that year.
37
All of
them passed.
38

The push to get same-sex marriage questions before state voters in 2004 was
largely the work of the Arlington Group,
39
a coalition that included some of the

36
National Conference of State Legislatures, State Laws Limiting Marriage to
Opposite-Sex Couples, available at http://www.ncsl.org/issues-research/human-
services/state-doma-laws.aspx (last visited August 7, 2013).
37
National Conference of State Legislatures, Statewide Votes on Same-Sex
Marriage, 1998-Present, available at http://www.ncsl.org/legislatures-
elections/elections/same-sex-marriage-on-the-ballot.aspx#3 (last visited August 7,
2013) In addition to Michigan, those states were Arkansas, Georgia, Kentucky,
Louisiana, Mississippi, Missouri, Montana, North Dakota, Ohio, Oklahoma,
Oregon, and Utah. Id. Efforts to prevent same-sex marriage did not end in 2004. In
2005, Kansas and Texas passed constitutional amendments. Id. The following year,
2006, eight more states followed suit: Alabama, Colorado, Idaho, South Carolina,
South Dakota, Tennessee, Virginia, and Wisconsin. Id.
38
Id.
39
See Paul Weyrich, The Arlington Group, available at http://www.renewamerica.
com/columns/weyrich/041203 (last visited August 7, 2013) [hereinafter
Weyrich].
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 22 of 35 Pg ID 1025
23

most influential supporters of the MMA, including the American Family
Association, the Family Research Council, and Gary Glenn of the MI-AFA.
40

[T]he effort to put marriage on the ballot in eleven states emanated from the
Arlington Group.
41
Arlington Group members contributed more than $540,000 in
support of the MMA,
42
or 28% of the total funds raised in its favor.
43
The
Arlington Group was most influential financially, anyway in the key 2004
presidential battleground state of Ohio. There, Group member contributions totaled
$1,183,485, or 98% of the funds raised in support of Ohios anti-same-sex-
marriage law.
44
Nationwide, Arlington Group members and related organizations
gave almost $2,000,000 in support of state anti-same-sex-marriage proposals.
45

While Arlington Group members feigned concern for such things as
traditional marriage or religious freedom,
46
clearly there was something else at
work. Many states already had laws limiting marriage to heterosexual couples. For
example, an Arkansas law enacted in 1997 said that [m]arriage shall be only

40
See Arlington Group Members, available at http://www.aproundtable.org/
untangling/arlington_Group.html (last visited August 7, 2013).
41
Weyrich, supra note 39.
42
Sue OConnell, The Money Behind the 2004 Marriage Amendments, National
Institute on Money in State Politics, at 10, available at http://www.followthemoney
.org/press/ReportView.phtml?r=236&ext=12 (last visited August 7, 2013)
[hereinafter 2004 Marriage Amendments].
43
Id. at 12.
44
Id.
45
Id.
46
See, e.g., Glenns Robocalls, supra note 10.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 23 of 35 Pg ID 1026
24

between a man and a woman. A marriage between persons of the same sex is
void. Ark. Code Ann. 9-11-107 (1997). Here in Michigan, a 1996 law provided
that a marriage that is not between a man and a woman is invalid in this state .
MCL 551.272 (1996). And well before 2004, Missouri declared that the public
policy of this state is to recognize marriage only between a man and a woman.
Mo. Rev. Stat. 451.022 (1996).
Given these pre-existing state laws, the purpose of adding constitutional
amendments must have been to gratuitously target gays and lesbians for political
purposes, and to make it more difficult for gays and lesbians in those states to
mobilize political processes in their favor. Making a law relatively more permanent
by enacting it into a state constitution is not per se troublesome, see, e.g., Romer v.
Evans, 517 U.S. 620, 639 (1996) (Scalia, J ., dissenting). But constitutional
problems emerge when the reason for doing so is animus against the targeted
group. A law declaring that in general it shall be more difficult for one group of
citizens than for all others to seek aid from the government is itself a denial of
equal protection of the laws in the most literal sense. Romer, 517 U.S. at 633. In
Hunter v. Erickson, 393 U.S. 385 (1969), the Supreme Court explained that the
State may no more disadvantage any particular group by making it more difficult
to enact legislation in its behalf than it may dilute one persons vote or give any
group a smaller representation than another of comparable size. Id. at 393.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 24 of 35 Pg ID 1027
25

The same-sex marriage issue was used to drive voters to the polls in 2004.
At least one scholar has noted a perception that the electorates opportunity to
vote on socially conservative ballot measures was critical to the reelection of
President George W. Bush. Bait-and-Switch, supra, at 17. This has become a
tried-and-true political strategy, as there is mounting evidence that political
parties are becoming engaged in crafting initiatives not for their substantive merits,
but because they expect the measures will touch a nerve with their supporters, or
conversely, drive a wedge into the base of a rival political party.
47

Putting same-sex marriage on the ballot in states all across the country drew
forward influential people and organizations, like those who make up the Arlington
Group. Given their feelings about same-sex marriage, they were easily motivated
to coax voters to the polls. The issue, it should be emphasized, is not electoral
politics, but the desire to harm an unpopular group. When animus motivates an
initiative like the MMA, the initiative is unconstitutional.
B. The MMA Is an Overbroad, Status-Based Enactment.
The MMA is a classic status-based enactment. It singles out one group of
people gays and lesbians and treats them differently because of the immutable
characteristic that defines the class: sexual orientation. This discriminatory

47
Todd Donovan and Daniel Smith, Turning On and Turning Out: Assessing the
Individual-Level Effects of Ballot Measures, at 5, available at http://lawweb.
usc.edu/centers/cslp/assets/docs/cslp-wp-032.pdf (last visited August 8, 2013).
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 25 of 35 Pg ID 1028
26

treatment results not from anything that is morally culpable or blameworthy but, as
J ustice J ackson stated in a different context, because of a characteristic over which
the targeted group had no choice, and from which there is no way to resign.
Korematsu v. United States, 323 U.S. 214, 243 (1944) (J ackson, J ., dissenting).
This was, in part, what caused the Supreme Court to take such offense at the
Colorado ballot initiative in Romer. There, J ustice Kennedy recalled the lessons of
the past. One century ago, the rst J ustice Harlan admonished this Court that the
Constitution neither knows nor tolerates classes among citizens. Romer, 517
U.S. at 623 (quoting Plessy v. Ferguson, 163 U. S. 537, 559 (1896) (Harlan, J .,
dissenting)). But the constitutional amendment in Romer went beyond just creating
a second class of citizens. Colorado tried to make a class of persons a stranger to
its laws. Romer, 517 U.S. at 635 (emphasis added). Colorado did so by denying
to gays and lesbians the protections of its antidiscrimination laws. Michigan, on the
other hand, has chosen a more direct route: barring any recognition by the State of
same-sex relationships. While the tactics might differ, the outcome is no more
acceptable in Michigan than it was in Colorado.
For equal protection purposes, the key word in the MMA is recognized.
Gays and lesbians who deign to stand publicly as dignified and committed couples
may not be recognized by the State. Michigan may not see them; it may not
acknowledge their humanity; it may not even grant that they exist under the law.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 26 of 35 Pg ID 1029
27

Interpreting the MMA in National Pride at Work, Inc. v. Granholm, 481
Mich. 56, 748 N.W.2d 524 (2008), the Michigan Supreme Court said that
[r]ecognize is defined as to perceive or acknowledge as existing, true, or
valid[.] When a public employer attaches legal consequence to a relationship, that
employer is clearly recognizing that relationship. That is, by providing legal
significance to a relationship, the public employer is acknowledging the validity of
that relationship. Natl. Pride at Work, 748 N.W. 2d at 537 (2008) (quoting
Random House Webster's College Dictionary (1991) (emphasis added)). So
Michigan may not perceive or acknowledge that same-sex couples even exist.
This prohibition extends to any similar union between same-sex persons
that approximates marriage. Returning to National Pride at Work, the Michigan
Supreme Court construed union in the broadest conceivable terms to mean
something formed by uniting two or more things; a combination joined for
some common purpose. Certainly, when two people join together for a common
purpose and legal consequences arise from that relationship, i.e., a public entity
accords legal significance to this relationship, a union may be said to be formed.
Natl. Pride at Work, 748 N.W. 2d at 533-534 (quoting Random House Webster's
College Dictionary (1991)). Thus, Michigan must make a stranger to its laws any
associated same-sex persons whose combination might implicate any legal
significance.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 27 of 35 Pg ID 1030
28

And to remove any doubt, the Michigan Supreme Court explained the
phrase, for any purpose:
Any means every; all[.] Therefore, if there were any residual doubt
regarding whether the marriage amendment prohibits the recognition of
a domestic partnership , this language makes it clear that such a
recognition is indeed prohibited for any purpose, which obviously
includes for the purpose of providing health-insurance benefits.
Whether the language for any purpose is essential to reach the
conclusion that health-insurance benefits cannot be provided under the
instant circumstances, or merely punctuates what is otherwise made
clear in the amendment, the people of this state could hardly have made
their intentions clearer. Natl. Pride at Work, 748 N.W. 2d at 538
(quoting Random House Webster's College Dictionary (1991)).

So the MMA, as authoritatively construed by the Michigan Supreme Court,
requires that any time a same-sex couple join[s] together for a common purpose
and legal consequences arise from that relationship, for every reason and all
reasons, including the provision of health-care benefits, the State of Michigan must
treat that relationship as if it does not exist. The purpose of the MMA could not be
clearer. For this reason alone, the MMA is facially unconstitutional.
The reasoning that led to the Supreme Court finding in Romer that
Colorados ballot measure was unconstitutional applies with equal force here, as
does its ultimate conclusion: We must conclude that Amendment 2 classifies
homosexuals not to further a proper legislative end but to make them unequal to
everyone else. This Colorado cannot do. A State cannot so deem a class of persons
a stranger to its laws. Romer, 517 U.S. at 635.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 28 of 35 Pg ID 1031
29

The MMA is an affront to the Equal Protection Clause even more sinister
than the Romer Colorado constitutional amendment or the Windsor DOMA statute.
In its breadth and its depth, the MMA is better described as a super-DOMA. See
generally, Andrew Koppelman, The Difference the Mini-DOMAs Make, 38 Loy. U.
L.J . 265 (2007). The super-DOMA label, as we use it here, indicates that the
MMA imposes the maximum disability on gays and lesbians that can be inflicted
by state law: gays and lesbians cannot marry, nor can they seek the benefits or
protections of marriage derived from any similar relationship, and this disability
exists regardless of any purpose for which same-sex couples might seek to be
recognized by the law.
In Perry v. Brown, 871 F.3d 1052 (2012), revd on other grounds sub nom
Hollingsworth v. Perry, 570 U.S. ___, 133 S. Ct. 2652 (2012), the Ninth Circuit
noted the remarkable similarities between the Romer constitutional amendment and
the California constitutional amendment known as Proposition 8, which stripped
Californias gay and lesbian citizens of the right to marry:
[Californias] Proposition 8 is remarkably similar to [Colorados]
Amendment 2. Like Amendment 2, Proposition 8 single[s] out a
certain class of citizens for disfavored legal status.... Like Amendment
2, Proposition 8 has the peculiar property, of withdraw[ing] from
homosexuals, but no others, access to the official designation of
marriage Like Amendment 2, Proposition 8 by state decree ...
put[s] [homosexuals] in a solitary class with respect to an important
aspect of human relations, and accordingly imposes a special disability
upon [homosexuals] alone. And like Amendment 2, Proposition 8
constitutionalizes that disability, meaning that gays and lesbians may
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 29 of 35 Pg ID 1032
30

overcome it only by enlisting the citizenry of [the state] to amend the
State Constitution for a second time. Perry, 871 F.3d at 1053, 1080-
1081 (citations omitted).

Of course, the same can be said of the MMA. Like both Californias Proposition 8
and Colorados Amendment 2, the MMA singles out one class of citizens for
disfavored legal status. Like those other provisions, the MMA is designed to
withdraw from gays and lesbians alone legal benefits available to all others. And
like those other provisions, the MMA constitutionalizes that disability and
dictates that gays and lesbians can only claim those rights enjoyed by all other
Michigan residents by seeking to amend the states constitution.
In Windsor, the Supreme Court was clearly troubled by DOMAs breadth.
DOMAs comprehensive definition of marriage for purposes of all federal statutes
and other regulations or directives covered by its terms control[s] over 1,000
federal laws in which marital or spousal status is addressed as a matter of federal
law. United States v. Windsor, 570 U.S. ___, 133 S. Ct. 2675, 2683 (2013).
J ustice Kennedy noted that, [a]mong the over 1,000 statutes and numerous federal
regulations that DOMA controls are laws pertaining to Social Security, housing,
taxes, criminal sanctions, copyright, and veterans benefits. Windsor, 133 S. Ct.
at 2694.
The Windsor Court minced no words over the legal significance of these
facts. The avowed purpose and practical effect of the law here in question are to
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 30 of 35 Pg ID 1033
31

impose a disadvantage, a separate status, and so a stigma upon all who enter into
same-sex marriages made lawful by the unquestioned authority of the States. Id.
at 2693. The Court lambasted DOMAs effects on same-sex couples and their
children:
The differentiation demeans the couple, whose moral and sexual
choices the Constitution protects and whose relationship the State
has sought to dignify. And it humiliates tens of thousands of children
now being raised by same-sex couples. The law in question makes it
even more difficult for the children to understand the integrity and
closeness of their own family and its concord with other families in
their community and in their daily lives. Id. at 2694 (citing Lawrence
v. Texas, 539 U. S. 558 (2003)).

If the similarities between Perry, Romer, Windsor, and our facts make the
MMA constitutionally objectionable, key differences between them magnify the
MMAs constitutional infirmities. Where DOMA affected only federal benefits
and federal protections accruing to married couples, the MMA prevents marriage
in the first instance. See Mich. Const. art. I, 25. The Colorado constitutional
provision in Romer formally extended to anti-discrimination laws; the MMA goes
farther by prohibiting recognition of same-sex relationships for any purpose. Id.
Proposition 8 deprived California same-sex couples of the use of the term
marriage, but [left] in place all of their other rights and responsibilities as
partners rights and responsibilities that are identical to those of married persons
and form an integral part of the marriage relationship. Perry, 871 F.3d at 1076.
Same sex couples could, for example,
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 31 of 35 Pg ID 1034
32

Raise children together, and have the same rights and obligations as to their
children as spouses have, id. at 1077 (citation omitted);

Enjoy the presumption of parentage as to a child born to either partner, or
adopted by one partner and raised jointly by both, id. (citations omitted);

Adopt each other's children, id. (citation omitted);
File state taxes jointly, id. (citation omitted);
Be treated in a manner equal to that of a widow or widower with respect to
a deceased partner, id. (citations omitted); and

Sue for the wrongful death of a partner among many other things. Id.
(citation omitted).

The MMA deprives Michigan same-sex couples of all these rights and
more.
48
In this regard, the MMA does even greater harm to Michigan same-sex
couples than Proposition 8 did to California same-sex couples.
Applying rational basis review in Romer, 517 U.S. at 633, J ustice Kennedy
wrote, Amendment 2 confounds [the] normal process of judicial review. It is at
once too narrow and too broad. It identies persons by a single trait and then
denies them protection across the board. The resulting disqualication of a class of
persons from the right to seek specic protection from the law is unprecedented in
our jurisprudence.

48
For a partial listing of rights and benefits not available to Michigan same-sex
couples, see Plaintiffs Combined Brief, supra note 2, at 14, n. 10.
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 32 of 35 Pg ID 1035
33

How can the MMA conceivably be distinguished? It too identies persons
by a single trait and then denies them protection across the board. Id. Like
Colorados Amendment 2, the MMA is obnoxious to the constitution[]. Id.
(quoting Louisville Gas & Elec. Co. v. Coleman, 277 U. S. 32, 3738 (1928)).
V. Conclusion.
The MMA fails equal protection review by virtually any measure this Court
might employ. Motivated by nothing more than a desire to harm Michigan same-
sex couples, it lacks any legitimate interest to justify it. It creates a status-based
classification that punishes gays and lesbians for who they are, not for anything
they have done. As authoritatively construed by the Michigan Supreme Court, it is
so overbroad as to be beyond salvage.
We close where we started. Ours is not a Constitution of caste or class. It is
not a Constitution that allows a political majority to subordinate a defenseless
minority just because it can. It is not a Constitution that turns its back on any class,
much less a class that is morally blameless. It is not within our constitutional
tradition to enact laws of this sort. Romer, 517 U.S. at 633.
The MMA is unconstitutional.



2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 33 of 35 Pg ID 1036
34

Respectfully submitted,
/s/Alan M. Gershel
Brendan Beery (P59464) Alan M. Gershel (P29652)
Of Counsel Counsel of Record
Thomas M. Cooley Law School Thomas M. Cooley Law School
9445 Camden Field Pkwy. 2630 Featherstone
Riverview, FL 33578 Auburn Hills, MI 48236
Phone: (813) 419-5100 ext. 5106 Phone: (248) 751-7800 ext. 7765
beeryb@cooley.edu gershela@cooley.edu

Daniel R. Ray (P63758) Gina M. Torielli (P45275)
Of Counsel Of Counsel
Thomas M. Cooley Law School Thomas M. Cooley Law School
3475 Plymouth Rd. 3475 Plymouth Road
Ann Arbor, MI 48105 Ann Arbor, MI 48105
Phone: (734) 372-4900 ext. 8775 Phone: (734) 372-4900 ext. 8732
rayd@cooley.edu toriellg@cooley.edu

Frank C. Aiello (P63151) Emily S. Horvath (P60186)
Of Counsel Of Counsel
Thomas M. Cooley Law School Thomas M. Cooley Law School
2630 Featherstone 300 S. Capitol Ave.
Auburn Hills, MI 48236 Lansing, MI 48933
Phone: (248) 751-7800 ext. 7764 Phone: (517) 371-5140 ext. 2819
aiellof@cooley.edu horvathe@cooley.edu

Karen L. Chadwick (P33163) Marjorie B. Gell (P46974)
Of Counsel Of Counsel
Thomas M. Cooley Law School Thomas M. Cooley Law School
3475 Plymouth Rd. 111 Commerce Ave. SW
Ann Arbor, MI 48105 Grand Rapids, MI 49503
Phone: (734) 372-4900 ext. 8730 Phone: (616) 301-6800 ext. 6823
chadwick@cooley.edu gellm@cooley.edu

Dated: August 12, 2013
2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 34 of 35 Pg ID 1037


CERTIFICATE OF SERVICE

I hereby certify that on August 12, 2013, I electronically filed the foregoing
document(s) with the Clerk of the Court using the ECF system, which will provide
electronic notice and copies of such filing to the parties: Motion of Amici Curiae
Michigan Law Professors for Leave to File Brief in Support of Plaintiffs, and Brief
of Amici Curiae Michigan Law Professors in Support of Plaintiffs.
/s/Alan M. Gershel (P29652)
Thomas M. Cooley Law School
2630 Featherstone
Auburn Hills MI 48236
Phone: (248) 751-7800 ext. 7765
gershela@cooley.edu



















2:12-cv-10285-BAF-MJH Doc # 65-1 Filed 08/12/13 Pg 35 of 35 Pg ID 1038
1
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

APRIL DEBOER, et. al.,

Plaintiffs, No. 2:12-cv-10285-BAF-MJH
HON. BERNARD A. FRIEDMAN
v. MAG. MICHAEL J. HLUCHANIUK

RICHARD SNYDER, et. al.,

Defendants.

INDEX OF ATTACHMENTS - CAPTURED INTERNET PAGES
REFERENCED IN AMICUS BRIEF OF LAW PROFESSORS


Attachment Description

A Glenn AFA Statements, Footnote 5
B Regnerus Study, Footnote 6
C Chronicle Regnerus Study, Footnote 7
D Glenn Bad Employees, Footnote 8
E Glenn Robocalls, Footnote 10
F Testimony to MIAFA, Footnote 11
G Follow the Money, Footnote 12
H CDF, Footnote 13
I FRC History Mission, Footnote 22
J Top Ten Harms, Footnote 24
K Top Ten Myths, Footnote 28
L King Review, Footnote 30
M NCSL State DOMAs, Footnote 36
N NCSL State Ballots, Footnote 37
O Weyrich Arlington Group Renewamerica, Footnote 39
P Arlington Group Members, Footnote 40
Q Marriage Amendment Funding, Footnote 42
R Turning On and Turning Out, Footnote 47

2:12-cv-10285-BAF-MJH Doc # 65-2 Filed 08/12/13 Pg 1 of 1 Pg ID 1039
ATTACHMENT A

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 1 of 153 Pg ID 1040
AFAMI News
American
Freedom Law
Center files brief in
support of its
petition for U.S.
Supreme Court
review of federal
Hate Crimes law
Marriage
amendment
coauthor warns
children will be
harmed and
taxpayers hit with
increased social
costs if federal judge
overturns vote of the
people
An open letter to
homosexuals
Anti-gay-rights
group sends letter to
Jackson City
Council
AFA-Michigan
President Gary
Glenn participates in
forum on
employment
benefits for
unmarried
partners
Bill Maher And
Andrew Sullivan
Argue Against Hate
Crime Laws
AFA-Michigan
President Gary
Glenn speaks at
Religious Freedom
Rally
Help AFA-
Michigan protect
and promote
traditional family
values and religious
freedom
Marriage amendment coauthor warns children will
be harmed and taxpayers hit with increased social
costs if federal judge overturns vote of the people
March 7, 2013
Contact: Gary Glenn 9898357978
DETROIT, Mich. A coauthor of Michigans Marriage Protection Amendment
Thursday warned that future generations of children will be harmed
and taxpayers hit with the costs of increased law enforcement, social
services, and welfare programs if a single federal judge redefines marriage and
overturns the state constitutional provision supported by 2.7 million voters in
2004.
The amendment, added to Michigans constitution with the backing of nearly
60 percent of the vote on the November 2004 ballot, reads:
To secure and preserve the benefits of marriage for our society and for future
generations of children, the union of one man and one woman in marriage shall
be the only agreement recognized as a marriage or similar union for any
purpose.
U.S. District Judge Bernard Friedman is scheduled to hear arguments Thursday
at Wayne State University in a lawsuit in which a homosexual couple is asking
the court to declare the amendment in violation of the U.S. Constitution.
Gary Glenn, Midland, president of the American Family Association of
Michigan, said our society and future generations of children will suffer
significant harm if this federal judge, this one man, is arrogant enough to
believe the authors of our Constitution intended him to have the raw power to
overturn the will and common sense of 2.7 million voters.
Glenn, who first proposed the amendment in 2003 and was one of its two co
authors, last week debated the homosexual couples attorney, Dana
Nessel, live on Fox 2 Detroits public affairs television talk show Let It
Rip. (Click to watch nineminute video: http://goo.gl/lHCMw )
Glenn Thursday said the lesbian couple bringing the lawsuit may each be able
to play the role of a mother, but neither one is capable of being a father. The
role model relationship we should continue to uphold and protect and
encourage as the social ideal, as whats best for every child, is to have both a
mother and a father who committed to each other and to their children in
marriage.
Theyre not asking for access to the institution of marriage, he said, theyre
asking a single judge to overrule the people of Michigan and redefine what
marriage is for all of society.
He said legally redefining marriage to include homosexual couples would result
in legal recognition and thus social encouragement
of homosexual relationships in which children would be intentionally, on
purpose, by design, denied having one or the other, either a mother or a
father.
Abortion
Eminent Domain
Homosexual Agenda
AFL-CIO
Boy Scouts
Public Health
In The News
Marriage
News Releases
Pornography
Public Schools and
Universities
Religious Freedom
Religious Heritage
Select Month
Page 1 of 4 AFA Michigan Marriage amendment coauthor warns children will be harmed and taxpa...
8/4/2013 http://www.afamichigan.org/2013/03/07/marriage-amendment-coauthor-warns-children-will...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 2 of 153 Pg ID 1041
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, viewed Aug. 4, 2013
Conservatives
plot to roll back
LGBT protections
AFA-Michigan
opposes anti-
discrimination law
Search
Search
That radical new social model tells women that the uniquely feminine
qualities they bring to parenting are insignificant and unimportant to a childs
emotional and social needs, something a second father could do just as well,
and that young girls are just as well off not having a mother, Glenn said.
People with common sense instinctively know thats not true, nor is it true
of the unique qualities men bring to parenting. Decades of experience
and social ills prove that not having a father in the home has caused serious
harm to children and to society.
Social science has always found that traditional marriage produces children
who are healthier, safer, more financially secure, less likely to be on
welfare, unemployment, or drugs, and less likely to get arrested, Glenn
said. If we as a society return to promoting and incentivizing the moral and
social virtues of oneman, onewoman marriage, well need fewer police, fewer
social services, and less welfare for future generations. Its not just the right
thing to do. For taxpayers, its the smart thing to do.
But as society now promotes homosexual relationships, new studies have
found that children raised by homosexual couples are far more likely to live in
poverty, be on welfare and unemployed, and be involved in criminal activity,
he said. If thats the future we choose for coming generations of children,
taxpayers will be forced to pay for more law enforcement, more social services,
and more welfare programs.
Glenn said social science has consistently found that the best, safest,
healthiest, most secure environment for a child is with its married biological
mother and father, in which children do better in school, are mentally,
emotionally, and physically healthier, and are less likely to use drugs, become
juvenile delinquents, or be involved in teen pregnancy.
He also cited peerreviewed university and other studies which found that
children raised in households headed by adults in a homosexual relationship
fare poorer on a wide range of factors, which he said inevitably lead
to increased costs to taxpayers and society at large.
University of TexasAustin
University of TexasAustin sociologist Mark Regnerus last summer reported the
results of a study that specifically compared adults who were raised
by homosexual couples with adults raised by their biological mother and
father. http://www.sciencedirect.com/science/article/pii/S0049089X12000610
Fox News reported regarding the study: Adult children of gay couples were
two to four times as likely to be on public assistance, more than twice as
likely to be unemployed and more than twice as likely to have contemplated
suicide. http://www.foxnews.com/us/2012/09/03/utexasbacksprofessorin
battlewithgayblogger/
Family Research Councils analysis of the UTA study also reported that the
adult children of homosexual couples were found to be much more likely to
have received welfare. (The study found that while only 17 percent of adults
raised by their mother and father had been on welfare, 69 percent of adults
raised by lesbian couples and 57 percent of adults raised by homosexual men
had received public assistance.)
According to FRC, the study also found that adults raised by homosexual
couples had lower educational attainment, less safety and security and more
ongoing negative impact in the family in which they were raised, and were
arrested more often, while daughters of homosexual couples reported more
sexual partners, both male and female.
In comparison to adults raised by their biological mother and father, adults
raised by lesbian couples in particular who made up 71 percent of the sample
of adults raised by a homosexual couple were found:
Page 2 of 4 AFA Michigan Marriage amendment coauthor warns children will be harmed and taxpa...
8/4/2013 http://www.afamichigan.org/2013/03/07/marriage-amendment-coauthor-warns-children-will...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 3 of 153 Pg ID 1042
almost four times more likely to be currently on public assistance.
more than three times more likely to be unemployed.
ten times more likely to have been touched sexually by a parent or other
adult caregiver.
nearly four times more likely to have been physically forced by someone to
have sex against their will.
more likely to use marijuana and to have pled guilty to a nonminor criminal
offense.
nearly four times more likely to identify as something other than
heterosexual.
more likely to be cohabiting rather than married, and three times more likely
to have had an affair while married or cohabiting.
Kansas State University
Family studies professor Walter Schumm found that children raised by
homosexual couples are far more likely to engage in homosexual behavior
themselves.
As AOL News reported Oct. 17, 2010: The study on sexual orientationsays
that gay and lesbian parents are far more likely to have children who become
gay. (W)hen the study restricted the results so that they included only
children in their 20s presumably after theyd been able to work out any
adolescent confusion or experimentation 58 percent of the children of
lesbians called themselves gay, and 33 percent of the children of gay men
called themselves gay. About 5 to 10 percent of the children of straight parents
call themselves gay, Schumm says. He found that when communities
welcome gays and lesbians, 89 percent feature higher rates of homosexual
behavior. And across all his datahe noticed how lesbians begat more
lesbians. Schumm also finds evidence of gay mothers pushing their
daughters, upset over a relationship with a man, to try out women.
University of Southern California
USC researchers Judith Stacey and Timothy J. Biblarz found that children raised
by homosexual parents are more likely to engage in homosexual behavior
themselves and that females raised by homosexual parents are more
promiscuous.
(A) greater number of young adult children raised by lesbians had participated
in or considered a samesex relationship or had an attraction to the same sex.
Adolescent and young adult girls raised by lesbian mothers appear to be
more sexually adventurous and less chaste, the study found, according to USC
News. http://www.usc.edu/uscnews/stories/6908.html
The Boston Phoenix, a homosexual activist newspaper, reported that as Paula
Ettlebrick of the National Gay and Lesbian Task Force puts it, Stacy and Biblarz
have burst the bubble of one of the bestkept community secrets.
Associated Press national correspondent David Crary reported June 16, 2001:
The new study by two University of Southern California sociologists says
children with lesbian or gay parentsare probably more likely to explore
homosexual activity themselves. Kate Kendall, head of the San Francisco
based National Center for Lesbian Rightsurged lesbians and gays to overcome
any uneasiness they might have about the report. If in fact our kids are
somewhat more likely to identify as lesbian and gay if were ashamed of that
outcome, it means were ashamed of ourselves, Kendall said.
Page 3 of 4 AFA Michigan Marriage amendment coauthor warns children will be harmed and taxpa...
8/4/2013 http://www.afamichigan.org/2013/03/07/marriage-amendment-coauthor-warns-children-will...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 4 of 153 Pg ID 1043
Glenn said children being raised to be more likely to engage in homosexual
behavior as USC and Kansas State researchers found would subject them
to greater risk of the severe health consequences experienced by individuals
involved in such behavior, including higher incidence of domestic
violence, mental illness (Journal of the American Medical Association),
substance abuse, serious lifethreatening diseases such as HIV/AIDS (which
former National Gay and Lesbian Task Force executive director Matt Foreman
called a gay disease), anal cancer, and hepatitis, and according to Oxford
Universitys Journal of Epidemiology, premature death by up to 20 years.
http://goo.gl/vIOqq
Glenn also said that if federal courts redefine marriage as anything other than
between one man and one woman, there will thereafter be no rational,
reasonable, logical, or legally consistent basis for refusing the next special
interest groups demand to redefine marriage again, this time to include
polygamy and group marriage.
Polygamists and bisexuals will claim the same thing these homosexual
plaintiffs are asserting now, that they too have a right to redefine marriage to
let them marry as many people as they claim to love, no matter the impact and
harm to society and future generations of children.
# # #
site designed and hosted by: OptimusMedia.com
Page 4 of 4 AFA Michigan Marriage amendment coauthor warns children will be harmed and taxpa...
8/4/2013 http://www.afamichigan.org/2013/03/07/marriage-amendment-coauthor-warns-children-will...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 5 of 153 Pg ID 1044
ATTACHMENT B

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 6 of 153 Pg ID 1045
How different are the adult children of parents who have same-sex
relationships? Findings from the New Family Structures Study
Mark Regnerus
Department of Sociology and Population Research Center, University of Texas at Austin, 1 University Station A1700, Austin, TX 78712-0118, United States
a r t i c l e i n f o
Article history:
Received 1 February 2012
Revised 29 February 2012
Accepted 12 March 2012
Keywords:
Same-sex parenting
Family structure
Young adulthood
Sampling concerns
a b s t r a c t
The New Family Structures Study (NFSS) is a social-science data-collection project that
elded a survey to a large, random sample of American young adults (ages 1839) who
were raised in different types of family arrangements. In this debut article of the NFSS, I
compare how the young-adult children of a parent who has had a same-sex romantic rela-
tionship fare on 40 different social, emotional, and relational outcome variables when com-
pared with six other family-of-origin types. The results reveal numerous, consistent
differences, especially between the children of women who have had a lesbian relationship
and those with still-married (heterosexual) biological parents. The results are typically
robust in multivariate contexts as well, suggesting far greater diversity in lesbian-parent
household experiences than convenience-sample studies of lesbian families have revealed.
The NFSS proves to be an illuminating, versatile dataset that can assist family scholars in
understanding the long reach of family structure and transitions.
2012 Elsevier Inc. All rights reserved.
1. Introduction
The well-being of children has long been in the center of public policy debates about marriage and family matters in the
United States. That trend continues as state legislatures, voters, and the judiciary considers the legal boundaries of marriage.
Social science data remains one of the few sources of information useful in legal debates surrounding marriage and adoption
rights, and has been valued both by same-sex marriage supporters and opponents. Underneath the politics about marriage
and child development are concerns about family structures possible effects on children: the number of parents present and
active in childrens lives, their genetic relationship to the children, parents marital status, their gender distinctions or sim-
ilarities, and the number of transitions in household composition. In this introduction to the New Family Structures Study
(NFSS), I compare how young adults from a variety of different family backgrounds fare on 40 different social, emotional,
and relational outcomes. In particular, I focus on how respondents who said their mother had a same-sex relationship with
another womanor their father did so with another mancompare with still-intact, two-parent heterosexual married fam-
ilies using nationally-representative data collected from a large probability sample of American young adults.
Social scientists of family transitions have until recently commonly noted the elevated stability and social benets of the
two-parent (heterosexual) married household, when contrasted to single mothers, cohabiting couples, adoptive parents, and
ex-spouses sharing custody (Brown, 2004; Manning et al., 2004; McLanahan and Sandefur, 1994). In 2002, Child Trendsa
well-regarded nonpartisan research organizationdetailed the importance for childrens development of growing up in the
presence of two biological parents (their emphasis; Moore et al., 2002, p. 2). Unmarried motherhood, divorce, cohabitation,
and step-parenting were widely perceived to fall short in signicant developmental domains (like education, behavior prob-
lems, and emotional well-being), due in no small part to the comparative fragility and instability of such relationships.
0049-089X/$ - see front matter 2012 Elsevier Inc. All rights reserved.
http://dx.doi.org/10.1016/j.ssresearch.2012.03.009
E-mail address: regnerus@prc.utexas.edu
Social Science Research 41 (2012) 752770
Contents lists available at SciVerse ScienceDirect
Social Science Research
j our nal homepage: www. el sevi er . com/ l ocat e/ ssr esear ch
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 7 of 153 Pg ID 1046
DeBoer v. Snyder, No.
2:12-cv-10285-BAF-MJH, visited August 4, 2013
In their 2001 American Sociological Review article reviewing ndings on sexual orientation and parenting, however, soci-
ologists Judith Stacey and Tim Biblarz began noting that while there are some differences in outcomes between children in
same-sex and heterosexual unions, there were not as many as family sociologists might expect, and differences need not
necessarily be perceived as decits. Since that time the conventional wisdom emerging from comparative studies of
same-sex parenting is that there are very few differences of note in the child outcomes of gay and lesbian parents (Tasker,
2005; Wainright and Patterson, 2006; Rosenfeld, 2010). Moreover, a variety of possible advantages of having a lesbian couple
as parents have emerged in recent studies (Crowl et al., 2008; Biblarz and Stacey, 2010; Gartrell and Bos, 2010; MacCallum
and Golombok, 2004). The scholarly discourse concerning gay and lesbian parenting, then, has increasingly posed a challenge
to previous assumptions about the supposed benets of being raised in biologically-intact, two-parent heterosexual
households.
1.1. Sampling concerns in previous surveys
Concern has arisen, however, about the methodological quality of many studies focusing on same-sex parents. In partic-
ular, most are based on non-random, non-representative data often employing small samples that do not allow for gener-
alization to the larger population of gay and lesbian families (Nock, 2001; Perrin and Committee on Psychosocial Aspects
of Child and Family Health, 2002; Redding, 2008). For instance, many published studies on the children of same-sex parents
collect data from snowball or convenience samples (e.g., Bos et al., 2007; Brewaeys et al., 1997; Fulcher et al., 2008; Sirota,
2009; Vanfraussen et al., 2003). One notable example of this is the National Longitudinal Lesbian Family Study, analyses of
which were prominently featured in the media in 2011 (e.g., Hufngton Post, 2011). The NLLFS employs a convenience sam-
ple, recruited entirely by self-selection from announcements posted at lesbian events, in womens bookstores, and in les-
bian newspapers in Boston, Washington, and San Francisco. While I do not wish to downplay the signicance of such a
longitudinal studyit is itself quite a featthis sampling approach is a problem when the goal (or in this case, the practical
result and conventional use of its ndings) is to generalize to a population. All such samples are biased, often in unknown
ways. As a formal sampling method, snowball sampling is known to have some serious problems, one expert asserts (Snij-
ders, 1992, p. 59). Indeed, such samples are likely biased toward inclusion of those who have many interrelationships with,
or are coupled to, a large number of other individuals (Berg, 1988, p. 531). But apart from the knowledge of individuals
inclusion probability, unbiased estimation is not possible.
Further, as Nock (2001) entreated, consider the convenience sample recruited from within organizations devoted to
seeking rights for gays and lesbians, like the NLLFS sampling strategy. Suppose, for example, that the respondents have
higher levels of education than comparable lesbians who do not frequent such events or bookstores, or who live else-
where. If such a sample is used for research purposes, then anything that is correlated with educational attainmentlike
better health, more deliberative parenting, and greater access to social capital and educational opportunities for children
will be biased. Any claims about a population based on a group that does not represent it will be distorted, since its sam-
ple of lesbian parents is less diverse (given what is known about it) than a representative sample would reveal (Baumle
et al., 2009).
To compound the problem, results from nonprobability samplesfrom which meaningful statistics cannot be generated
are regularly compared with population-level samples of heterosexual parents, which no doubt are comprised of a blend of
higher and lower quality parents. For example, Gartrell et al. (2011a,b) inquired about the sexual orientation and behavior of
adolescents by comparing data from the National Survey of Family Growth (NSFG) with those in the snowball sample of
youth in the NLLFS. Comparing a population-based sample (the NSFG) to a select sample of youth from same-sex parents
does not provide the statistical condence demanded of good social science. Until now, this has been a primary way in which
scholars have collected and evaluated data on same-sex parents. This is not to suggest that snowball samples are inherently
problematic as data-collection techniques, only that they are not adequate for making useful comparisons with samples that
are entirely different with regard to selection characteristics. Snowball and various other types of convenience sampling are
simply not widely generalizable or comparable to the population of interest as a whole. While researchers themselves com-
monly note this important limitation, it is often entirely lost in the translation and transmission of ndings by the media to
the public.
1.2. Are there notable differences?
The no differences paradigm suggests that children from same-sex families display no notable disadvantages when
compared to children from other family forms. This suggestion has increasingly come to include even comparisons with
intact biological, two-parent families, the form most associated with stability and developmental benets for children
(McLanahan and Sandefur, 1994; Moore et al., 2002).
Answering questions about notable between-group differences has nevertheless typically depended on with whom com-
parisons are being made, what outcomes the researchers explored, and whether the outcomes evaluated are considered sub-
stantial or supercial, or portents of future risk. Some outcomeslike sexual behavior, gender roles, and democratic
parenting, for examplehave come to be valued differently in American society over time.
For the sake of brevityand to give ample space here to describing the NFSSI will avoid spending too much time
describing previous studies, many of whose methodological challenges are addressed by the NFSS. Several review articles,
M. Regnerus / Social Science Research 41 (2012) 752770 753
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 8 of 153 Pg ID 1047
and at least one book, have sought to provide a more thorough assessment of the literature (Anderssen et al., 2002; Biblarz
and Stacey, 2010; Goldberg, 2010; Patterson, 2000; Stacey and Biblarz, 2001a). Sufce it to say that versions of the phrase
no differences have been employed in a wide variety of studies, reports, depositions, books, and articles since 2000 (e.g.,
Crowl et al., 2008; Movement Advancement Project, 2011; Rosenfeld, 2010; Tasker, 2005; Stacey and Biblarz, 2001a,b;
Veldorale-Brogan and Cooley, 2011; Wainright et al., 2004).
Much early research on gay parents typically compared the child development outcomes of divorced lesbian mothers
with those of divorced heterosexual mothers (Patterson, 1997). This was also the strategy employed by psychologist Fiona
Tasker (2005), who compared lesbian mothers with single, divorced heterosexual mothers and found no systematic differ-
ences between the quality of family relationships therein. Wainright et al. (2004), using 44 cases in the nationally-repre-
sentative Add Health data, reported that teenagers living with female same-sex parents displayed comparable self-
esteem, psychological adjustment, academic achievement, delinquency, substance use, and family relationship quality to
44 demographically matched cases of adolescents with opposite-sex parents, suggesting that here too the comparisons
were not likely made with respondents from stable, biologically-intact, married families.
However, small sample sizes can contribute to no differences conclusions. It is not surprising that statistically-signi-
cant differences would not emerge in studies employing as few as 18 or 33 or 44 cases of respondents with same-sex parents,
respectively (Fulcher et al., 2008; Golombok et al., 2003; Wainright and Patterson, 2006). Even analyzing matched samples,
as a variety of studies have done, fails to mitigate the challenge of locating statistically-signicant differences when the sam-
ple size is small. This is a concern in all of social science, but one that is doubly important when there may be motivation to
conrm the null hypothesis (that is, that there are in fact no statistically-signicant differences between groups). Therefore,
one important issue in such studies is the simple matter of if there is enough statistical power to detect meaningful differ-
ences should they exist. Rosenfeld (2010) is the rst scholar to employ a large, random sample of the population in order to
compare outcomes among children of same-sex parents with those of heterosexual married parents. He concludedafter
controlling for parents education and income and electing to limit the sample to households exhibiting at least 5 years of
co-residential stabilitythat there were no statistically-signicant differences between the two groups in a pair of measures
assessing childrens progress through primary school.
Sex-related outcomes have more consistently revealed distinctions, although the tone of concern about them has dimin-
ished over time. For example, while the daughters of lesbian mothers are now widely understood to be more apt to explore
same-sex sexual identity and behavior, concern about this nding has faded as scholars and the general public have become
more accepting of GLB identities (Goldberg, 2010). Tasker and Golombok (1997) noted that girls raised by lesbian mothers
reported a higher number of sexual partners in young adulthood than daughters of heterosexual mothers. Boys with lesbian
mothers, on the other hand, appear to display the opposite trendfewer partners than the sons of heterosexual mothers.
More recently, however, the tone about no differences has shifted some toward the assertion of differences, and that
same-sex parents appear to be more competent than heterosexual parents (Biblarz and Stacey, 2010; Crowl et al., 2008).
Even their romantic relationships may be better: a comparative study of Vermont gay civil unions and heterosexual mar-
riages revealed that same-sex couples report higher relationship quality, compatibility, and intimacy, and less conict than
did married heterosexual couples (Balsam et al., 2008). Biblarz and Staceys (2010) review article on gender and parenting
asserts that,
based strictly on the published science, one could argue that two women parent better on average than a woman and a
man, or at least than a woman and man with a traditional division of labor. Lesbian coparents seem to outperform com-
parable married heterosexual, biological parents on several measures, even while being denied the substantial privileges
of marriage (p. 17).
Even here, however, the authors note that lesbian parents face a somewhat greater risk of splitting up, due, they sug-
gest, to their asymmetrical biological and legal statuses and their high standards of equality (2010, p. 17).
Another meta-analysis asserts that non-heterosexual parents, on average, enjoy signicantly better relationships with
their children than do heterosexual parents, together with no differences in the domains of cognitive development, psycho-
logical adjustment, gender identity, and sexual partner preference (Crowl et al., 2008).
However, the meta-analysis reinforces the profound importance of who is doing the reportingnearly always volunteers
for small studies on a group whose claims about documentable parenting successes are very relevant in recent legislative
and judicial debates over rights and legal statuses. Tasker (2010, p. 36) suggests caution:
Parental self-report, of course, may be biased. It is plausible to argue that, in a prejudiced social climate, lesbian and gay
parents may have more at stake in presenting a positive picture. . ..Future studies need to consider using additional
sophisticated measures to rule out potential biases. . .
Sufce it to say that the pace at which the overall academic discourse surrounding gay and lesbian parents comparative
competence has shiftedfrom slightly-less adept to virtually identical to more adeptis notable, and rapid. By comparison,
studies of adoptiona common method by which many same-sex couples (but more heterosexual ones) become parents
have repeatedly and consistently revealed important and wide-ranging differences, on average, between adopted children
and biological ones. In fact, these differences have been so pervasive and consistent that adoption experts now emphasize
that acknowledgement of difference is critical for both parents and clinicians when working with adopted children and
754 M. Regnerus / Social Science Research 41 (2012) 752770
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 9 of 153 Pg ID 1048
teens (Miller et al., 2000). This ought to give social scientists studying gay parenting outcomes pause, especially in light of
concerns noted above about small sample sizes and the absence of a comparable recent, documented improvement in out-
comes from youth in adopted families and stepfamilies.
Far more, too, is known about the children of lesbian mothers than about those of gay fathers (Biblarz and Stacey, 2010;
Patterson, 2006; Veldorale-Brogan and Cooley, 2011). Biblarz and Stacey (2010, p. 17) note that while gay-male families re-
main understudied, their daunting routes to parenthood seem likely to select more for strengths than limitations. Others
are not so optimistic. One veteran of a study of the daughters of gay fathers warns scholars to avoid overlooking the family
dynamics of emergent gay parents, who likely outnumber planned ones: Children born into heterosexually organized
marriages where fathers come out as gay or bisexual also face having to deal with maternal bitterness, marital conict, pos-
sible divorce, custody issues, and fathers absence (Sirota, 2009, p. 291).
Regardless of sampling strategy, scholars also know much less about the lives of young-adult children of gay and lesbian
parents, or how their experiences and accomplishments as adults compare with others who experienced different sorts of
household arrangements during their youth. Most contemporary studies of gay parenting processes have focused on the
presentwhat is going on inside the household when children are still under parental care (Tasker, 2005; Bos and Sandfort,
2010; Brewaeys et al., 1997). Moreover, such research tends to emphasize parent-reported outcomes like parental divisions of
labor, parentchild closeness, daily interaction patterns, gender roles, and disciplinary habits. While such information is
important to learn, it means we know far more about the current experience of parents in households with children than
we do about young adults who have already moved through their childhood and nowspeak for themselves. Studies on family
structure, however, serve scholars and family practitioners best when they span into adulthood. Do the children of gay and
lesbian parents look comparable to those of their heterosexual counterparts? The NFSS is poised to address this question
about the lives of young adults between the ages of 18 and 39, but not about children or adolescents. While the NFSS is
not the answer to all of this domains methodological challenges, it is a notable contribution in important ways.
1.3. The New Family Structures Study
Besides being brand-new data, several other aspects about the NFSS are novel and noteworthy. First, it is a study of young
adults rather than children or adolescents, with particular attention paid to reaching ample numbers of respondents who
were raised by parents that had a same-sex relationship. Second, it is a much larger study than nearly all of its peers. The
NFSS interviewed just under 3000 respondents, including 175 who reported their mother having had a same-sex romantic
relationship and 73 who said the same about their father. Third, it is a weighted probability sample, from which meaningful
statistical inferences and interpretations can be drawn. While the 2000 (and presumably, the 2010) US Census Integrated
Public Use Microdata Series (IPUMS) offers the largest nationally-representative sample-based information about youth in
same-sex households, the Census collects much less outcome information of interest. The NFSS, however, asked numerous
questions about respondents social behaviors, health behaviors, and relationships. This manuscript provides the rst
glimpse into those outcomes by offering statistical comparisons of them among eight different family structures/experiences
of origin. Accordingly, there is much that the NFSS offers, and not just about the particular research questions of this study.
There are several things the NFSS is not. The NFSS is not a longitudinal study, and therefore cannot attempt to broach
questions of causation. It is a cross-sectional study, and collected data from respondents at only one point in time, when they
were between the ages of 18 and 39. It does not evaluate the offspring of gay marriages, since the vast majority of its respon-
dents came of age prior to the legalization of gay marriage in several states. This study cannot answer political questions
about same-sex relationships and their legal legitimacy. Nevertheless, social science is a resource that offers insight to polit-
ical and legal decision-makers, and there have been enough competing claims about what the data says about the children
of same-sex parentsincluding legal depositions of social scientists in important casesthat a study with the methodolog-
ical strengths of this one deserves scholarly attention and scrutiny.
2. Data collection, measures, and analytic approach
The NFSS data collection project is based at the University of Texas at Austins Population Research Center. A survey de-
sign team consisting of several leading family researchers in sociology, demography, and human developmentfrom Penn
State University, Brigham Young University, San Diego State University, the University of Virginia, and several from the
University of Texas at Austinmet over 2 days in January 2011 to discuss the projects sampling strategy and scope, and con-
tinued to offer advice as questions arose over the course of the data collection process. The team was designed to merge
scholars across disciplines and ideological lines in a spirit of civility and reasoned inquiry. Several additional external con-
sultants also gave close scrutiny to the survey instrument, and advised on how best to measure diverse topics. Both the study
protocol and the questionnaire were approved by the University of Texas at Austins Institutional Review Board. The NFSS
data is intended to be publicly accessible and will thus be made so with minimal requirements by mid-late 2012. The NFSS
was supported in part by grants from the Witherspoon Institute and the Bradley Foundation. While both of these are com-
monly known for their support of conservative causesjust as other private foundations are known for supporting more
liberal causesthe funding sources played no role at all in the design or conduct of the study, the analyses, the interpreta-
tions of the data, or in the preparation of this manuscript.
M. Regnerus / Social Science Research 41 (2012) 752770 755
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 10 of 153 Pg ID 1049
2.1. The data collection process
The data collection was conducted by Knowledge Networks (or KN), a research rm with a very strong record of gener-
ating high-quality data for academic projects. Knowledge Networks recruited the rst online research panel, dubbed the
KnowledgePanel

, that is representative of the US population. Members of the KnowledgePanel

are randomly recruited


by telephone and mail surveys, and households are provided with access to the Internet and computer hardware if needed.
Unlike other Internet research panels sampling only individuals with Internet access who volunteer for research, the Knowl-
edgePanel

is based on a sampling frame which includes both listed and unlisted numbers, those without a landline tele-
phone and is not limited to current Internet users or computer owners, and does not accept self-selected volunteers. As a
result, it is a random, nationally-representative sample of the American population. At last count, over 350 working papers,
conference presentations, published articles, and books have used Knowledge Networks panels, including the 2009 National
Survey of Sexual Health and Behavior, whose extensive results were featured in an entire volume of the Journal of Sexual
Medicineand prominently in the mediain 2010 (Herbenick et al., 2010). More information about KN and the Knowledge-
Panel

, including panel recruitment, connection, retention, completion, and total response rates, are available from KN. The
typical within survey response rate for a KnowledgePanel

survey is 65%. Appendix A presents a comparison of age-appro-


priate summary statistics from a variety of socio-demographic variables in the NFSS, alongside the most recent iterations of
the Current Population Survey, the National Longitudinal Study of Adolescent Health (Add Health), the National Survey of
Family Growth, and the National Study of Youth and Religionall recent nationally-representative survey efforts. The esti-
mates reported there suggest the NFSS compares very favorably with other nationally-representative datasets.
2.2. The screening process
Particularly relevant for the NFSS is the fact that key populationsgay and lesbian parents, as well as heterosexual adop-
tive parentscan be challenging to identify and locate. The National Center for Marriage and Family Research (2010) esti-
mates that there are approximately 580,000 same-sex households in the United States. Among them, about 17%or
98,600are thought to have children present. While that may seem like a substantial number, in population-based sampling
strategies it is not. Locating minority populations requires a search for a probability sample of the general population, typ-
ically by way of screening the general population to identify members of rarer groups. Thus in order to boost the number of
respondents who reported being adopted or whose parent had a same-sex romantic relationship, the screener survey (which
distinguished such respondents) was left in the eld for several months between July 2011 and February 2012, enabling
existing panelists more time to be screened and new panelists to be added. Additionally, in late Fall 2011, former members
of the KnowledgePanel

were re-contacted by mail, phone, and email to encourage their screening. A total of 15,058 current
and former members of KNs KnowledgePanel

were screened and asked, among several other questions, From when you
were born until age 18 (or until you left home to be on your own), did either of your parents ever have a romantic relation-
ship with someone of the same sex? Response choices were Yes, my mother had a romantic relationship with another wo-
man, Yes, my father had a romantic relationship with another man, or no. (Respondents were also able to select both of
the rst two choices.) If they selected either of the rst two, they were asked about whether they had ever lived with that
parent while they were in a same-sex romantic relationship. The NFSS completed full surveys with 2988 Americans between
the ages of 18 and 39. The screener and full survey instrument is available at the NFSS homepage, located at: www.prc.utex-
as.edu/nfss.
2.3. What does a representative sample of gay and lesbian parents (of young adults) look like?
The weighted screener dataa nationally-representative samplereveal that 1.7% of all Americans between the ages of
18 and 39 report that their father or mother has had a same-sex relationship, a gure comparable to other estimates of chil-
dren in gay and lesbian households (e.g., Stacey and Biblarz (2001a,b) report a plausible range from 1% to 12%). Over twice as
many respondents report that their mother has had a lesbian relationship as report that their fathers have had a gay rela-
tionship. (A total of 58% of the 15,058 persons screened report spending their entire youthup until they turned 18 or left
the housewith their biological mother and father.)
While gay and lesbian Americans typically become parents today in four waysthrough one partners previous partici-
pation in a heterosexual union, through adoption, in-vitro fertilization, or by a surrogatethe NFSS is more likely to be com-
prised of respondents from the rst two of these arrangements than from the last two. Todays children of gay men and
lesbian women are more apt to be planned (that is, by using adoption, IVF, or surrogacy) than as little as 1520 years
ago, when such children were more typically the products of heterosexual unions. The youngest NFSS respondents turned
18 in 2011, while the oldest did so in 1990. Given that unintended pregnancy is impossible among gay men and a rarity
among lesbian couples, it stands to reason that gay and lesbian parents today are far more selective about parenting than
the heterosexual population, among whom unintended pregnancies remain very common, around 50% of total (Finer and
Henshaw, 2006). The share of all same-sex parenting arrangements that is planned, however, remains unknown. Although
the NFSS did not directly ask those respondents whose parent has had a same-sex romantic relationship about the manner of
756 M. Regnerus / Social Science Research 41 (2012) 752770
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 11 of 153 Pg ID 1050
their own birth, a failed heterosexual union is clearly the modal method: just under half of such respondents reported that
their biological parents were once married. This distinguishes the NFSS from numerous studies that have been entirely con-
cerned with planned gay and lesbian families, like the NLLFS.
Among those who said their mother had a same-sex relationship, 91% reported living with their mother while she was in
the romantic relationship, and 57% said they had lived with their mother and her partner for at least 4 months at some point
prior to age 18. A smaller share (23%) said they had spent at least 3 years living in the same household with a romantic part-
ner of their mothers.
Among those who said their father had a same-sex relationship, however, 42% reported living with him while he was in a
same-sex romantic relationship, and 23% reported living with him and his partner for at least 4 months (but less than 2% said
they had spent at least 3 years together in the same household), a trend similarly noted in Taskers (2005) review article on
gay and lesbian parenting.
Fifty-eight (58) percent of those whose biological mothers had a same-sex relationship also reported that their biological
mother exited the respondents household at some point during their youth, and just under 14% of them reported spending
time in the foster care system, indicating greater-than-average household instability. Ancillary analyses of the NFSS suggests
a likely planned lesbian origin of between 17% and 26% of such respondents, a range estimated from the share of such
respondents who claimed that (1) their biological parents were never married or lived together, and that (2) they never lived
with a parental opposite-sex partner or with their biological father. The share of respondents (whose fathers had a same-sex
relationship) that likely came from planned gay families in the NFSS is under 1%.
These distinctions between the NFSSa population-based sampleand small studies of planned gay and lesbian families
nevertheless raise again the question of just how unrepresentative convenience samples of gay and lesbian parents actually
are. The use of a probability sample reveals that the young-adult children of parents who have had same-sex relationships
(in the NFSS) look less like the children of todays stereotypic gay and lesbian coupleswhite, uppermiddle class, well-edu-
cated, employed, and prosperousthan many studies have tacitly or explicitly portrayed. Goldberg (2010, pp. 1213) aptly
notes that existing studies of lesbian and gay couples and their families have largely included white, middle-class persons
who are relatively out in the gay community and who are living in urban areas, while working-class sexual minorities,
racial or ethnic sexual minorities, sexual minorities who live in rural or isolated geographical areas have been overlooked,
understudied, and difcult to reach. Rosenfelds (2010) analysis of Census data suggests that 37% of children in lesbian
cohabiting households are Black or Hispanic. Among respondents in the NFSS who said their mother had a same-sex rela-
tionship, 43% are Black or Hispanic. In the NLLFS, by contrast, only 6% are Black or Hispanic.
This is an important oversight: demographic indicators of where gay parents live today point less toward stereotypic
places like New York and San Francisco and increasingly toward locales where families are more numerous and overall fer-
tility is higher, like San Antonio and Memphis. In their comprehensive demographic look at the American gay and lesbian
population, Gates and Ost (2004, p. 47) report, States and large metropolitan areas with relatively low concentrations of
gay and lesbian couples in the population tend to be areas where same-sex couples are more likely to have children in
the household. A recent updated brief by Gates (2011, p. F3) reinforces this: Geographically, same-sex couples are most
likely to have children in many of the most socially conservative parts of the country. Moreover, Gates notes that racial
minorities are disproportionately more likely (among same-sex households) to report having children; whites, on the other
hand, are disproportionately less likely to have children. The NFSS sample reveals the same. Gates Census-based assess-
ments further raise questions about the sampling strategies ofand the popular use of conclusions fromstudies based en-
tirely on convenience samples derived from parents living in progressive metropolitan locales.
2.4. The structure and experience of respondents families of origin
The NFSS sought to provide as clear a vision as possible of the respondents household composition during their childhood
and adolescence. The survey asked respondents about the marital status of their biological parents both in the past and pres-
ent. The NFSS also collected calendar data from each respondent about their relationship to people who lived with them in
their household (for more than 4 months) from birth to age 18, as well as who has lived with them from age 18after they
have left hometo the present. While the calendar data is utilized only sparingly in this study, such rich data enables
researchers to document who else has lived with the respondent for virtually their entire life up to the present.
For this particular study, I compare outcomes across eight different types of family-of-origin structure and/or experience.
They were constructed from the answers to several questions both in the screener survey and the full survey. It should be
noted, however, that their construction reects an unusual combination of intereststhe same-sex romantic behavior of par-
ents, and the experience of household stability or disruption. The eight groups or household settings (with an acronym or
short descriptive title) evaluated here, followed by their maximum unweighted analytic sample size, are:
1. IBF: Lived in intact biological family (with mother and father) from 0 to 18, and parents are still married at present
(N = 919).
2. LM: R reported Rs mother had a same-sex romantic (lesbian) relationship with a woman, regardless of any other
household transitions (N = 163).
3. GF: R reported Rs father had a same-sex romantic (gay) relationship with a man, regardless of any other household
transitions (N = 73).
M. Regnerus / Social Science Research 41 (2012) 752770 757
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 12 of 153 Pg ID 1051
4. Adopted: R was adopted by one or two strangers at birth or before age 2 (N = 101).
5. Divorced later or had joint custody: R reported living with biological mother and father from birth to age 18, but par-
ents are not married at present (N = 116).
6. Stepfamily: Biological parents were either never married or else divorced, and Rs primary custodial parent was mar-
ried to someone else before R turned 18 (N = 394).
7. Single parent: Biological parents were either never married or else divorced, and Rs primary custodial parent did not
marry (or remarry) before R turned 18 (N = 816).
8. All others: Includes all other family structure/event combinations, such as respondents with a deceased parent
(N = 406).
Together these eight groups account for the entire NFSS sample. These eight groups are largely, but not entirely, mutually
exclusive in reality. That is, a small minority of respondents might t more than one group. I have, however, forced their
mutual exclusivity here for analytic purposes. For example, a respondent whose mother had a same-sex relationship might
also qualify in Group 5 or Group 7, but in this case my analytical interest is in maximizing the sample size of Groups 2 and 3
so the respondent would be placed in Group 2 (LMs). Since Group 3 (GFs) is the smallest and most difcult to locate ran-
domly in the population, its composition trumped that of others, even LMs. (There were 12 cases of respondents who re-
ported both a mother and a father having a same-sex relationship; all are analyzed here as GFs, after ancillary analyses
revealed comparable exposure to both their mother and father).
Obviously, different grouping decisions may affect the results. The NFSS, which sought to learn a great deal of information
about respondents families of origin, is well-poised to accommodate alternative grouping strategies, including distinguish-
ing those respondents who lived with their lesbian mothers partner for several years (vs. sparingly or not at all), or early in
their childhood (compared to later). Small sample sizes (and thus reduced statistical power) may nevertheless hinder some
strategies.
In the results section, for maximal ease, I often make use of the acronyms IBF (child of a still-intact biological family), LM
(child of a lesbian mother), and GF (child of a gay father). It is, however, very possible that the same-sex romantic relation-
ships about which the respondents report were not framed by those respondents as indicating their own (or their parents
own) understanding of their parent as gay or lesbian or bisexual in sexual orientation. Indeed, this is more a study of the chil-
dren of parents who have had (and in some cases, are still in) same-sex relationships than it is one of children whose parents
have self-identied or are out as gay or lesbian or bisexual. The particular parental relationships the respondents were
queried about are, however, gay or lesbian in content. For the sake of brevity and to avoid entanglement in interminable
debates about xed or uid orientations, I will regularly refer to these groups as respondents with a gay father or lesbian
mother.
2.5. Outcomes of interest
This study presents an overview of 40 outcome measures available in the NFSS. Table 1 presents summary statistics for all
variables. Why these outcomes? While the survey questionnaire (available online) contains several dozen outcome questions
of interest, I elected to report here an overview of those outcomes, seeking to include common and oft-studied variables of
interest from a variety of different domains. I include all of the particular indexes we sought to evaluate, and a broad list of
outcomes from the emotional, relational, and social domains. Subsequent analyses of the NFSS will no doubt examine other
outcomes, as well as examine the same outcomes in different ways.
The dichotomous outcome variables summarized in Table 1 are the following: relationship status, employment status,
whether they voted in the last presidential election, and use of public assistance (both currently and while growing up),
the latter of which was asked as Before you were 18 years old, did anyone in your immediate family (that is, in your house-
hold) ever receive public assistance (such as welfare payments, food stamps, Medicaid, WIC, or free lunch)? Respondents
were also asked about whether they had ever seriously thought about committing suicide in the past 12 months, and about
their utilization of counseling or psychotherapy for treatment of any problem connected with anxiety, depression, relation-
ships, etc.
The Kinsey scale of sexual behavior was employed, but modied to allow respondents to select the best description of
their sexual orientation (rather than behavior). Respondents were asked to choose the description that best ts how they
think about themselves: 100% heterosexual, mostly heterosexual but somewhat attracted to people of your own sex, bisex-
ual (that is, attracted to men and women equally), mostly homosexual but somewhat attracted to people of the opposite sex,
100% homosexual, or not sexually attracted to either males or females. For simplicity of presentation, I create a dichotomous
measure indicating 100% heterosexual (vs. anything else). Additionally, unmarried respondents who are currently in a rela-
tionship were asked if their romantic partner is a man or a woman, allowing construction of a measure of currently in a
same-sex romantic relationship.
All respondents were asked if a parent or other adult caregiver ever touched you in a sexual way, forced you to touch him
or her in a sexual way, or forced you to have sexual relations? Possible answers were: no, never; yes, once; yes, more than
once; or not sure. A broader measure about forced sex was asked before it, and read as follows: Have you ever been phys-
ically forced to have any type of sexual activity against your will? It employs identical possible answers; both have been
dichotomized for the analyses (respondents who were not sure were not included). Respondents were also asked if they
758 M. Regnerus / Social Science Research 41 (2012) 752770
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 13 of 153 Pg ID 1052
Table 1
Weighted summary statistics of measures, NFSS.
NFSS variables Range Mean SD N
Currently married 0, 1 0.41 0.49 2988
Currently cohabiting 0, 1 0.15 0.36 2988
Family received welfare growing up 0, 1 0.34 0.47 2669
Currently on public assistance 0, 1 0.21 0.41 2952
Currently employed full-time 0,1 0.45 0.50 2988
Currently unemployed 0, 1 0.12 0.32 2988
Voted in last presidential election 0, 1 0.55 0.50 2960
Bullied while growing up 0, 1 0.36 0.48 2961
Ever suicidal during past year 0, 1 0.07 0.25 2953
Recently or currently in therapy 0, 1 0.11 0.32 2934
Identies as entirely heterosexual 0, 1 0.85 0.36 2946
Is in a same-sex romantic relationship 0, 1 0.06 0.23 1056
Had affair while married/cohabiting 0, 1 0.19 0.39 1869
Has ever had an STI 0, 1 0.11 0.32 2911
Ever touched sexually by parent/adult 0, 1 0.07 0.26 2877
Ever forced to have sex against will 0, 1 0.13 0.33 2874
Educational attainment 15 2.86 1.11 2988
Family-of-origin safety/security 15 3.81 0.97 2917
Family-of-origin negative impact 15 2.58 0.98 2919
Closeness to biological mother 15 4.05 0.87 2249
Closeness to biological father 15 3.74 0.98 1346
Self-reported physical health 15 3.57 0.94 2964
Self-reported overall happiness 15 4.00 1.05 2957
CES-D depression index 14 1.89 0.62 2815
Attachment scale (depend) 15 2.97 0.84 2848
Attachment scale (anxiety) 15 2.51 0.77 2830
Impulsivity scale 14 1.88 0.59 2861
Level of household income 113 7.42 3.17 2635
Current relationship quality index 15 3.98 0.98 2218
Current relationship is in trouble 14 2.19 0.96 2274
Frequency of marijuana use 16 1.50 1.23 2918
Frequency of alcohol use 16 2.61 1.36 2922
Frequency of drinking to get drunk 16 1.70 1.09 2922
Frequency of smoking 16 2.03 1.85 2922
Frequency of watching TV 16 3.15 1.60 2919
Frequency of having been arrested 14 1.29 0.63 2951
Frequency pled guilty to non-minor offense 14 1.16 0.46 2947
N of female sex partners (among women) 011 0.40 1.10 1975
N of female sex partners (among men) 011 3.16 2.68 937
N of male sex partners (among women) 011 3.50 2.52 1951
N of male sex partners (among men) 011 0.40 1.60 944
Age 1839 28.21 6.37 2988
Female 0, 1 0.51 0.50 2988
White 0, 1 0.57 0.49 2988
Gay-friendliness of state of residence 15 2.58 1.78 2988
Family-of-origin structure groups
Intact biological family (IBF) 0, 1 0.40 0.49 2988
Mother had same-sex relationship (LM) 0, 1 0.01 0.10 2988
Father had same-sex relationship (GF) 0, 1 0.01 0.75 2988
Adopted age 02 0, 1 0.01 0.75 2988
Divorced later/joint custody 0, 1 0.06 0.23 2988
Stepfamily 0, 1 0.17 0.38 2988
Single parent 0, 1 0.19 0.40 2988
All others 0, 1 0.15 0.36 2988
Mothers education
Less than high school 0, 1 0.15 0.35 2988
Received high school diploma 0, 1 0.28 0.45 2988
Some college/associates degree 0, 1 0.26 0.44 2988
Bachelors degrees 0, 1 0.15 0.36 2988
More than bachelors 0, 1 0.08 0.28 2988
Do not know/missing 0, 1 0.08 0.28 2988
Family-of-origin income
$020,000 0, 1 0.13 0.34 2988
$20,00140,000 0, 1 0.19 0.39 2988
$40,00175,000 0, 1 0.25 0.43 2988
$75,001100,000 0, 1 0.14 0.34 2988
$100,001150,000 0, 1 0.05 0.22 2988
(continued on next page)
M. Regnerus / Social Science Research 41 (2012) 752770 759
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 14 of 153 Pg ID 1053
had ever had a sexually-transmitted infection, and if they had ever had a sexual relationship with someone else while they
(the respondent) were married or cohabiting.
Among continuous variables, I included a ve-category educational achievement measure, a standard ve-point self-
reported measure of general physical health, a ve-point measure of overall happiness, a 13-category measure of total
household income before taxes and deductions last year, and a four-point (frequency) measure of how often the respondent
thought their current relationship might be in trouble (never once, once or twice, several times, or numerous times).
Several continuous variables were constructed from multiple measures, including an eight-measure modied version of
the CES-D depression scale, an index of the respondents reported current (romantic) relationship quality, closeness to
the respondents biological mother and father, and a pair of attachment scalesone assessing dependability and the other
anxiety. Finally, a pair of indexes captures (1) the overall safety and security in their family while growing up, and (2)
respondents impressions of negative family-of-origin experiences that continue to affect them. These are part of a multidi-
mensional relationship assessment instrument (dubbed RELATE) designed with the perspective that aspects of family life,
such as the quality of the parents relationship with their children, create a family tone that can be mapped on a continuum
from safe/predictable/rewarding to unsafe/chaotic/punishing (Busby et al., 2001). Each of the scales and their component
measures are detailed in Appendix B.
Finally, I evaluate nine count outcomes, seven of which are frequency measures, and the other two counts of gender-spe-
cic sexual partners. Respondents were asked, During the past year, howoften did you. . . watch more than 3 h of television
in a row, use marijuana, smoke, drink alcohol, and drink with the intent to get drunk. Responses (05) ranged from never
to every day or almost every day. Respondents were also asked if they have ever been arrested, and if they had ever been
convicted of or pled guilty to any charges other than a minor trafc violation. Answers to these two ranged from 0 (no, never)
to 3 (yes, numerous times). Two questions about respondents number of sex partners were asked (of both men and women)
in this way: How many different women have you ever had a sexual relationship with? This includes any female you had
sex with, even if it was only once or if you did not know her well. The same question was asked about sexual relationships
with men. Twelve responses were possible: 0, 1, 2, 3, 46, 79, 1015, 1620, 2130, 3150, 5199, and 100+.
2.6. Analytic approach
My analytic strategy is to highlight distinctions between the eight family structure/experience groups on the 40 outcome
variables, both in a bivariate manner (using a simple T-test) and in a multivariate manner using appropriate variable-specic
regression techniqueslogistic, OLS, Poisson, or negative binomialand employing controls for respondents age, race/eth-
nicity, gender, mothers education, and perceived family-of-origin income, an approach comparable to Rosenfelds (2010)
analysis of differences in children making normal progress through school and the overview article highlighting the ndings
of the rst wave of the Add Health study (Resnick et al., 1997). Additionally, I controlled for having been bullied, the measure
for which was asked as follows: While growing up, children and teenagers typically experience negative interactions with
others. We say that someone is bullied when someone else, or a group, says or does nasty and unpleasant things to him or
her. We do not consider it bullying when two people quarrel or ght, however. Do you recall ever being bullied by someone
else, or by a group, such that you still have vivid, negative memories of it?
Finally, survey respondents current state of residence was coded on a scale (15) according to how expansive or restric-
tive its laws are concerning gay marriage and the legal rights of same-sex couples (as of November 2011). Emerging research
suggests state-level political realities about gay rights may discernibly shape the lives of GLB residents (Hatzenbuehler et al.,
2009; Rostosky et al., 2009). This coding scheme was borrowed from a Los Angeles Times effort to map the timeline of state-
level rights secured for gay unions. I modied it from a 10-point to a 5-point scale (Times Research Reporting, 2012). I clas-
sify the respondents current state in one of the following ve ways:
1 = Constitutional amendment banning gay marriage and/or other legal rights.
2 = Legal ban on gay marriage and/or other legal rights.
3 = No specic laws/bans and/or domestic partnerships are legal.
4 = Domestic partnerships with comprehensive protections are legal and/or gay marriages performed elsewhere are
recognized.
5 = Civil unions are legal and/or gay marriage is legal.
Each case in the NFSS sample was assigned a weight based on the sampling design and their probability of being selected,
ensuring a sample that is nationally representative of American adults aged 1839. These sample weights were used in every
Table 1 (continued)
NFSS variables Range Mean SD N
$150,001200,000 0, 1 0.01 0.11 2988
Above $200,000 0, 1 0.01 0.10 2988
Do not know/missing 0, 1 0.22 0.42 2988
760 M. Regnerus / Social Science Research 41 (2012) 752770
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 15 of 153 Pg ID 1054
statistical procedure displayed herein unless otherwise noted. The regression models exhibited few (N < 15) missing values
on the covariates.
This broad overview approach, appropriate for introducing a new dataset, provides a foundation for future, more focused
analyses of the outcomes I explore here. There are, after all, far more ways to delineate family structure and experiences
and changes thereinthan I have undertaken here. Others will evaluate such groupings differently, and will construct alter-
native approaches of testing for group differences in what is admittedly a wide diversity of outcome measures.
I would be remiss to claim causation here, since to document that having particular family-of-origin experiencesor the
sexual relationships of ones parentscauses outcomes for adult children, I would need to not only document that there is a
correlation between such family-of-origin experiences, but that no other plausible factors could be the common cause of any
suboptimal outcomes. Rather, my analytic intention is far more modest than that: to evaluate the presence of simple group
differences, andwith the addition of several control variablesto assess just how robust such group differences are.
3. Results
3.1. Comparisons with still-intact, biological families (IBFs)
Table 2 displays mean scores on 15 dichotomous outcome variables which can be read as simple percentages, sorted by
the eight different family structure/experience groups described earlier. As in Tables 3 and 4, numbers that appear in bold
indicate that the groups estimate is statistically different from the young-adult children of IBFs, as discerned by a basic
T-test (p < 0.05). Numbers that appear with an asterisk (

) beside it indicate that the groups dichotomous variable estimate


from a logistic regression model (not shown) is statistically-signicantly different from IBFs, after controlling for respon-
dents age, gender, race/ethnicity, level of mothers education, perceived family-of-origins income, experience with having
been bullied as a youth, and the gay friendliness of the respondents current state of residence.
At a glance, the number of statistically-signicant differences between respondents from IBFs and respondents from the
other seven types of family structures/experiences is considerable, and in the vast majority of cases the optimal outcome
where one can be readily discernedfavors IBFs. Table 2 reveals 10 (out of 15 possible) statistically-signicant differences in
simple t-tests between IBFs and LMs (the pool of respondents who reported that their mother has had a lesbian relationship),
one higher than the number of simple differences (9) between IBFs and respondents from both single-parent and stepfam-
ilies. All but one of those associations is signicant in logistic regression analyses contrasting LMs and IBFs (the omitted
category).
Beginning at the top of Table 2, the marriage rates of LMs and GFs (those who reported that their father had a gay rela-
tionship) are statistically comparable to IBFs, while LMs cohabitation rate is notable higher than IBFs (24% vs. 9%, respec-
tively). Sixty-nine (69) percent of LMs and 57% of GFs reported that their family received public assistance at some point
while growing up, compared with 17% of IBFs; 38% of LMs said they are currently receiving some form of public assistance,
compared with 10% of IBFs. Just under half of all IBFs reported being employed full-time at present, compared with 26% of
Table 2
Mean scores on select dichotomous outcome variables, NFSS (can read as percentage: as in, 0.42 = 42%).
IBF (intact
bio family)
LM
(lesbian mother)
GF
(gay father)
Adopted by
strangers
Divorced
late (>18)
Stepfamily Single-
parent
All
other
Currently married 0.43 0.36 0.35 0.41 0.36

0.41 0.37 0.39


Currently cohabiting 0.09 0.24

0.21 0.07
^
0.31

0.19

0.19

0.13
Family received welfare growing up 0.17 0.69

0.57

0.12
^
0.47
^
0.53
^
0.48
^
0.35
^
Currently on public assistance 0.10 0.38

0.23 0.27

0.31

0.30

0.30

0.23

Currently employed full-time 0.49 0.26

0.34 0.41 0.42 0.47


^
0.43
^
0.39
Currently unemployed 0.08 0.28

0.20 0.22

0.15 0.14 0.13


^
0.15
Voted in last presidential election 0.57 0.41 0.73
^
0.58 0.63
^
0.57
^
0.51 0.48
Thought recently about suicide 0.05 0.12 0.24

0.07 0.08 0.10 0.05 0.09


Recently or currently in therapy 0.08 0.19

0.19 0.22

0.12 0.17

0.13

0.09
Identies as entirely heterosexual 0.90 0.61

0.71

0.82
^
0.83
^
0.81
^
0.83
^
0.82
^
Is in a same-sex romantic relationship 0.04 0.07 0.12 0.23 0.05 0.13

0.03 0.02
Had affair while married/cohabiting 0.13 0.40

0.25 0.20 0.12


^
0.32

0.19
^
0.16
^
Has ever had an STI 0.08 0.20

0.25

0.16 0.12 0.16

0.14

0.08
Ever touched sexually by parent/adult 0.02 0.23

0.06
^
0.03
^
0.10

0.12

0.10

0.08
^
Ever forced to have sex against will 0.08 0.31

0.25

0.23

0.24

0.16

0.16
^
0.11
^
Bold indicates the mean scores displayed are statistically-signicantly different from IBFs (currently intact, bio mother/father household, column 1),
without additional controls.
An asterisk (

) next to the estimate indicates a statistically-signicant difference (p < 0.05) between the groups coefcient and that of IBFs, controlling for
respondents age, gender, race/ethnicity, level of mothers education, perceived household income while growing up, experience being bullied as a youth,
and states legislative gay-friendliness, derived from logistic regression models (not shown).
A caret (^) next to the estimate indicates a statistically-signicant difference (p < 0.05) between the groups mean and the mean of LM (column 2), without
additional controls.
M. Regnerus / Social Science Research 41 (2012) 752770 761
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 16 of 153 Pg ID 1055
LMs. While only 8% of IBF respondents said they were currently unemployed, 28% of LM respondents said the same. LMs
were statistically less likely than IBFs to have voted in the 2008 presidential election (41% vs. 57%), and more than twice
as likely19% vs. 8%to report being currently (or within the past year) in counseling or therapy for a problem connected
with anxiety, depression, relationships, etc., an outcome that was signicantly different after including control variables.
In concurrence with several studies of late, the NFSS reveals that the children of lesbian mothers seem more open to
same-sex relationships (Biblarz and Stacey, 2010; Gartrell et al., 2011a,b; Golombok et al., 1997). Although they are not sta-
tistically different from most other groups in having a same-sex relationship at present, they are much less apt to identify
entirely as heterosexual (61% vs. 90% of respondents from IBFs). The same was true of GF respondentsthose young adults
who said their father had a relationship with another man: 71% of them identied entirely as heterosexual. Other sexual dif-
ferences are notable among LMs, too: a greater share of daughters of lesbian mothers report being not sexually attracted to
either males or females than among any other family-structure groups evaluated here (4.1% of female LMs, compared to
0.5% of female IBFs, not shown in Table 2). Exactly why the young-adult children of lesbian mothers are more apt to expe-
rience same-sex attraction and behaviors, as well as self-report asexuality, is not clear, but the fact that they do seems con-
sistent across studies. Given that lower rates of heterosexuality characterize other family structure/experience types in the
Table 3
Mean scores on select continuous outcome variables, NFSS.
IBF (intact
bio family)
LM (lesbian
mother)
GF (gay
father)
Adopted by
strangers
Divorced
late (>18)
Stepfamily Single- parent All
other
Educational attainment 3.19 2.39

2.64

3.21
^
2.88
^
2.64

2.66

2.54

Family-of-origin safety/security 4.13 3.12

3.25

3.77
^
3.52

3.52
^
3.58
^
3.77
^
Family-of-origin negative impact 2.30 3.13

2.90

2.83

2.96

2.76

2.78

2.64
^
Closeness to biological mother 4.17 4.05 3.71

3.58 3.95 4.03 3.85

3.97
Closeness to biological father 3.87 3.16 3.43 3.29

3.65 3.24

3.61
Self-reported physical health 3.75 3.38 3.58 3.53 3.46 3.49 3.43

3.41
Self-reported overall happiness 4.16 3.89 3.72 3.92 4.02 3.87

3.93 3.83
CES-D depression index 1.83 2.20

2.18

1.95 2.01 1.91


^
1.89
^
1.94
^
Attachment scale (depend) 2.82 3.43

3.14 3.12

3.08
^
3.10
^
3.05
^
3.02
^
Attachment scale (anxiety) 2.46 2.67 2.66 2.66 2.71 2.53 2.51 2.56
Impulsivity scale 1.90 2.03 2.02 1.85 1.94 1.86
^
1.82
^
1.89
Level of household income 8.27 6.08 7.15 7.93
^
7.42
^
7.04 6.96 6.19

Current relationship quality index 4.11 3.83 3.63

3.79 3.95 3.80

3.95 3.94
Current relationship is in trouble 2.04 2.35 2.55

2.35 2.43 2.35

2.26

2.15
Bold indicates the mean scores displayed are statistically-signicantly different from IBFs (currently intact, bio mother/father household, column 1),
without additional controls.
An asterisk (

) next to the estimate indicates a statistically-signicant difference (p < 0.05) between the groups coefcient and that of IBFs, controlling for
respondents age, gender, race/ethnicity, level of mothers education, perceived household income while growing up, experience being bullied as a youth,
and states legislative gay-friendliness, derived from OLS regression models (not shown).
A caret (^) next to the estimate indicates a statistically-signicant difference (p < 0.05) between the groups mean and the mean of LM (column 2), without
additional controls.
Table 4
Mean scores on select event-count outcome variables, NFSS.
IBF (intact
bio family)
LM (lesbian
mother)
GF
(gay father)
Adopted by
strangers
Divorced
late (>18)
Stepfamily Single-
parent
All
other
Frequency of marijuana use 1.32 1.84

1.61 1.33
^
2.00

1.47 1.73

1.49
Frequency of alcohol use 2.70 2.37 2.70 2.74 2.55 2.50 2.66 2.44
Frequency of drinking to get drunk 1.68 1.77 2.14 1.73 1.90 1.68 1.74 1.64
Frequency of smoking 1.79 2.76

2.61

2.34

2.44

2.31

2.18

1.91
^
Frequency of watching TV 3.01 3.70

3.49 3.31 3.33 3.43

3.25 2.95
^
Frequency of having been arrested 1.18 1.68

1.75

1.31
^
1.38 1.38
^
1.35
^
1.34
^
Frequency pled guilty to non-minor offense 1.10 1.36

1.41

1.19 1.30 1.21

1.17
^
1.17
^
N of female sex partners (among women) 0.22 1.04

1.47

0.47
^
0.96

0.47
^
0.52
^
0.33
^
N of female sex partners (among men) 2.70 3.46 4.17 3.24 3.66 3.85

3.23 3.37
N of male sex partners (among women) 2.79 4.02

5.92

3.49 3.97

4.57

4.04

2.91
^
N of male sex partners (among men) 0.20 1.48

1.47

0.27 0.98

0.55 0.42 0.44


Bold indicates the mean scores displayed are statistically-signicantly different from IBFs (currently intact, bio mother/father household, column 1),
without additional controls.
An asterisk (

) next to the estimate indicates a statistically-signicant difference (p < 0.05) between the groups coefcient and that of IBFs, controlling for
respondents age, gender, race/ethnicity, level of mothers education, perceived household income while growing up, experience being bullied as a youth,
and states legislative gay-friendliness, derived from Poisson or negative binomial regression models (not shown).
A caret (^) next to the estimate indicates a statistically-signicant difference (p < 0.05) between the groups mean and the mean of LM (column 2), without
additional controls.
762 M. Regnerus / Social Science Research 41 (2012) 752770
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 17 of 153 Pg ID 1056
NFSS, as Table 2 clearly documents, the answer is likely located not simply in parental sexual orientation but in successful
cross-sex relationship role modeling, or its absence or scarcity.
Sexual conduct within their romantic relationships is also distinctive: while 13% of IBFs reported having had a sexual rela-
tionship with someone else while they were either married or cohabiting, 40% of LMs said the same. In contrast to Gartrell
et al.s (2011a,b) recent, widely-disseminated conclusions about the absence of sexual victimization in the NLLFS data, 23% of
LMs said yes when asked whether a parent or other adult caregiver ever touched you in a sexual way, forced you to touch
him or her in a sexual way, or forced you to have sexual relations, while only 2% of IBFs responded afrmatively. Since such
reports are more common among women than men, I split the analyses by gender (not shown). Among female respondents,
3% of IBFs reported parental (or adult caregiver) sexual contact/victimization, dramatically below the 31% of LMs who re-
ported the same. Just under 10% of female GFs responded afrmatively to the question, an estimate not signicantly different
from the IBFs.
It is entirely plausible, however, that sexual victimization could have been at the hands of the LM respondents biological
father, prompting the mother to leave the union andat some point in the futurecommence a same-sex relationship. Ancil-
lary (unweighted) analyses of the NFSS, which asked respondents how old they were when the rst incident occurred (and
can be compared to the household structure calendar, which documents who lived in their household each year up until age
18) reveal this possibility, up to a point: 33% of those LM respondents who said they had been sexually victimized by a parent
or adult caregiver reported that they were also living with their biological father in the year that the rst incident occurred.
Another 29% of victimized LMs reported never having lived with their biological father at all. Just under 34% of LM respon-
dents who said they had at some point lived with their mothers same-sex partner reported a rst-time incident at an age
that was equal to or higher than when they rst lived with their mothers partner. Approximately 13% of victimized LMs
reported living with a foster parent the year when the rst incident occurred. In other words, there is no obvious trend
to the timing of rst victimization and when the respondent may have lived with their biological father or their mothers
same-sex partner, nor are we suggesting by whom the respondent was most likely victimized. Future exploration of the
NFSSs detailed household structure calendar offers some possibility for clarication.
The elevated LM estimate of sexual victimization is not the only estimate of increased victimization. Another more gen-
eral question about forced sex, Have you ever been physically forced to have any type of sexual activity against your will
also displays signicant differences between IBFs and LMs (and GFs). The question about forced sex was asked before the
question about sexual contact with a parent or other adult and may include incidents of it but, by the numbers, clearly in-
cludes additional circumstances. Thirty-one percent of LMs indicated they had, at some point in their life, been forced to
have sex against their will, compared with 8% of IBFs and 25% of GFs. Among female respondents, 14% of IBFs reported forced
sex, compared with 46% of LMs and 52% of GFs (both of the latter estimates are statistically-signicantly different from that
reported by IBFs).
While I have so far noted several distinctions between IBFs and GFsrespondents who said their father had a gay rela-
tionshipthere are simply fewer statistically-signicant distinctions to note between IBFs and GFs than between IBFs and
LMs, which may or may not be due in part to the smaller sample of respondents with gay fathers in the NFSS, and the much
smaller likelihood of having lived with their gay father while he was in a same-sex relationship. Only six of 15 measures in
Table 2 reveal statistically-signicant differences in the regression models (but only one in a bivariate environment). After
including controls, the children of a gay father were statistically more apt (than IBFs) to receive public assistance while grow-
ing up, to have voted in the last election, to have thought recently about committing suicide, to ever report a sexually-trans-
mitted infection, have experienced forced sex, and were less likely to self-identify as entirely heterosexual. While other
outcomes reported by GFs often differed from IBFs, statistically-signicant differences were not as regularly detected.
Although my attention has been primarily directed at the inter-group differences between IBFs, LMs, and GFs, it is worth
noting that LMs are hardly alone in displaying numerous differences with IBFs. Respondents who lived in stepfamilies or sin-
gle-parent families displayed nine simple differences in Table 2. Besides GFs, adopted respondents displayed the fewest sim-
ple differences (three).
Table 3 displays mean scores on 14 continuous outcomes. As in Table 2, bold indicates simple statistically-signicant out-
come differences with young-adult respondents from still-intact, biological families (IBFs) and an asterisk indicates a regres-
sion coefcient (models not shown) that is signicantly different from IBFs after a series of controls. Consistent with Table 2,
eight of the estimates for LMs are statistically different from IBFs. Five of the eight differences are signicant as regression
estimates. The young-adult children of women who have had a lesbian relationship fare worse on educational attainment,
family-of-origin safety/security, negative impact of family-of-origin, the CES-D (depression) index, one of two attachment
scales, report worse physical health, smaller household incomes than do respondents from still-intact biological families,
and think that their current romantic relationship is in trouble more frequently.
The young-adult GF respondents were likewise statistically distinct from IBF respondents on seven of 14 continuous out-
comes, all of which were signicantly different when evaluated in regression models. When contrasted with IBFs, GFs re-
ported more modest educational attainment, worse scores on the family-of-origin safety/security and negative impact
indexes, less closeness to their biological mother, greater depression, a lower score on the current (romantic) relationship
quality index, and think their current romantic relationship is in trouble more frequently.
As in Table 2, respondents who reported living in stepfamilies or in single-parent households also exhibit numerous sim-
ple statistical differences from IBFson nine and 10 out of 14 outcomes, respectivelymost of which remain signicant in
M. Regnerus / Social Science Research 41 (2012) 752770 763
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 18 of 153 Pg ID 1057
the regression models. On only four of 14 outcomes do adopted respondents appear distinctive (three of which remain sig-
nicant after introducing controls).
Table 4 displays mean scores on nine event counts, sorted by the eight family structure/experience groups. The NFSS
asked all respondents about experience with male and female sexual partners, but I report them here separately by gender.
LM respondents report statistically greater marijuana use, more frequent smoking, watch television more often, have been
arrested more, pled guilty to non-minor offenses more, andamong womenreport greater numbers of both female and
male sex partners than do IBF respondents. Female LMs reported an average of just over one female sex partner in their life-
times, as well as four male sex partners, in contrast to female IBFs (0.22 and 2.79, respectively). Male LMs report an average
of 3.46 female sex partners and 1.48 male partners, compared with 2.70 and 0.20, respectively, among male IBFs. Only the
number of male partners among men, however, displays signicant differences (after controls are included).
Among GFs, only three bivariate distinctions appear. However, six distinctions emerge after regression controls: they are
more apt than IBFs to smoke, have been arrested, pled guilty to non-minor offenses, and report more numerous sex partners
(except for the number of female sex partners among male GFs). Adopted respondents display no simple differences from
IBFs, while the children of stepfamilies and single parents each display six signicant differences with young adults from
still-intact, biological mother/father families.
Although I have paid much less attention to most of the other groups whose estimates also appear in Tables 24, it is
worth noting how seldom the estimates of young-adult children who were adopted by strangers (before age 2) differ statis-
tically from the children of still-intact biological families. They display the fewest simple signicant differencesseven
across the 40 outcomes evaluated here. Given that such adoptions are typically the result of considerable self-selection, it
should not surprise that they display fewer differences with IBFs.
To summarize, then, in 25 of 40 outcomes, there are simple statistically-signicant differences between IBFs and LMs,
those whose mothers had a same-sex relationship. After controls, there are 24 such differences. There are 24 simple differ-
ences between IBFs and stepfamilies, and 24 statistically-signicant differences after controls. Among single (heterosexual)
parents, there are 25 simple differences before controls and 21 after controls. Between GFs and IBFs, there are 11 and 19 such
differences, respectively.
3.2. Summary of differences between LMs and other family structures/experiences
Researchers sometimes elect to evaluate the outcomes of children of gay and lesbian parents by comparing them not di-
rectly to stable heterosexual marriages but to other types of households, since it is often the caseand it is certainly true of
the NFSSthat a gay or lesbian parent rst formed a heterosexual union prior to coming out of the closet, and witnessing
the dissolution of that union (Tasker, 2005). So comparing the children of such parents with those who experienced no union
dissolution is arguably unfair. The NFSS, however, enables researchers to compare outcomes across a variety of other types of
family-structural history. While I will not explore in-depth here all the statistically-signicant differences between LMs, GFs,
and other groups besides IBFs, a few overall observations are merited.
Of the 239 possible between-group differences herenot counting those differences with Group 1 (IBFs) already de-
scribed earlierthe young-adult children of lesbian mothers display 57 (or 24% of total possible) that are signicant at
the p < 0.05 level (indicated in Tables 24 with a caret), and 44 (or 18% of total) that are signicant after controls (not
shown). The majority of these differences are in suboptimal directions, meaning that LMs display worse outcomes. The
young-adult children of gay men, on the other hand, display only 11 (or 5% of total possible) between-group differences
that are statistically signicant at the p < 0.05 level, and yet 24 (or 10% of total) that are signicant after controls (not
shown).
In the NFSS, then, the young-adult children of a mother who has had a lesbian relationship display more signicant
distinctions with other respondents than do the children of a gay father. This may be the result of genuinely different
experiences of their family transitions, the smaller sample size of children of gay men, or the comparatively-rarer expe-
rience of living with a gay father (only 42% of such respondents reported ever living with their father while he was in a
same-sex relationship, compared with 91% who reported living with their mother while she was in a same-sex
relationship).
4. Discussion
Just how different are the adult children of men and women who pursue same-sex romantic (i.e., gay and lesbian)
relationships, when evaluated using population-based estimates from a random sample? The answer, as might be expected,
depends on to whom you compare them. When compared with children who grew up in biologically (still) intact, mother
father families, the children of women who reported a same-sex relationship look markedly different on numerous out-
comes, including many that are obviously suboptimal (such as education, depression, employment status, or marijuana
use). On 25 of 40 outcomes (or 63%) evaluated here, there are bivariate statistically-signicant (p < 0.05) differences between
children from still-intact, mother/father families and those whose mother reported a lesbian relationship. On 11 of 40 out-
comes (or 28%) evaluated here, there are bivariate statistically-signicant (p < 0.05) differences between children from
still-intact, mother/father families and those whose father reported a gay relationship. Hence, there are differences in both
764 M. Regnerus / Social Science Research 41 (2012) 752770
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 19 of 153 Pg ID 1058
comparisons, but there are many more differences by any method of analysis in comparisons between young-adult children
of IBFs and LMs than between IBFs and GFs.
While the NFSS may best capture what might be called an earlier generation of children of same-sex parents, and in-
cludes among them many who witnessed a failed heterosexual union, the basic statistical comparisons between this group
and those of others, especially biologically-intact, mother/father families, suggests that notable differences on many out-
comes do in fact exist. This is inconsistent with claims of no differences generated by studies that have commonly em-
ployed far more narrow samples than this one.
Goldberg (2010) aptly asserts that many existing studies were conducted primarily comparing children of heterosexual
divorced and lesbian divorced mothers, potentially leading observers to erroneously attribute to parental sexual orientation
the corrosive effects of enduring parental divorce. Her warning is well-taken, and it is one that the NFSS cannot entirely
mitigate. Yet when compared with other young adults who experienced household transitions and who witnessed parents
forming new romantic relationshipsfor example, stepfamiliesthe children of lesbian mothers looked (statistically) signif-
icantly different just under 25% of the time (and typically in suboptimal directions). Nevertheless, the children of mothers
who have had same-sex relationships are far less apt to differ from stepfamilies and single parents than they are from
still-intact biological families.
Why the divergence between the ndings in this study and those from so many previous ones? The answer lies in part
with the small or nonprobability samples so often relied upon in nearly all previous studiesthey have very likely underes-
timated the number and magnitude of real differences between the children of lesbian mothers (and to a lesser extent, gay
fathers) and those raised in other types of households. While the architects of such studies have commonly and appropri-
ately acknowledged their limitations, practicallysince they are often the only studies being conductedtheir results are
treated as providing information about gay and lesbian household experiences in general. But this study, based on a rare large
probability sample, reveals far greater diversity in the experience of lesbian motherhood (and to a lesser extent, gay father-
hood) than has been acknowledged or understood.
Given that the characteristics of the NFSSs sample of children of LMs and GFs are close to estimates of the same offered by
demographers using the American Community Study, one conclusion from the analyses herein is merited: the sample-selec-
tion bias problem in very many studies of gay and lesbian parenting is not incidental, but likely profound, rendering the abil-
ity of much past research to offer valid interpretations of average household experiences of children with a lesbian or gay
parent suspect at best. Most snowball-sample-based research has, instead, shed light on above-average household
experiences.
While studies of family structure often locate at least modest benets that accrue to the children of married biological
parents, some scholars attribute much of the benet to socioeconomic-status differences between married parents and those
parents in other types of relationships (Biblarz and Raftery, 1999). While this is likely true of the NFSS as well, the results
presented herein controlled not only for socioeconomic status differences between families of origin, but also political-geo-
graphic distinctions, age, gender, race/ethnicity, and the experience of having been bullied (which was reported by 53% of
LMs but only 35% of IBFs).
To be sure, those NFSS respondents who reported that a parent of theirs had had a romantic relationship with a member
of the same sex are a very diverse group: some experienced numerous household transitions, and some did not. Some of their
parents may have remained in a same-sex relationship, while others did not. Some may self-identify as lesbian or gay, while
others may not. I did not explore in detail the diversity of household experiences here, given the overview nature of this
study. But the richness of the NFSSwhich has annual calendar data for household transitions from birth to age 18 and from
age 18 to the presentallows for closer examination of many of these questions.
Nevertheless, to claim that there are few meaningful statistical differences between the different groups evaluated here
would be to state something that is empirically inaccurate. Minimally, the population-based estimates presented here sug-
gest that a good deal more attention must be paid to the real diversity among gay and lesbian parent experiences in America,
just as it long has been among heterosexual households. Child outcomes in stable, planned GLB families and those that are
the product of previous heterosexual unions are quite likely distinctive, as previous studies conclusions would suggest. Yet
as demographers of gay and lesbian America continue to noteand as the NFSS reinforcesplanned GLB households only
comprise a portion (and an unknown one at that) of all GLB households with children.
Even if the children in planned GLB families exhibit better outcomes than those from failed heterosexual unions, the for-
mer still exhibits a diminished context of kin altruism (like adoption, step-parenting, or nonmarital childbirth), which have
typically proven to be a risk setting, on average, for raising children when compared with married, biological parenting (Mill-
er et al., 2000). In short, if same-sex parents are able to raise children with no differences, despite the kin distinctions, it
would mean that same-sex couples are able to do something that heterosexual couples in step-parenting, adoptive, and
cohabiting contexts have themselves not been able to doreplicate the optimal childrearing environment of married, bio-
logical-parent homes (Moore et al., 2002). And studies focusing on parental roles or household divisions of labor in planned
GLB families will fail to revealbecause they have not measured ithow their children fare as adults.
The between-group comparisons described above also suggest that those respondents with a lesbian mother and those
with a gay father do not always exhibit comparable outcomes in young adulthood. While the sample size of gay fathers
in the NFSS was modest, any monolithic ideas about same-sex parenting experiences in general are not supported by these
analyses.
M. Regnerus / Social Science Research 41 (2012) 752770 765
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 20 of 153 Pg ID 1059
Although the NFSS offers strong support for the notion that there are signicant differences among young adults that cor-
respond closely to the parental behavior, family structures, and household experiences during their youth, I have not and will
not speculate here on causality, in part because the data are not optimally designed to do so, and because the causal
reckoning for so many different types of outcomes is well beyond what an overview manuscript like this one could ever pur-
port to accomplish. Focused (and more complex) analyses of unique outcomes, drawing upon idiosyncratic, domain-specic
conceptual models, is recommended for scholars who wish to more closely assess the functions that the number, gender, and
sexual decision-making of parents may play in young adults lives. I am thus not suggesting that growing up with a lesbian
mother or gay father causes suboptimal outcomes because of the sexual orientation or sexual behavior of the parent; rather,
my point is more modest: the groups display numerous, notable distinctions, especially when compared with young adults
whose biological mother and father remain married.
There is more that this article does not accomplish, including closer examinations of subpopulations, consideration
of more outcomes and comparisons between other groups, and stronger tests of statistical signicancesuch as multiple
regression with more numerous independent variables, or propensity score matching. That is what the NFSS is designed
to foster. This article serves as a call for such study, as well as an introduction to the data and to its sampling and measure-
ment strengths and abilities. Future studies would optimally include a more signicant share of children from planned gay
families, although their relative scarcity in the NFSS suggests that their appearance in even much larger probability samples
will remain infrequent for the foreseeable future. The NFSS, despite signicant efforts to randomly over-sample such popu-
lations, nevertheless was more apt to survey children whose parents exhibited gay and lesbian relationship behavior after
being in a heterosexual union. This pattern may remain more common today than many scholars suppose.
5. Conclusion
As scholars of same-sex parenting aptly note, same-sex couples have and will continue to raise children. American courts
are nding arguments against gay marriage decreasingly persuasive (Rosenfeld, 2007). This study is intended to neither
undermine nor afrm any legal rights concerning such. The tenor of the last 10 years of academic discourse about gay
and lesbian parents suggests that there is little to nothing about them that might be negatively associated with child devel-
opment, and a variety of things that might be uniquely positive. The results of analyzing a rare large probability sample re-
ported herein, however, document numerous, consistent differences among young adults who reported maternal lesbian
behavior (and to a lesser extent, paternal gay behavior) prior to age 18. While previous studies suggest that children in
planned GLB families seem to fare comparatively well, their actual representativeness among all GLB families in the US
may be more modest than research based on convenience samples has presumed.
Although the ndings reported herein may be explicable in part by a variety of forces uniquely problematic for child
development in lesbian and gay familiesincluding a lack of social support for parents, stress exposure resulting from per-
sistent stigma, and modest or absent legal security for their parental and romantic relationship statusesthe empirical claim
that no notable differences exist must go. While it is certainly accurate to afrm that sexual orientation or parental sexual
behavior need have nothing to do with the ability to be a good, effective parent, the data evaluated herein using population-
based estimates drawn froma large, nationally-representative sample of young Americans suggest that it may affect the real-
ity of family experiences among a signicant number.
Do children need a married mother and father to turn out well as adults? No, if we observe the many anecdotal accounts
with which all Americans are familiar. Moreover, there are many cases in the NFSS where respondents have proven resilient
and prevailed as adults in spite of numerous transitions, be they death, divorce, additional or diverse romantic partners, or
remarriage. But the NFSS also clearly reveals that children appear most apt to succeed well as adultson multiple counts and
across a variety of domainswhen they spend their entire childhood with their married mother and father, and especially
when the parents remain married to the present day. Insofar as the share of intact, biological mother/father families contin-
ues to shrink in the United States, as it has, this portends growing challenges within families, but also heightened depen-
dence on public health organizations, federal and state public assistance, psychotherapeutic resources, substance use
programs, and the criminal justice system.
Appendix A. Comparison of weighted NFSS results with parallel national survey results on selected demographic and
lifestyle variables, US adults (in percentages)
NFSS 2011,
N = 941
(1823)
NSYR
20072008,
N = 2520
(1823)
NFSS 2011,
N = 1123
(2432)
Add Health
20072008,
N = 15,701
(2432)
NFSS 2011,
N = 2988
(1839)
NSFG
20062010,
N = 16,851
(1839)
CPS ASEC
2011,
N = 58,788
(1839)
Gender
Male 52.6 48.3 47.3 50.6 49.4 49.8 50.4
Female 47.4 51.7 52.8 49.4 50.6 50.2 49.6
766 M. Regnerus / Social Science Research 41 (2012) 752770
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 21 of 153 Pg ID 1060
Appendix A (continued)
NFSS 2011,
N = 941
(1823)
NSYR
20072008,
N = 2520
(1823)
NFSS 2011,
N = 1123
(2432)
Add Health
20072008,
N = 15,701
(2432)
NFSS 2011,
N = 2988
(1839)
NSFG
20062010,
N = 16,851
(1839)
CPS ASEC
2011,
N = 58,788
(1839)
Age
1823 28.9 28.6 28.2
2432 41.2 40.6 42.1
3339 29.9 30.9 29.8
Race/ethnicity
White, NH 54.2 68.3 60.2 69.2 57.7 61.6 59.6
Black, NH 11.0 15.0 13.0 15.9 12.6 13.3 13.2
Hispanic 24.9 11.2 20.7 10.8 20.8 18.6 19.5
Other (or multiple),
NH
10.0 5.5 6.2 4.2 8.9 6.5 7.8
Region
Northeast 18.9 11.8 16.5 17.6 17.5
Midwest 18.7 25.6 23.3 21.1 21.2
South 34.3 39.1 39.6 36.7 37.0
West 28.2 23.5 20.6 24.6 24.4
Mothers education
(BA or above)
28.4 33.3 24.6 21.9 25.3 22.2
Respondents education
(BA or above)
5.3 3.8 33.7 30.0 26.5 24.2
Household income
(current)
Under $10,000 21.0 9.7 5.6 11.9 9.5 5.7
$10,00019,999 13.3 9.1 6.9 9.2 13.1 7.4
$20,00029,999 11.6 10.3 10.1 10.5 13.5 9.5
$30,00039,999 8.0 11.0 11.1 9.6 13.4 9.4
$40,00049,999 6.5 12.8 11.8 9.9 8.5 9.1
$50,00074,999 14.9 22.3 24.3 19.2 19.5 20.3
$75,000 or more 24.7 24.9 30.2 29.8 22.7 38.6
Ever had sex 66.5 75.6 90.6 93.9 85.6 91.2
Never been married 89.3 92.8 45.7 50.0 51.7 52.3 54.4
Currently married 8.0 6.9 44.9 44.6 40.6 39.2 37.9
Church attendance
Once a week or more 18.4 20.2 22.1 16.0 22.3 26.2
Never 32.3 35.6 31.2 32.1 31.7 25.8
Not religious 21.1 24.7 22.5 20.2 22.0 21.7
Self-reported health
Poor 1.8 1.5 1.0 1.2 1.5 0.7
Fair 8.4 9.2 11.0 7.9 10.7 5.3
Good 28.7 26.7 37.6 33.5 33.9 24.9
Very Good 39.6 37.5 35.7 38.2 37.3 40.9
Excellent 21.5 25.2 14.8 19.1 16.7 28.3
Never drinks alcohol 30.5 21.9 22.4 26.1 25.4 18.7
M. Regnerus / Social Science Research 41 (2012) 752770 767
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 22 of 153 Pg ID 1061
Appendix B. Construction of outcome indexes
B.1. CES-D (depression) index (8 items, a = 0.87)
Respondents were asked to think about the past 7 days, and assess howoften each of the following things were true about
them. Answer categories ranged from never or rarely (0) to most of the time or all of the time (3). Some items were re-
verse-coded for the index variable (e.g., You felt happy.):
1. You were bothered by things that usually do not bother you.
2. You could not shake off the blues, even with help from your family and your friends.
3. You felt you were just as good as other people.
4. You had trouble keeping your mind on what you were doing.
5. You felt depressed.
6. You felt happy.
7. You enjoyed life.
8. You felt sad.
B.2. Current romantic relationship quality (6 items, a = 0.96)
Respondents were asked to assess their current romantic relationship. Answer categories ranged from strongly disagree
(1) to strongly agree (5):
1. We have a good relationship.
2. My relationship with my partner is very healthy.
3. Our relationship is strong.
4. My relationship with my partner makes me happy.
5. I really feel like part of a team with my partner.
6. Our relationship is pretty much perfect.
B.3. Family-of-origin relationship safety/security (4 items, a = 0.90)
Respondents were asked to evaluate the overall atmosphere in their family while growing up by responding to four state-
ments whose answer categories ranged from strongly disagree (1) to strongly agree (5):
1. My family relationships were safe, secure, and a source of comfort.
2. We had a loving atmosphere in our family.
3. All things considered, my childhood years were happy.
4. My family relationships were confusing, inconsistent, and unpredictable.
B.4. Family-of-origin negative impact (3 items, a = 0.74)
Respondents were asked to evaluate the present-day impact of their family-of-origin experiences by responding to three
statements whose answer categories ranged from strongly disagree (1) to strongly agree (5):
1. There are matters from my family experience that I am still having trouble dealing with or coming to terms with.
2. There are matters from my family experience that negatively affect my ability to form close relationships.
3. I feel at peace about anything negative that happened to me in the family in which I grew up.
B.5. Impulsivity (4 items, a = 0.76)
Respondents were asked to respond to four statements about their decision-making, especially as it concerns risk-taking
and new experiences. Answer categories ranged from 1 (never or rarely) to 4 (most or all of the time):
1. When making a decision, I go with my gut feeling and do not think much about the consequences of each
alternative.
2. I like new and exciting experiences, even if I have to break the rules.
3. I am an impulsive person.
4. I like to take risks.
768 M. Regnerus / Social Science Research 41 (2012) 752770
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 23 of 153 Pg ID 1062
B.6. Closeness to biological mother and father (6 items, a = 0.89 and 0.92)
Respondents were asked to evaluate their current relationship with up to four parent gureswho they reported living
with for at least 3 years when they were 018 years oldby reporting the frequency of six parentchild interactions. For each
parent gure, these six items were coded and summed into a parental closeness index. From these, I derived indices of close-
ness to the respondents biological mother and biological father. Response categories ranged from never (1) to always (5):
1. How often do you talk openly with your parent about things that are important to you?
2. How often does your parent really listen to you when you want to talk?
3. How often does your parent explicitly express affection or love for you?
4. Would your parent help you if you had a problem?
5. If you needed money, would you ask your parent for it?
6. How often is your parent interested in the things you do?
B.7. Attachment (depend, 6 items, a = 0.80; anxiety, 6 items, a = 0.82)
For a pair of attachment measures, respondents were asked to rate their general feelings about romantic relationships,
both past and present, in response to 12 items. Response categories ranged from not at all characteristic of me (1) to very
characteristic of me (5). Items 16 were coded and summed into a depend scale, with higher scores denoting greater com-
fort with depending upon others. Items 712 were coded and summed into an anxiety scale, with higher scores denoting
greater anxiety in close relationships, in keeping with the original Adult Attachment Scale developed by Collins and Read
(1990). The measures employed were:
1. I nd it difcult to allow myself to depend on others.
2. I am comfortable depending on others.
3. I nd that people are never there when you need them.
4. I know that people will be there when I need them.
5. I nd it difcult to trust others completely.
6. I am not sure that I can always depend on others to be there when I need them.
7. I do not worry about being abandoned.
8. In relationships, I often worry that my partner does not really love me.
9. I nd that others are reluctant to get as close as I would like.
10. In relationships, I often worry that my partner will not want to stay with me.
11. I want to merge completely with another person.
12. My desire to merge sometimes scares people away.
References
Anderssen, Norman, Amlie, Christine, Erling, Ytteroy A., 2002. Outcomes for children with lesbian or gay parents. A review of studies from 1978 to 2000.
Scandinavian Journal of Psychology 43 (4), 335351.
Balsam, Kimberly F., Beauchaine, Theodore P., Rothblum, Esther D., Solomon, Sondra E., 2008. Three-year follow-up of same-sex couples who had civil
unions in Vermont, same-sex couples not in civil unions, and heterosexual married couples. Developmental Psychology 44, 102116.
Baumle, Amanda K., Compton, DLane R., Poston Jr., Dudley L., 2009. Same-Sex Partners: The Demography of Sexual Orientation. SUNY Press, Albany, NY.
Berg, Sven, 1988. Snowball sampling. In: Kotz, Samuel, Johnson, Norman L. (Eds.), Encyclopedia of Statistical Sciences, vol. 8. Wiley-Interscience, New York.
Biblarz, Timothy J., Raftery, Adrian E., 1999. Family structure, educational attainment, and socioeconomic success: rethinking the pathology of matriarchy.
American Journal of Sociology 105, 321365.
Biblarz, Timothy J., Stacey, Judith, 2010. How does the gender of parents matter? Journal of Marriage and Family 72 (1), 322.
Bos, Henny M.W., Sandfort, Theo G.M., 2010. Childrens gender identity in lesbian and heterosexual two-parent families. Sex Roles 62, 114126.
Bos, Henny M.W., van Balen, Frank, van den Boom, Dymphna C., 2007. Child adjustment and parenting in planned lesbian parent families. American Journal
of Orthopsychiatry 77, 3848.
Brewaeys, Anne, Ponjaert, Ingrid, Van Hall, Eylard V., Golombok, Susan, 1997. Donor insemination: child development and family functioning in lesbian
mother families. Human Reproduction 12, 13491359.
Brown, Susan L., 2004. Family structure and child well-being: the signicance of parental cohabitation. Journal of Marriage and Family 66 (2), 351367.
Busby, Dean M., Holman, Thomas B., Taniguchi, Narumi, 2001. RELATE: relationship evaluation of the individual, family, cultural, and couple contexts.
Family Relations 50, 308316.
Collins, Nancy L., Read, Stephen J., 1990. Adult attachment, working models, and relationship quality in dating couples. Journal of Personality and Social
Psychology 58, 644663.
Crowl, Alicia L., Ahn, Soyeon, Baker, Jean, 2008. A meta-analysis of developmental outcomes for children of same-sex and heterosexual parents. Journal of
GLBT Family Sciences 4 (3), 385407.
Finer, Lawrence B., Henshaw, Stanley K., 2006. Disparities in rates of unintended pregnancy in the United States, 1994 and 2001. Perspectives on Sexual and
Reproductive Health 38, 9096.
Fulcher, Megan, Sutn, Erin L., Patterson, Charlotte J., 2008. Individual differences in gender development: associations with parental sexual orientation,
attitudes, and division of labor. Sex Roles 57, 330341.
Gartrell, Nanette K., Bos, Henny M.W., 2010. US national longitudinal lesbian family study: psychological adjustment of 17-year-old adolescents. Pediatrics
126 (1), 111.
M. Regnerus / Social Science Research 41 (2012) 752770 769
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 24 of 153 Pg ID 1063
Gartrell, Nanette K., Bos, Henny M.W., Goldberg, Naomi G., 2011a. Adolescents of the U.S. national longitudinal lesbian family study: sexual orientation,
sexual behavior, and sexual risk exposure. Archives of Sexual Behavior 40, 11991209.
Gartrell, Nanette K., Bos, Henny M.W., Goldberg, Naomi G., 2011b. New trends in same-sex sexual contact for American adolescents? Archives of Sexual
Behavior. http://dx.doi.org/10.1007/s10508-011-9883-5.
Gates, Gary J., 2011. Family formation and raising children among same-sex couples. NCFR Report 56 (4), F1F3.
Gates, Gary J., Ost, Jason, 2004. The Gay and Lesbian Atlas. The Urban Institute Press, Washington, DC.
Goldberg, Abbie E., 2010. Lesbian and Gay parents and Their Children: Research on the Family Life Cycle. APA Books, Washington, DC.
Golombok, Susan, Perry, Beth, Burston, Amanda, Murray, Clare, Mooney-Somers, Julie, Stevens, Madeleine, Golding, Jean, 2003. Children with lesbian
parents: a community study. Developmental Psychology 39, 2033.
Golombok, Susan., Tasker, Fiona., Murray, Clare., 1997. Children raised in fatherless families from infancy: family relationships and the socioemotional
development of children of lesbian and single heterosexual mothers. Journal of Child Psychology and Psychiatry 38, 783792.
Hatzenbuehler, Mark L., Keyes, Katherine M., Hasin, Deborah S., 2009. State-level policies and psychiatric morbidity in lesbian, gay, and bisexual
populations. American Journal of Public Health 99 (12), 22752281.
Herbenick, Debby, Reece, Michael, Schick, Vanessa, Sanders, Stephanie A., Dodge, Brian, Fortenberry, J.Dennis, 2010. Sexual behavior in the United States:
results from a national probability sample of men and women ages 1494. Journal of Sexual Medicine 7 (Suppl. 5), 255265.
Hufngton Post: Healthy Living, 2011. Child Abuse Rate at Zero Percent in Lesbian Households, New Report Finds. The Hufngton Post. <http://
www.hufngtonpost.com/2010/11/10/lesbians-child-abuse-0-percent_n_781624.html> (accessed 01.13.12).
Times Research Reporting, 2012. Interactive: Gay Marriage Chronology. Los Angeles Times. <http://www.latimes.com/news/local/la-gmtimeline-
,0,5345296.htmlstory> (accessed 01.03.12).
MacCallum, Fiona, Golombok, Susan, 2004. Children raised in fatherless families from infancy: a follow-up of children of lesbian and single heterosexual
mothers at early adolescence. Journal of Psychology and Psychiatry 45, 14071419.
Manning, Wendy D., Smock, Pamela J., Majumdar, Debarun, 2004. The relative stability of cohabiting and marital unions for children. Population Research
and Policy Review 23, 135159.
McLanahan, Sara, Sandefur, Gary, 1994. Growing Up with a Single Parent: What Hurts, What Helps. Harvard University Press, Cambridge.
Miller, Brent C., Fan, Xitao, Christensen, Matthew, Grotevant, Harold, van Dulmen, Manfred, 2000. Comparisons of adopted and nonadopted adolescents in a
large, nationally representative sample. Child Development 71 (5), 14581473.
Moore, Kristin Anderson, Jekielek, Susan M., Emig, Carol, 2002. Marriage from a Childs Perspective: How Does Family Structure Affect Children, and What
Can We Do About It? Child Trends Research Brief, Child Trends, Washington, DC.
Movement Advancement Project, Family Equality Council and Center for American Progress, 2011. All Children Matter: How Legal and Social Inequalities
Hurt LGBT Families, Full Report.
National Center for Family and Marriage Research, 2010. Same-Sex Couple Households in the US, 2009. Family Proles, FP-10-08.
Nock, Steven L., 2001. Afdavit of Steven Nock. Halpern et al. v. Canada and MCCT v. Canada. ON S.C.D.C. <http://marriagelaw.cua.edu/Law/cases/Canada/
ontario/halpern/aff_nock.pdf> (accessed 12.20.11).
Patterson, Charlotte J., 1997. Children of lesbian and gay parents. In: Ollendick, Thomas H., Prinz, Ronald J. (Eds.), Advances in Clinical Child Psychology, vol.
19. Plenum, New York.
Patterson, Charlotte J., 2000. Family relationships of lesbians and gay men. Journal of Marriage and the Family 62, 10521069.
Patterson, Charlotte J., 2006. Children of lesbian and gay parents. Current Directions in Psychological Science 15 (5), 241244.
Perrin, Ellen C., Committee on Psychosocial Aspects of Child and Family Health, 2002. Technical report: coparent or second-parent adoption by same-sex
partners. Pediatrics 109, 341344.
Redding, Richard R., 2008. Its really about sex: same-sex marriage, lesbigay parenting, and the psychology of disgust. Duke Journal of Gender Law and Policy
16, 127193.
Resnick, Michael D., Bearman, Peter S., Blum, Robert W., Bauman, Karl E., Harris, Kathleen M., Jones, Jo, Tabor, Joyce, Beuhring, Trish, Sieving, Renee E., Shew,
Marcia, Ireland, Marjorie, Bearinger, Linda H., Udry, J.R., 1997. Protecting adolescents from harm: ndings from the national longitudinal study on
adolescent health. Journal of the American Medical Association 278 (10), 823832.
Rosenfeld, Michael, 2007. The Age of Independence: Interracial Unions, Same-Sex Unions and the Changing American Family. Harvard University Press,
Cambridge, MA.
Rosenfeld, Michael J., 2010. Nontraditional families and childhood progress through school. Demography 47, 755775.
Rostosky, Sharon Scales, Riggle, Ellen D.B., Horne, Sharon G., Miller, Angela D., 2009. Marriage amendments and psychological distress in lesbian, gay, and
bisexual (LGB) adults. Journal of Counseling Psychology 56 (1), 5666.
Sirota, Theodora, 2009. Adult attachment style dimensions in women who have gay or bisexual fathers. Archives of Psychiatric Nursing 23 (4), 289297.
Snijders, Tom A.B., 1992. Estimation on the basis of snowball samples: how to weight? Bulletin de Mthodologie Sociologique 36, 5970.
Stacey, Judith, Biblarz, Timothy J., 2001a. (How) does the sexual orientation of parents matter? American Sociological Review 66 (2), 159183.
Stacey, Judith, Biblarz, Timothy, 2001b. Afdavit of Judith Stacey and Timothy Biblarz. Halpern et al. v. Canada and MCCT v. Canada. ON S.C.D.C. <http://
www.samesexmarriage.ca/docs/stacey_biblarz.pdf> (accessed 12.20.11).
Tasker, Fiona, 2005. Lesbian mothers, gay fathers, and their children: a review. Developmental and Behavioral Pediatrics 26 (3), 224240.
Tasker, Fiona, 2010. Same-sex parenting and child development: reviewing the contribution of parental gender. Journal of Marriage and Family 72, 3540.
Tasker, Fiona L., Golombok, Susan, 1997. Growing Up in a Lesbian Family. Guilford, New York.
Vanfraussen, Katrien, Ponjaert-Kristoffersen, Ingrid, Brewaeys, Anne, 2003. Family functioning in lesbian families created by donor insemination. American
Journal of Orthopsychiatry 73 (1), 7890.
Veldorale-Brogan, Amanda, Cooley, Morgan, 2011. Child outcomes for children with LGBT parents. NCFR Report 56 (4), F15F16.
Wainright, Jennifer L., Patterson, Charlotte J., 2006. Delinquency, victimization, and substance use among adolescents with female same-sex parents. Journal
of Family Psychology 20 (3), 526530.
Wainright, Jennifer L., Russell, Stephen T., Patterson, Charlotte J., 2004. Psychosocial adjustment, school outcomes, and romantic relationships of adolescents
with same-sex parents. Child Development 75 (6), 18861898.
770 M. Regnerus / Social Science Research 41 (2012) 752770
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 25 of 153 Pg ID 1064
ATTACHMENT C

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 26 of 153 Pg ID 1065
back to Percolator
PREVIOUS
Mystery Human Ancestor Found in African
Genes
NEXT
Blasting Rock and Hunting for Martian Life
Controversial Gay-Parenting Study Is Severely Flawed,
Journals Audit Finds
July 26, 2012, 10:57 pm
By Tom Bartlett
The peer-review process failed to identify significant, disqualifying problems with a controversial and widely publicized
study that seemed to raise doubts about the parenting abilities of gay couples, according to an internal audit scheduled
to appear in the November issue of the journal, Social Science Research, that published the study.
The highly critical audit, a draft of which was provided to The Chronicle by the journals editor, also cites
conflicts of interest among the reviewers, and states that scholars who should have known better failed to
recuse themselves from the review process.
Since it was published last month, the study, titled How Different Are the Adult Children of Parents Who
Have Same-Sex Relationships?, has been the subject of numerous news articles and blog posts. It has been
used by opponents of same-sex marriage to make their case, and its been blasted by gay-rights activists as
flawed and biased.
The studys author, Mark Regnerus, an associate professor of sociology at the University of Texas at Austin,
even made the cover of The Weekly Standard. In the illustration, he is strapped to a Catherine wheel thats
being tended by masked torturers.
Like Regnerus, the editor of Social Science Research, James D. Wright, has been at the receiving end of an
outpouring of anger over the paper. At the suggestion of another scholar, Wright, a professor of sociology at
the University of Central Florida, assigned a member of the journals editorial boardDarren E. Sherkat, a
professor of sociology at Southern Illinois University at Carbondaleto examine how the paper was
handled.
Mark Regnerus
Page 1 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percolator...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 27 of 153 Pg ID 1066
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 4, 2013
Sherkat was given access to all the reviews and correspondence connected with the paper, and was told the
identities of the reviewers. According to Sherkat, Regneruss paper should never have been published. His
assessment of it, in an interview, was concise: Its bullshit, he said.
Among the problems Sherkat identified is the papers definition of lesbian mothers and gay fathersan
aspect that has been the focus of much of the public criticism. A woman could be identified as a lesbian
mother in the study if she had had a relationship with another woman at any point after having a child,
regardless of the brevity of that relationship and whether or not the two women raised the child as a couple.
Sherkat said that fact alone in the paper should have disqualified it immediately from being considered
for publication.
In his audit, he writes that the peer-review system failed because of both ideology and inattention on the part of the
reviewers (three of the six reviewers, according to Sherkat, are on record as opposing same-sex marriage). Whats more,
he writes that the reviewers were not without some connection to Regnerus, and suggests that those ties influenced
their reviews.
He declined to be more specific in an interview, saying that he was obligated to protect their identities.
Obviously, he concluded, the reviewers did not do a good job.
At the same time, he sympathizes with the task of the overburdened reviewer inclined to skim. Because of
how the paper was written, Sherkat said, it would have been easy to miss Regneruss explanation of who
qualified as lesbian mothers and gay fathers. If a reviewer were to skip ahead to the statistics in the
table, it would be understandable, he said, to assume that the children described there were, in fact, raised
by a gay or lesbian couple for a significant portion of their childhoods.
In reality, only two respondents lived with a lesbian couple for their entire childhoods, and most did not live
with lesbian or gay parents for long periods, if at all.
The information about how parents are labeled is in the paper. Regnerus writes that he chose those labels
for the sake of brevity and to avoid entanglement in interminable debates about fixed or fluid
orientations. Sherkat, however, called the presentation of the data extremely misleading. Writes Sherkat:
Reviewers uniformly downplayed or ignored the fact that the study did not examine children of
identifiably gay and lesbian parents, and none of the reviewers noticed that the marketing-research data
were inappropriate for a top-tier social-scientific journal.
He also had harsh words for an accompanying paper in the same issue by Loren D. Marks, an associate
professor of family, child, and consumer sciences at Louisiana State University at Baton Rouge. Marks
wrote a review of papers that had been published on the children of same-sex parents, taking the authors of
those papers to task for using small convenience samples that are not generalizable, among other failings.
Darren E. Sherkat
Page 2 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percolator...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 28 of 153 Pg ID 1067
Sherkat writes that the Marks paper is a lowbrow meta-analysis of studies that was inappropriate for a
journal that publishes original quantitative research. Sherkat, in an interview, said that Marks didnt
perform a true meta-analysis of the studies and instead simply wrote summaries of the results. Marks could
not be reached for comment.
That said, Sherkat did not find that the journals normal procedures had been disregarded, or that the
Regnerus paper had been inappropriately expedited to publication, as some critics have charged. He also
vigorously defended Wright, the editor. If I were in Wrights shoes, he writes, I may well have made the
same decisions.
Because the reviewers were unanimously positive, Wright had little choice but to go ahead with publication,
according to Sherkat. He goes on: My review of the editorial processing of the Regnerus and Marks papers
revealed that there were no gross violations of editorial proceduresthe papers were peer-reviewed, and
the peers for papers on this topic were similar to what you would expect at Social Science Research.
As for accusations that Wright was part of a conservative conspiracy, as some have suggested, Sherkat
deems that ludicrous.
Sherkat was an early critic of the paper, even before he was chosen to conduct the audit. He also said in an
interview that he had little respect for conservative religiosity and believes that Regnerus and some other
socially conservative scholars push a political agenda in their academic work. In a paper published last year,
he wrote about how religion and political affiliation affects support for same-sex marriage.
There should be reflection about a conservative scholar garnering a very large grant from exceptionally
conservative foundations, he writes in the audit, to make incendiary arguments about the worthiness of
LGBT parentsand putting this out in time to politicize it before the 2012 United States presidential
election.
Sherkat considers Regnerus to be a bright young scholar, and, years ago, he wrote a letter of recommendation for him.
Sherkat believes that Regnerus, whom he has known for two decades, made a decision to push a conservative political
agenda in his academic work a number of years ago, and that this paper is evidence of it.
Regnerus wrote in a blog post that he is at a point in my career where Im less concerned about making my
professional peers happy.
Regnerus declined to sit for an interview, citing the University of Texas continuing inquiry into the paper.
But when asked by e-mail if Sherkat was a fair arbiter in this case, he replied: He was appointed to
undertake the audit. I wont offer subjective perceptions of fairness or lack thereof.
James D. Wright
Page 3 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percolator...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 29 of 153 Pg ID 1068
with your Chronicle account: Don't have an account? Create one now.
Or log in using one of these alternatives:
Log in to post
Wow, the lynch mob moved quickly.
This is truly very sad. I apologize to Mark Regnerus on behalf of my country and
profession. His study pointed out serious flaws with prior research, which was biased (and
often funded) with bias in the opposite direction.
Wright, the editor, provided The Chronicle with a draft of his response to the controversy, which will also
appear in the November issue of the journal. He writes that two of the six reviewers were paid consultants
to the New Family Structures Study, of which this paper is a part (in addition, two of the three
commentators on the paper in the journal had been paid consultants on the new-family study, a fact that
was divulged at the time the paper was published).
Wright mentions that they made this known to him, assured him it would not affect their judgment, and
said that he trusts his reviewers to check their ideological guns at the referees door. He notes, too, that
its not unusual for scholars who have been consultants at some point on a project to later serve as referees.
Wright has suffered sleepless nights since the publication of Regneruss paper, and has received a steady
stream of angry e-mails, from both colleagues and irate strangers. In his response, he writes that
accusations that he was trying to foster gay-bashing are hurtful and preposterous and that he also
believes, along with critics of the paper, in civil rights for gay people and lesbians.
In his audit, Sherkat reveals that all the reviewers declared that the paper would generate enormous
interest. Enormous interest leads to citations and downloads, which is how a journals relevance is judged.
The higher the impact of its papers, the greater its prestige. Wright acknowledges that he was excited about
the interest the paper would no doubt inspire, and he wonders in retrospect if perhaps this prospect
caused me to be inattentive to things I should have kept a keener eye on.
That excitement was backed up by unanimous positive support from all reviewers. As Sherkat writes: [I]t is
unfair to expect Wright to hear the warning sirens when none were sounded by the reviewers.
Wright points out (as Regnerus himself wrote) that the paper could be read as supportive of gay marriage
because it seems to indicate that more-stable households produce less-troubled children. This does not
sound like spiteful gay-bashing to me, Wright contends in his response. It sounds like a perfectly
reasonable conclusion.
This entry was posted in Uncategorized. Bookmark the permalink.
Comments
Powered by DISQUS
Add a comment
Showing 39 of 228 comments
Sort by
Oldest first
Follow comments: by e-mail by RSS
Real-time updating is paused. (Resume)
Robert Oscar Lopez 1 year ago
Page 4 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percolator...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 30 of 153 Pg ID 1069
As a card-carrying bisexual, I find it sad that gays have now imposed a singular model of
what constitutes a happy GLBT life. You have to be a gay version of Ozzie and Harriet, you
need to follow one politically advantageous model, you can't have difficulties or hardships
in your life, because that makes you somehow not "representative" of who gay people are.
That's what I am seeing in the article above, as gay activists discounted a vast range of
people from the definition of "lesbian mother" and "gay father," literally censoring any
scholarly discussion of life experiences that deviate from the orthodox narrative of middle-
class gay normalcy, no matter how common it is for people not to fit into their categories.
In the rush to present gays as normal, activists have brushed over the fact that being gay is
very hard, and for reasons that are only partly due to stigma. By hiding the hardships that
come with the lifestyle, gays make it that much harder to converse openly about the best
way to find happiness for people regardless of their orientation. I still think civil unions are
a better route than marriage. I still think cooperative foster care working with the
biological parents (and committing to improving the biological parents' lives as opposed
to just taking their kids' custody) is better than pushing a bizarre heteronormatized system
of surrogacy, blind adoptions, and exclusive custody. You can love your kids and do all the
best for them, but chances are if you insist on raising them exclusively in an all-gay home
environment without any contact with a third party who's a biological parent, you are
adding unnecessary hardship.
Regenerus's study could have occasioned a frank conversation about these things and
fostered more honesty. Instead we have silence and everyone being dumbstruck while
thousands of kids are dragooned into a gay parenting system that is making a lot of people
increasingly uneasy, with good reason.
It's a Pyrrhic victory. Drive obvious observations like the ones put forward by Regnerus
into the shadows, and then the dissimulation and deception metastasize. You can silence
scholars who disagree, but you can't eliminate the basic reality that growing up being
raised by a gay couple is harder than being raised by a straight couple. Slather layers of
polish on your arguments and the underlying truth will corrode the whole project from
within.
130peopleliked this.
LIKE
Out of curiosity, Robert, where did you get your "bisexuality card?" Having looked
over some of your publications, you clearly have a bias as well. Perhaps, like
Regenerus, you should admit that bias. I would expect that being a scholar you'd
know better than to make statements ("...but you can't eliminate the basic reality that
being raised by a gay couple is harder...") without rigorous studies, using strong
methodologies. Instead, you let your own bias show through. One of the first things
we learn as young scholars is to leave your bias at the door. If Regenerus was unable
to do so, and clearly he wasn't, he should have stuck to other subject matter.
152peopleliked this.
LIKE
Comment removed.
bunga7 1 year ago
Guest 1 year ago
Page 5 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percolator...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 31 of 153 Pg ID 1070
http://www.youtube.com/watch?v...
LIKE
It's too easy to say we must leave bias at the door. There is no such thing as an
unbiased person. Better to own our biases than to claim we don't have them.
29peopleliked this.
LIKE
Actually many people can leave their bias at the door.............or perhaps you
do not know anyone who totes the company line in order to keep their
job.You apparently were never asked in college to take the opposite side of
a topic from the one you believed in and put together a winning argument
for the stand you don't agree with....................I also found out that no matter
what your stand is, you can find someone who has written something on it
and in some cases much has been written on it..................
And when you say there is no such thing as an unbiased person, in what
respect do you mean??? I think I would disagree with you on that.
LIKE
And you think the other studies done by asking gay and lesbian couples how
their children were doing is less biased? I think what Robert said is true. Many
are not accepting of a relationship they do not approve of based on religious
beliefs, so it would impact how everyone in the family is treated including the
children who might likely be with the gay or lesbian couple in the presence of
someone who does not agree with their relationship. Get real Bunga7. We are
talking about less than 3% of the population of this country living in a
relationship many do not approve of (and please note I did not say they did not
like the people nor do they speak to or treat them badly................but they do not
approve of the relationship (which means they probably aren't having family
picnics with them), so how are you going to have these children around the
gay/lesbian couple and others in marriages that might be considered more main
stream, and you have to do that so children realize they have some options and
their parents aren't the same as other children's parents and vice versa. I did
read another article which indicated that children brought up in gay or lesbian
households tend more towards homosexualf relationships as adults as well.
Given the hardships most gay/lesbian couples suffer, why would they wish to
impose that on children they raise.
LIKE
embuckles 1 year ago
thecoast 1 year ago
PMM 8 months ago
PMM 8 months ago
Page 6 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percolator...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 32 of 153 Pg ID 1071
Speak for yourself. I'm sorry that your life as a bisexual man is so cripplingly awful
that you just can't resiste letting everybody else know about it. As a gay man of many
years standing, and a sort-of-straight man before that - and incidentally, the father of
a wonderful, happy, eminently successful daughter - I must say that my life is
certainly no harder than anyone else's, and a heckuva lot less hard than many.
Projecting one's own miseries onto the whole population of LGBT parents with no
support except for loud ssertion is hardly a recipe for sound public policy
recommendations. Even less sound is constructing meretricious pseudo-studies out
of bad data, sneaking them into a journal by fudging and faking the review process,
and them complaining loudly about "research discrimination" when found out.
Regnerus could not have written so many lies dressed in social science suits by
accident or even stupidity - it was clearly an exercise calculated to mislead from the
start. Lopez is just one more ideological false-flag operation aimed at fighting a rear-
guard action against the truth.
177peopleliked this.
LIKE
Mr. Lopez and Mr. Eveland both seem to prove John Milton's point:
"The mind is its own place and in itself, can make a Heaven of Hell, a
Hell of Heaven."
14peopleliked this.
LIKE
Dr. Lopez, you simply cannot have it both ways. I have read a fair sampling of your
postings here, and you most often use your bisexuality in a pejorative way. In one
posting you talked about coming to grips with your sexuality through prayer and
reflection and then went on to state that your prayer and reflection brought you back
to a heterosexual marriage and life.
Far be it from me to criticize how you live your life. I too, in my early years faced an
uphill battle because of who and what I am (now an openly gay man). In my teenage
years as a Roman Catholic I was deeply closeted, I prayed for change, I prayed to be
made straight. It took until I was 22 for me to come to realize that I am what I am, and
there is nothing wrong with being gay. Well, actually that was the beginning of my
personal acceptance of what I am...not a clearly defined moment.
Believe me Robert, I am sympathetic. People and circumstances surrounding life can
be terribly crushing. But those circumstances of my life are part of what makesme
who I am.
But I am not sympathetic to Mark Regnerus. He demonstrably "cooked the books"
with his study. He sought a specific result and manipulated his study to make it meet
his expectations. He took money from people whose agenda is to deny equality to
LGBT folks andhe somehow found a way to get his paper refereed by people
sympathetic to his beliefs. Even if Dr. Regnerus had nothing but the best of
intentions...which I am fairly confident he did not, taking money from conservative
anti-gay forces puts an agenda in play. Something you and other conservatives always
accuse us liberals of...putting an agenda in play. Everyone has a bias, and everyone
has an agenda, Dr. Lopez, regardless of political ideology. How responsible scholars
acknowledge and deal with those biases is part of the process of research and
publication.
JD Eveland 1 year ago
observer1951 1 year ago
jcisneros 1 year ago
Page 7 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percolator...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 33 of 153 Pg ID 1072
Let us be frank for a moment. Being a parent is difficult. Children do not come issued
with owners' manuals. Gay and straight parents both have hard roads ahead of them,
and gay and lesbian parents do have the added burden of social opprobium from
certain quarters.
But Regnerus's study was not designed to expose and put scholars in a place where a
productivedebate about those particular difficulties would be possible.His study was
designed to authoritatively disqualify gays and lesbians as parents, that was what
those conservative think tanks paid him to do.
~JC
124peopleliked this.
LIKE
Homosexuality is a universally occurring, normal human variant. There is no need for
a type of person to be in a majority for their minority within humanity to be "normal,"
yet you write about an alleged "rush to present gays as normal." You are a jerk.
81peopleliked this.
LIKE
Agreed. The other problem is the silly notion that one can "check one's
ideological bias at the referee's door." All research and all reviews are done and
read through the lens of the people who are doing them, and all research and all
reviews are biased in some way. What we learned as far back as the 70s was to
identify that bias and to state it upfront. To pretend that there is some kind of
mystical "objectivity" is nonsense. There are facts, but how those facts are used
and interpreted is a matter of approach. That is why it is so easy to lie with
statistics.
14peopleliked this.
LIKE
Agreed also. Furthermore, his comment above, i.,e, "lifestyle," implies that
somehow there is a choice to being gay. Get over it. Some of us are born this
way.
21peopleliked this.
LIKE
Some of us? "All of us, any of us," to paraphrase that embarrassing
conservaturd from the Tundra.
1personliked this.
LIKE
Scott Rose 1 year ago
MChag12 1 year ago
22104894 1 year ago
hrh 1 year ago
jaropa 1 year ago
Page 8 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percolator...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 34 of 153 Pg ID 1073
"...the lifestyle..." meh...
I wonder if Lopez believes that heteros similarly follow a heterosexual
lifestyle?
8peopleliked this.
LIKE
Since you're bisexual you fit the mold that Regenerus used for his sample. If you
bother to read the above article carefully as well as the actual text ofRegenerus's
original article, you'll see that he defined as gay or lesbian anyone who had once had a
sexual encounter with someone of the same sex.Furthermore his sample did not
include anyone who was/is raised by stable same sex couples, and with good reasons
since he reached his conclusions with studies prior to 1980.
So according to Regenerus's conclusion, since you're bisexual you automatically are a
lousy parent. Remember it only takes one episode of same sex to be defined as gay or
lesbian in his sample. Acccording to Regenerus, there is no such person as a bisexual.
I don't think you'd agree with him if you took the time to think a bit before falling prey
to an ideological knee jerk reaction.
Regenerus calls himself a social scientist. O.R.Lopez you stated in other posts
thatyou teach literature. Have you ever taken a sociology course and learned about
random sampling, statistics and howyour sample is the foundation stone of your
study? Without arandom
sample, you are merely building a house of cards regardless of how much jargon you
use (I used to teach research methods in social science. In scientific studies, it's all
about method. If the method is flawed, it invalidates the whole study.
This has nothing to do with political/ideological orientation. Ithas everything to do
with scientific illieracy and taking advantage of the fact that so many of us will just
read the headline and skip the rest
PS: a look at Slate for instance and at the headline it assigned to the article about the
study. All it said that a study showed that same sex parents harmed their children.
Most readers did not go beyond the headline as evidenced by many of the
comments.Their "scientific" contributor at fist did not seem to understandthe
methodological flaws in the study at all and then after partly retracting himself, he
takes Regenerus'snotion of "kin based altruism"
as a given. Regenerus uses it to argue that only biological parents should raise
children and those children should be their own. This notion puts the lieonadoptive
parent and their adopted children. Also puts the lie on anyone who ever gave her/his
life to save his fellows (surely you know of soldiers throwing themselves on a grenade
to save their comrades. Or individual who devote their whole life to help people, as
for instance someone like Doc Gurley, a brilliant board certified internest working at a
free low income clinic in San Francisco instead of private practice and accumulating
lots of money, or how about Dr Sakswho refused to patent his polio vaccine and said
that he wanted it to belong to the whole of mankind? etc etc etc etc etc etc In so very
many cases altruism has nothing to do with genetic links.
42peopleliked this.
LIKE
Whatever you feel about life as a homosexual, whatever you feel about the gay rights
movements, it doesn't change the very basic fact that this is an incredibly biased and
poorly written study.
katisumas 1 year ago
joelp 1 year ago
Page 9 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percolator...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 35 of 153 Pg ID 1074
Again, the bottom line is that the study defined children of lesbian mothers or gay
fathers any respondent who claimed that their mother or father had a gay relationship
since their birth. Which means that it is incredibly, incredibly dishonest to portray
this as the outcomes of children raised by gays or lesbians.
29peopleliked this.
LIKE
"Lynch mob"?
Robert, I know you get something out of your obsession with so-called Christian
Martyrdom, but come back to planet earth, honey! No matter how many rights that
are extended to gay people which you already enjoy, you are NOT going to lose your
right to keep believing whatever bad things you want to believe about us. I keep
hearing some Christian Conservatives complain about being "silenced."With
hundreds of Christian Radiostations,mega-church tv shows, and millions in
advertising,I think your "speech" is doing just fine!
33peopleliked this.
LIKE
Gee, mebbe all that hate speech is what's causing climate change. -:)
4peopleliked this.
LIKE
Robert, you want to argue that Regnerus is being attacked purely on ideological
grounds but it is not true. Read the the material being presented to the University of
Texas in its investigation into the scholarly and scientific malpractice Regnerus
engaged in with this study. Regnerus ignored virtually every criterion for creating a
scientifically significant and meaningful study. Sherkat's analysis that the study was
BS is dead on.
13peopleliked this.
LIKE
you are just a lying troll, bisexual my ass!
9peopleliked this.
LIKE
While I would agree with you...we are all free to live in whatever delusion we
choose, especially in the academy, dontcha think?
LIKE
ChristopherErwinHogan 1 year ago
hrh 1 year ago
Diane Turner 1 year ago
cherry 1 year ago
benno 12 months ago
Page 10 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percola...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 36 of 153 Pg ID 1075
It's fitting that the first reply regarding such a travesty (this "study") opens with a line
like this:
"Wow, the lynch mob moved quickly."
This line reflects the same feckless vainglory masquerading as opprobrium that
motivated the "study".
I am reminded, not by such odious trolling, but by the circumstances of this "study"'s
publicationof the computer-generated paper that was accepted by a "prestigious"
journal:
"Philip Davis, a graduate student at Cornell University in Ithaca, New York, revealed
yesterday onThe Scholarly Kitchenblog that he got a nonsensical computer-
generated paper accepted for publication in a peer-reviewed journal.
Earlier this year, Davis started receiving unsolicited emails from Bentham Science
Publishers, which publishes more than 200 'open-access' journals which turn the
conventional business model of academic publishing on its head by charging
publication fees to the authors of research papers, and then making the content
available for free.
As the emails stacked up, Davis was not only encouraged to submit papers, but was
also invited to serve on the editorial board of some of Bentham's journals for which
he was told he would be allowed to publish one free article each year. 'I received
solicitations for journals for which I had no subject expertise at all,' says Davis. 'It
really painted a picture of vanity publishing.'"
----
"In his audit, Sherkat reveals that all the reviewers declared that the paper would
generate 'enormous interest.' Enormous interest leads to citations and downloads,
which is how a journals relevance is judged. The higher the impact of its papers, the
greater its prestige. Wright acknowledges that he was excited about the interest the
paper would no doubt inspire..."
Being anti-gay is quite a business move in the USA. There are all sorts of ways to make
money at it. "Oops. Did I do that?" after trolling for hits by publishing an unscientific
hit piece is par for the course. That someone would acknowledge that they did it for
unscientific reasons speaks to the glories of the tenure system and the academic rot
that permits Trojan horses to not only get past the gates, but to be debated as if
they're something else entirely.
Of course, that metaphor only applies if people are interested in the truth. That
doesn't seem to be an overriding concern in this case. Rather, it seems abundantly
clear that we're talking about putting socially-corrosive myopic business to the fore.
Perhaps they should rename the journal? The word tabloid comes to mind.
No computers were harmed during the making and dissemination of that paper, but
how many gay people must be sacrificed to generate buzz? As a gay man, I'm well
aware of the purely theoretical nature of my existence, one subject to all sorts of whim
and whimsy. As someone who has labored within academia I understand that politics
and business come first. However, one thing I was not programmed for is idleness in
the face of rank injury. The illusion of academic integrity (rigor) must be maintained,
right? If you can't think of the children, at least think of your prestige. Tabloid trickery
may seem alluring at first, but the cost is higher than the payoff.
9peopleliked this.
LIKE
Mr Lopez-
Rubiginous 1 year ago
Gary Gans Bru 1 year ago
Page 11 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percola...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 37 of 153 Pg ID 1076
Wow for being a bisexual you certainly are spreading the speckling rather thick! Does
Regenerus pay you well for this generous affirmation of their manipulated study
groups. Do you live in the UK? I do take offence that you claim being raised by a same-
sex couple brings hardships.
Two cousins of mine were raised by a lesbian couple, and they are fantastic adults.
Both married or will be. The elder son is straight and loves the family immensely.
Happily married, two lovely children that loves their uncles, and never a worry.
The younger son very well, thank you, and openly gay without issues, and a happy
relationship that looks forward to Marriage. Civil Unions are separate and never
equal, but they have settled on Civil Unions...for now. Together for over five years,
and will grow old together. Everyone is pleased as punch, and we look forward to
bring a wonderful Marriage Ceremony. Happy husbands, and like many of our friends
are looking forward to adopting the children Christians cast aside.
Before you blather on about their Ozzie and Harriet life let me inform you that one of
my aunts, their mother, died a few years back. We were all there, but it was my
younger cousin and his husband that moved his grieving mother to live in a larger
home with them. Now my aunt and their Mum are living in the gay couple's home in
the country. So BOOM. Your theory is blown out of the water. Same sex Marriages will
go through the same challenges that everyone else does.
Have you ever been in a same-sex relationship? Please, let me hear about your love
life. I'm looking forward to reading the stories you have with another card-carrying
member of Bisexual Regiment, Robert. How long was your relationship with another
man, how many men have you had relationships, and how about women in your life
regarding the same inquiries?? You've tried to pull the wool, but I can smell someone
speaking bollocks, especially the card-carrying Septics.
9peopleliked this.
LIKE
Well said. Also, the emotion that the study has stirred should should make people
question whether the criticism is scientific or just petulance. For example, Sherkat's
"concise assessment" of the study.
LIKE
"By hiding the hardships that come with the lifestyle, gays make it that
much harder to converse openly about the best way to find happiness for
people regardless of their orientation."
In what way does intellectual dishonesty or laziness-- or simply a glaring error in
method left unmitigated-- help to make this point to people who don't already agree
with it? This should be your concern: How could Regnerus choose _those_ samples
and present _those_ stats and expect to sound credible when he suggests that "the
paper could be read as supportive of gay marriage because it
seems to indicate that more-stable households produce less-troubled
children?"
1personliked this.
LIKE
Dallas_Guy 11 months ago
ericuhe 3 months ago
Dolmance 2 months ago
Page 12 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percola...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 38 of 153 Pg ID 1077
It's a lousy study tarring an entire class of people with a series of scandalous lies.
I'm sorry that as a self hating gay man, you have a problem with that. Unfortunately,
self hating gay men comprise the majority of those who would otherwise oppress
homosexual persons not so unfortunate as to be suffering from the same sort of self
esteem issues you yourself seem prone to.
1personliked this.
LIKE
Sherkat is not an appropriate person to have conducted a review of the publication
process. The fact that he was a member of the editorial board of Social Science Research
and "an early critic of the paper" makes him an inappropriate choice to have conducted
this inquiry in the first place. He is hardly a detached observer here, and it is irresponsible
to have placed him in a position to conduct this inquiry.
What kind of incompetent inquiry is this? You have an originalcritic of the paper who
then becomes an evaluator of the degree to which the publication process was conducted
in an appropriate professional manner on a paper on which he was an early critic. The
evaluator would seem to have a political agenda himself, insofar as the unpleasant things
that he has to say about religious conservatives would seem to predispose him toward a
particular view on these matters. Is this a person who could be expected to practice
scholarly detachment and render an unbiased judgment on a paper that presented
findings that would seem to stand is such sharp contrast to the views of someone with
such contempt for religious conservatives? Further, the evaluator falls all over himself to
praise and defend the editor of the journal, who we know asked him to conduct the inquiry
in the first place.For Sherkat to cast such aspersions on the editorial process and then to
suggest that he might have done the same thing if he were editor suggests a considerable
amount of muddled thinking on his part. Either the editorial process is flawed or it is not.
From this story, it appears that Sherkat suggests that the editorial process was fine but that
the decision to publish the Regnerus was not. The fact is that this is one person's opinion
of the publishability of the Regnerus and Marks papers, and in making this a headline story
the Chronicle has made far too much of one person's opinion. In Sherkat we do not have a
detached scholarly observer. It is an embarassment to Editor Wright and to Social Science
Research to have created an inquiry tobe conducted in this manner by a single biased
observer who is a member of the SSR editorial board and who had already expressed an
evaluation of the Regnerus paper.
If there was a problem with the publication process of the journal, asking a single editorial
board member known to be a critic of the paper that was the subject of the inquiry in the
first place is completely inappropriate and, arguably, unethical. The editor should have
asked a group of leading sociologists who represent a diversity of opinion and who were
completely divorced from the operation of the journal to conduct the inquiry. That this
was not done calls into serious question this entire sordid process.
99peopleliked this.
LIKE
Some weight of evidence would seem to suggest that the "audit" is a CYA sham.
8peopleliked this.
LIKE
Sample? Or do you think that methodology is for the birds?
dashwood 1 year ago
Scott Rose 1 year ago
katisumas 1 year ago
Page 13 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percola...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 39 of 153 Pg ID 1078
7peopleliked this.
LIKE
Robert here clearly identifies his agenda, so much so that he cannot recognize a serious
methodology issue in defining who the subject was in this "study." If a child is not raised
significantly or solely by a gay/lesbian couple, I don't understand how this case qualifies.
There's little input. A woman who possibly had a fling counts? There should have been a
domicile standard. The cause and effect here is dubious without some reasonable
certainty that the couple had an influence on the child for a sizable part of his/her
upbringing. I don't see the science here at all with such a low, arbitrary categorization of
gay parenting. Of course, anyone with a stake in this study won't point out a glaring issue
like this. Did the editor really need help figuring this out? Yikes.
72peopleliked this.
LIKE
Finally! All the discussion so far is on the topic(s) of being gay etc. etc. You have voice
what I am thinking while reading all of them-- WHAT ABOUTTHE METHODOLOGY.
Apparently, that (def of lebian) was just one of the flaws in his reserach.
Thank you for bringing the focus back where it's supposed to be.
9peopleliked this.
LIKE
Thank you, when I read the study, I felt maybe I had read the title, then jumped to a
different study. the title should have been "How infidelity and Homosexuals living a
Lie in Heterosexual Marriages is Harmful to Children"Who needs a study to figure
that out?
15peopleliked this.
LIKE
I'd say Regnerus will be very happy with his citation rating after this :)
17peopleliked this.
LIKE
Dr. Sherkat's cv is available online. It's enormously impressive, demonstrating the range of
his professional accomplishments. I do note some relevant publications that may suggest
his perspective:
Sherkat, Darren E. Powell, Melissa, and Greg Maddox. Religion and Opposition toSame
Sex Marriage.Sherkat, Darren E. Bad Samaritans: Christian Sectarianism and Anti-
ImmigrantSentiment
Lisa Kazmier 1 year ago
maricueta 1 year ago
bayhuntr 1 year ago
Angela Flynn 1 year ago
bethelcollege 1 year ago
Page 14 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percola...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 40 of 153 Pg ID 1079
Sherkat, Darren E., Kylan DeVries, and Stacia Creek. 2010. Religion, Race and Supportfor
Same-Sex Marriage. Social Science Quarterly.91:80-98.
Sherkat, Darren E. 2000. ""That They Be Keepers of the Home": The Effect ofConservative
Religion on Early and Late Transitions into Housewifery." Review ofReligious Research.
41:344-458.
Sherkat, Darren E. and Alfred Darnell. 1999. "The Effect of Parents' Fundamentalism
onChildren's Educational Attainment: Examining Differences by Gender and
Children'sFundamentalism" Journal for the Scientific Study of Religion. 38:23-35.
Darnell, Alfred and Darren E. Sherkat. 1997. "The Impact of Fundamentalism
onEducational Attainment." American Sociological Review. 62:306-315.
Sherkat, Darren E. and John Wilson. 1995. "Preferences, Constraints, and Choices
inReligious Markets: An Examination of Religious Switching and Apostasy." SocialForces.
73:993-1026.
Ellison, Christopher G. and Darren E. Sherkat. 1995. "The Semi-Involuntary
InstitutionRevisited: Regional Variations in Church Participation Among Black
Americans."Social Forces. 73:1415-1437.
Wilson, John and Darren E. Sherkat. 1994. "Returning to the Fold." Journal for
theScientific Study of Religion. 33:148-161.
Ellison, Christopher G. and Darren E. Sherkat. 1993. "Conservative Protestantism
andSupport for Corporal Punishment." American Sociological Review. 58:131-144.
23peopleliked this.
LIKE
I was really impressed with the first reference -- until I realized that the guy who
pitched for the Braves was Greg Maddux, not the Greg Maddox who is a co-author.
11peopleliked this.
LIKE
As reported in the above article, Social Science Research editor James Wright made a
business-based, not a science-based decision to publish this invalid Regnerus study.
Sherkat is on the editorial board of SSR, and Wright assigned him to carry out an
"audit" in the midst of a seeming publication scandal. It would not necessarily be
incorrect to refer to the audit as a CYA sham. Nothing in Sherkat's prior publication
history is any guarantee of him not behaving unethically at some later point, to
protect a journal where he is on the editorial board. To understand Wright's and
Sherkat's involvement in the matter, you would look not to their prior publications,
but rather to the internal and external communications regarding the Regnerus study
with all relevant parties. And you would take into consideration that they might have
made some of those Regnerus-study-related communications via their personal
e-mail addresses rather than their professional ones.
17peopleliked this.
LIKE
fiscalwiz 1 year ago
Scott Rose 1 year ago
haohtt 1 year ago
Page 15 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percola...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 41 of 153 Pg ID 1080
Yes, Dr. Sherkat's resume lists a number of publications. However, thanks to EBSCO
Host, the articles themselves are available and reveal someone with a strong bias
against the religiously active (particularly those that he would label "conservative").
Accordingly, every one of his studies shows religious activity to lead to negative
results. Since anti-gay/pro religion bias has been put forth as the cause of allegedly
flawed research, having an "audit" by someone with an anti-religion bias isno
lessflawed.
26peopleliked this.
LIKE
it should be noted that the flaws in the research are evident and demonstrable;
anti-gay bias has been put forth as the motivation of those flaws. It's one thing to
suggest that anti-religion bias is the cause behind a flawed audit, but first you
have to demonstrate that the audit is flawed in the first place. This you have not
done; you've presupposed it.
11peopleliked this.
LIKE
The study is even more flawed than this article describes. The key measure was based on
adult respondents (a) knowing about, (b) recalling, and (c) reporting that an adult parent
had a same-sex affair, not on whether the respondent's parent actually had a same-sex
affair (let alone was in a long-term same-sex relationship). His core finding, then, is that
adults who recall -- whether accurately or not -- that one parent had a same-sex affair have
worse outcomes, on average, than adults who grew up in intact families, the majority of
which are heterosexual. Regnerus had better measures of LGBT households available, but
chose not to use them.
That being said, accepting grant money from conservative foundations is not grounds for
dismissal. Neither
is hawking careless summaries of your research to Slate or the conservative media. And
neither is publishing a scientifically flawed study. (Heck, the conservative's favorite poster
child for climate change denial, Ed Wegman, is a known plagiarist, and he still has his job.)
92peopleliked this.
LIKE
LOAD MORE COMMENTS
nominalize 1 year ago
signspotter 1 year ago
Page 16 of 16 Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds - Percola...
8/4/2013 http://chronicle.com/blogs/percolator/controversial-gay-parenting-study-is-severely-flawed-j...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 42 of 153 Pg ID 1081
ATTACHMENT D

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 43 of 153 Pg ID 1082
All Michigan
Sign in | Join
Search
Pinterest
0
Email
293
comments
Print (http://blog.mlive.com/businessreview/western_impact/print.html?
entry=/2011/07/conservative_christian_activis.html)
(http://ads.mlive.com/RealMedia/ads/click_lx.ads/www.mlive.com/business/west- michigan/2011/07/conservative_christian_activis.html/1511062920/StoryAd/MICH
Gary Glenn, president of American Family Association of Michigan
Press play button to listen to Gary Glenn's full interview
Glenn appeared on WRFD 880 AM Columbus with Linda Harvey of
"Mission America." Glenn's comments about Holland are heard around
the 11-minute mark.
(http://connect.mlive.com/user/smartinezgr/index.html) By Shandra Martinez | smartinez@mlive.com
(http://connect.mlive.com/user/smartinezgr/posts.html)
on July 06, 2011 at 2:06 PM, updated July 07, 2011 at 10:42 AM
Christian rights activist Gary
Glenn says he wants to set the
record straight after his
comments about gay employees
during a conservative radio
show were picked up by liberal
media outlets.
He didn't say gay workers
shouldn't be hired
(http://www.rightwingwatch.org/content/harvey-and-glenn-dont-hire-
gays) but rather suggested they are not the "best and brightest" employees.
"Being the 'best and brightest' is not defined by engaging in homosexual behavior,
specifically because it's not bright to engage in behavior medically associated with
dramatically increased personal health risks," Glenn alleged in an e-mail to The Press.
People who are gay or lesbian are at dramatically higher risk of mental illness and
substance abuse and AIDS and cancer and hepatitis, he said during his radio interview
about gay marriage with Linda Harvey of "Mission America" on July 2.
Glenn's comments were targeted at office-furniture maker Herman Miller and other
Holland-area companies that have said the City Council's vote against expanding its
anti-discriminatory ordinance (http://www.mlive.com/news/grand-
rapids/index.ssf/2011/06/holland_votes_against_adding_s.html) to include
Conservative Christian activist Gary Glenn says gay
employees are bad hires because of health risks
(http://ads.mlive.com/RealMedia/ads/click_lx.ads/www.mlive.com/busine
michigan/2011/07/conservative_christian_activis.html/1234669184/SecS
More Michigan Business
Michigan Automotive
News and Reviews
(http://www.mlive.com/auto)
Michigan business
press releases
(http://www.mlive.com/prnews
Experience Michigan
John Gonzalez explores the
Great Lakes State
(http://topics.mlive.com/tag/e
michigan/index.html)
See highlights and hidden places
(http://topics.mlive.com/tag/experience-
michigan/index.html)
(http://topics.mlive.com/tag/experience-
michigan/index.html)
Statewide Automotive News Ann Arbor Jackson & Lansing Mid-Michigan Metro Detroit West Michigan
Set Weather
NEWS BUSINESS SPORTS H.S. SPORTS ENTERTAINMENT LOCAL
IN YOUR COMMUNITY: JOBS AUTOS REAL ESTATE RENTALS CLASSIFIEDS OBITUARIES FIND&SAVE LOCAL BUSINESSES PLACE AN AD
Page 1 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because of h...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 44 of 153 Pg ID 1083
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 4, 2013
Pinterest
0
Email
(http://www.mlive.com/lansing-
news/index.ssf/2013/08/michigan_state
Michigan State study: 'Evolution will
punish you if you're selfish and
mean' (http://www.mlive.com/lansing-
news/index.ssf/2013/08/michigan_state
(http://www.mlive.com/lansing-
news/index.ssf/2013/04/state_news_bla
Did The State News really buy out
Michigan State's satirical newspaper?
(http://www.mlive.com/lansing-
news/index.ssf/2013/04/state_news_bla
sexual orientation will hurt their efforts to recruit and retain the most talented
employees (http://www.mlive.com/business/west-
michigan/index.ssf/2011/06/businesses_worry_that_hollands.html).
What ridiculous folly to suggest that only those individuals who engage in homosexual
behavior given all of its severe medical consequences constitute the best and the
brightest," Glenn said.
While Glenn didn't say gays shouldn't be hired, Harvey did during the interview: I
would not think of a homosexual person as a good employment risk, I just wouldnt.
So why do the comments of Glenn, who lives in Midland, matter in Holland?
Glenn is offering to fund the campaigns of candidates running against City
Council members who voted in favor (http://www.mlive.com/news/grand-
rapids/index.ssf/2011/06/pro-family_group_aims_to_unsea.html) of
expanding the ordinance. Glenn is quick to point out that effort is done under his role
as chairman of the Campaign for Michigan Families, a political action committee.
My point was to mock the suggestion that engaging in homosexual behavior defines a
potential job applicant as the 'best and brightest,' he said.
Those who support expanding the ordinance are focusing their efforts
(http://www.mlive.com/news/grand-
rapids/index.ssf/2011/07/holland_gay_rights_supporters.html) on trying to
convince one of the five council members who voted against it to change his or her vote
rather than trying to put the issue on the ballot.
Glenn says his and Harvey's comments were edited and don't include the sources he
says that back up his contention that gay employees have more health issues than
heterosexual employees.
"We are not talking abut a matter of opinions but scientific facts from mainstream
organizations, the Center for Disease Control and by openly homosexual organizations,
said Glenn. These facts are not in dispute.
E-mail Shandra Martinez: smartinez@grpress.com
(mailto:smartinez@grpress.com) and follow her on Twitter at
twitter.com/shandramartinez (http://twitter.com/shandramartinez)
Tweet 40 1 Pinterest Email
Related Stories
Real Estate
Gregory, MI Hamburg, MI
Like 724 0
Search for jobs in
Michigan
(http://jobs.mlive.com/jobs/sea
(http://ads.mlive.com/RealMedia/ads/click_lx.ads/www.mlive.com/busine
michigan/2011/07/conservative_christian_activis.html/1281685150/Mark
Most Comments Most Read
See more comments
(http://www.mlive.com/interact/)
Live blog recap: Detroit Tigers rally to force
extra innings but lose 4-3 to New York
Yankees
(http://mlive.com/tigers/index.ssf/2013/08/live_blog_detroit_
comments)
1974
(http://mlive.com/tigers/index.ssf/2013/08/
comments)
Blog recap: Max Scherzer silences Indians
to improve to 17-1 and help Detroit Tigers
complete sweep
(http://mlive.com/tigers/index.ssf/2013/08/live_blog_7_pm_c
comments)
1363
(http://mlive.com/tigers/index.ssf/2013/08/
comments)
Live Blog: Detroit Lions host New York Jets
in preseason opener
(http://mlive.com/lions/index.ssf/2013/08/live_blog_detroit_l
comments)
1264
(http://mlive.com/lions/index.ssf/2013/08/l
comments)
Susan J. Demas: Mark Schauer takes on
sexism, could pick running mate this year
(http://mlive.com/politics/index.ssf/2013/08/mark_schauer_b
comments)
558
(http://mlive.com/politics/index.ssf/2013/08
comments)
Detroit Tigers' Justin Verlander accused of
using PEDs by former major leaguer Jack
Clark
(http://mlive.com/tigers/index.ssf/2013/08/detroit_tigers_just
comments)
304
(http://mlive.com/tigers/index.ssf/2013/08/
comments)
Page 2 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because of h...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 45 of 153 Pg ID 1084
Pinterest
0
Email
Sign in with your MLive.com, Facebook or Google account
Most Recent
Sort By:
293 comments so far
Pause Live Updates
SimpsonX
(http://connect.mlive.com/user/SimpsonX/index.html)
Monday, March 05, 2012, 5:06:12 PM (http://mlive.com/news/grand-
rapids/index.ssf/2012/03/us_senate_candidate_gary_glenn.html/post/2012-
03-05/19566081)
Reply
Exactly. This Article has shown me who the Santorum voters are. If
people's biggest concern is Gay Marriage, Life must be pretty easy for
them.
http://www.mlive.com/business/west-michigan/index....
(http://www.mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.ht
ml)
Around every corner in the Government, there is a Politician trying to
force their hand, and religion into people's personal lives. What
happened to the Separation of Church and State?
(http://mlive.com/)
https://www.google.com/accounts/o8/id?
id=AItOawkCEmOE9NXl4bGmH7rfFjxweOjoXzdBLE4
(http://connect.mlive.com/user/d_h_1/index.html)
Friday, October 14, 2011, 11:03:00 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
10-15/17494035)
Reply
Perhaps Christian Fundamentalists are not the "best and brightest!"
They tend to be racist and anti-semitic, not to mention homophobic.
Also, he should not be speaking about increased risks associated with
being gay on one hand, and then opposing same sex marriage on the
other. Those who oppose same-sex marriage are responsible for these
risks!
(http://mlive.com/)
Jack_Bloor_189
(http://connect.mlive.com/user/Jack_Bloor_189/index.html)
What strikes me most about this story is the fact that both Gary Glenn
and Linda Harvey scream "closet cases" or at least they APPEAR to be
your typical closet case homosexuals. Gary Glenn has a very effeminate
Add Your Comment
Page 3 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because of h...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 46 of 153 Pg ID 1085
Pinterest
0
Email
Wednesday, July 13, 2011, 3:08:03 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-13/16140196)
Reply
appearing face, not to mention a "gay chin." While Linda Harvey looks
like she's enjoyed her fair share of folk music festivals in Michigan and
Vermont.
Now if I were an employer... And if as an employer I were coached into
discriminating against gays as advised by Gary Glenn / Linda Harvey...
And if either Gary Glenn or Linda Harvey applied for jobs at my place of
employment.... I might very well never hire these two because based on
my anti gay prejudices, I might just automatically assume that Gary
Glenn [secretly or openly] enjoys sexual relations with other men or
that Linda Harvey enjoys fixing Jeep Wranglers in her spare time.
Of course, people like Gary Glenn and Linda Harvey don't have to worry
about seeking employment in corporate America. They were able to
carve out self-employment situations by bashing gay people (among
other people). It would be interesting to see if either of the two could
gain employment, much less land interviews with some of America's
larger more corporate employers (or anyone for that matter...).
In any case, I can't think of a greater act of violence in the USA than
advocating for employers to fire anyone for who and what they are, the
way god or nature created them to be, or for what others perceive them
to be. Employment for most people is a means to pay bills, eat, house
oneself, thrive, SURVIVE.... ...save for retirement, take care of family
members, pay for healthcare, pay down a mortgage...
And here we have a couple of religious wackos oh sorry I mean
"Christians" advocating for economic violence against an entire group of
people.
(http://mlive.com/)
songofkazoo
(http://connect.mlive.com/user/songofkazoo/index.html)
Wednesday, July 13, 2011, 12:06:00 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-13/16139522)
Reply
He and Andrew Shirvel would make a lovely couple.
(http://mlive.com/)
Parker's Lament
(http://connect.mlive.com/user/Replicateleaf/index.html)
Saturday, July 16, 2011, 4:13:59 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-16/16189911)
Reply
Like.
(http://mlive.com/)
Page 4 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because of h...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 47 of 153 Pg ID 1086
Pinterest
0
Email
jacobmaxdad
(http://connect.mlive.com/user/jacobmaxdad/index.html)
Tuesday, July 12, 2011, 9:56:41 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-13/16138440)
Reply
What this man and associated comments show, is that there is little
chance of Americans progressing economically, socially, etc, while we
allow our country to pay attention to hateful rhetoric and ideas
espoused by religious fanatics.
These comments also show a frightening ignorance that is the result of
listening to propaganda from information (not news or facts, for sure)
sources such as FOX.
(http://mlive.com/)
Zandra_Faline_147
(http://connect.mlive.com/user/Zandra_Faline_147/index.html)
Tuesday, July 12, 2011, 4:11:54 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16134443)
Reply
ok-- then ya have to do HUGE questionnaires before every hire--
eliminate anyone who drinks (accidents, liver disease, alcohol poisoning)
drives motorcycle, Ski's, uses ATV's or PWC's, Smokes, Eats Fried food
more than 3x a week etc...
This is NOT a Dictatorship- and HE is not in charge...
If you want to say "hey- I do not like Gays and I think that business
owners should have the right to not hire gay people because it makes
them uncomfortable" THEN SAY SO.. DO NOT hide behind a statement
about health & insurance...
Grow a set- and take your punishment for being what you are-- a Hate
Monger in Guise of a prophet!
God knows who you are and what is in your heart- better than even you
do... and if you are an ACTUAL Christian- You are committing THE
ultimate sin- using God's name in vain to promote hate...
(http://mlive.com/)
David_Oslow_48
(http://connect.mlive.com/user/David_Oslow_48/index.html)
hate hate hate hate hate hate hate hate hate hate hate hate
hate hate! Every other word out of your piehole is the word
hate. Let me help you here: Repeat after me: hate hate hate
hate hate hate hate hate hate hate hate hate hate hate hate
hate hate hate hate hate. Now I want you to say it all my
yourself. I want you to say the word hate until it makes you
Page 5 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because of h...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 48 of 153 Pg ID 1087
Pinterest
0
Email
Tuesday, July 12, 2011, 4:29:49 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16134756)
Reply
sick to your stomach that you vomit when you hear the word.
Homos and their supporters are so full of hate, bigotry and
intolerance, they need to learn how to practice what they
preach.
(http://mlive.com/)
Rick (http://connect.mlive.com/user/rickmcopy/index.html)
Tuesday, July 12, 2011, 3:39:13 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16133853)
Reply
Also, gays don't really like NASCAR. How can someone be a good worker
if he doesn't follow NASCAR?
(http://mlive.com/)
LiveFromDeltaTwp
(http://connect.mlive.com/user/LiveFromDeltaTwp/index.html)
Tuesday, July 12, 2011, 1:42:45 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16131682)
Reply
Mr Glenn sorta looks like the guy in Deliverance who says, "you got a
right pretty mouth."
(http://mlive.com/)
Double Eagle
(http://connect.mlive.com/user/Eeyan/index.html)
Tuesday, July 12, 2011, 3:41:42 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16125404)
Reply
Hiring gays does have its problems.
it's almost impossible to fire a gay for poor job performance, they claim
"discrimination"
(http://mlive.com/)
Idiot
(http://connect.mlive.com/user/getrid2010/index.html)
Tuesday, July 12, 2011, 12:17:28 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16130118)
Reply
You suck too.
(http://mlive.com/)
bhcxyz (http://connect.mlive.com/user/bhcxyz/index.html)
Maybe if they they practiced safe sex we would not have to worry about
Aids. Interferon gets very expensive.
Page 6 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because of h...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 49 of 153 Pg ID 1088
Pinterest
0
Email
Monday, July 11, 2011, 11:42:37 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16124463)
Reply
(http://mlive.com/)
Idiot
(http://connect.mlive.com/user/getrid2010/index.html)
Tuesday, July 12, 2011, 12:18:47 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16130142)
Reply
you suck three.
you suck three.
you suck three.
(http://mlive.com/)
Marlon122
(http://connect.mlive.com/user/Marlon122/index.html)
Monday, July 11, 2011, 11:08:59 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16124171)
Reply
You know when you watch some old news videos of white dudes being
racist in the name of politics or religion or whatever? You know, like
from the 50's or 60's? You think, "how stupid was this guy" or "man this
dude has got to be embarrassed now".... This man, Gary, is that guy.
His children, grandchildren, siblings and others who know him will be
disappointed that they are even related to him. Hate is his game. His
word are of no value to any human being.
(http://mlive.com/)
Idiot
(http://connect.mlive.com/user/getrid2010/index.html)
Tuesday, July 12, 2011, 12:21:02 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16130180)
Reply
some of those old white dudes (in all their "glory" and
"superiority") have not changed a single bit!!
(http://mlive.com/)
Andrew Patner
(http://connect.mlive.com/user/AndrewPatner/index.html)
How sad that Western Michigan and Holland still remain bases and
magnets for twisted bigots such as this "Conservative Christian activist."
Too bad Betty and Gerald Ford could not have lived forever to remind
people who really are best and brightest.
Page 7 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because of h...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 50 of 153 Pg ID 1089
Pinterest
0
Email
Monday, July 11, 2011, 7:31:24 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16121913)
Reply
Andrew Patner -- Chicago
(http://mlive.com/)
Idiot
(http://connect.mlive.com/user/getrid2010/index.html)
Tuesday, July 12, 2011, 12:22:54 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16130218)
Reply
agree w/you Andrew. The whole Holland area and Hope
College really suck bigtime.
(http://mlive.com/)
michigansue
(http://connect.mlive.com/user/michigansue/index.html)
Monday, July 11, 2011, 5:50:28 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16120818)
Reply
Gary Glenn has always been an idiot. He is a classless, clueless fool. I
didn;t even think he was around anymore. Jesus! He's an
embarrassment to all of us REAL Christians!
(http://mlive.com/)
87R10 (http://connect.mlive.com/user/87R10/index.html)
Monday, July 11, 2011, 10:24:38 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16113639)
Reply
So that means that all the "conservatives" in denial about their own
sexuality are better choices? If nobody knows they're really gay, then
they're a better "health choice?"
I've known a lot of straight people that engage in poor health activities
such as binge drinking, drugs, smoking, etc... that are poor "health
choices" for businesses. But by this idiot's rationale, because they're
"straight" they're a better choice for employment?
I want some of what this guy is smoking....
(http://mlive.com/)
lambog (http://connect.mlive.com/user/lambog/index.html)
Here's my problem with his argument: He says that gays are bad hires
because of health risks, but these health risks are not exclusive to gay
people. Therefore shouldn't his argument be that *people* with these
health problems are bad hires? Shouldn't he also be saying that people
that share needles bad hires? What about if my mom had caught
Page 8 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because of h...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 51 of 153 Pg ID 1090
Pinterest
0
Email
Monday, July 11, 2011, 8:27:07 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16112293)
Reply
something from a shared needle or she unknowingly got it from my
father and transmited it to me? I'm not gay but would still put my
employer at risk of higher health care costs.
But he singles out homosexuals. He's a bigot plain and simple.
(http://mlive.com/)
hockeynut100
(http://connect.mlive.com/user/hockeynut100/index.html)
Monday, July 11, 2011, 8:07:16 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16112105)
Reply
I too have an important announcement, Gary Glenn is bad hire due the
fact that he is a narrow minded bigot. From the look of the photo above,
he appears to be a moron as well. Someone should close his mouth for
him and teach him to breath through his nose. Birds or bugs might fly in
there and become trapped.
(http://mlive.com/)
Lookingup
(http://connect.mlive.com/user/hotlkt63/index.html)
Monday, July 11, 2011, 5:03:51 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16120247)
Reply
Great comment. Made me laugh because that is exactly what
I was thinking. He would poison the moral of any business.
(http://mlive.com/)
Idiot
(http://connect.mlive.com/user/getrid2010/index.html)
Tuesday, July 12, 2011, 12:25:30 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16130256)
Ditto!
(http://mlive.com/)
reallyusaidthat?
(http://connect.mlive.com/user/Kheck/index.html)
Monday, July 11, 2011, 6:43:58 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16111684)
Reply
Real life experience? I have yet to see an HIV positive man in the
hospital on his death bed. I have seen countless middle age, married
men dying from alcohol, obesity, and smoking. Most of them retired
auto workers.
(http://mlive.com/)
Page 9 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because of h...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 52 of 153 Pg ID 1091
Pinterest
0
Email
Oscardelablahblah
(http://connect.mlive.com/user/Oscardelablahblah/index.html)
Monday, July 11, 2011, 1:30:14 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16111042)
Reply
Scary photo......kinda of looks evil?
(http://mlive.com/)
reallyusaidthat?
(http://connect.mlive.com/user/Kheck/index.html)
Sunday, July 10, 2011, 8:44:05 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16109050)
Reply
I think Nathan secretly loves Gary.
(http://mlive.com/)
scammer
(http://connect.mlive.com/user/somerss2/index.html)
Sunday, July 10, 2011, 12:37:54 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-10/16104908)
Reply
Lucky for the majority of us that don't share this type of b**&^%it
attitude, we are part of a growing percentage of the population that
chooses to make decisions about our fellow man/woman on an
individual basis and not based on stereotypes and full-on mistruths. This
trend of acceptance will continue because it is right. Mr. Glenn is just
plain wrong. Nuff said. Scammer has spoken....
(http://mlive.com/)
Idiot
(http://connect.mlive.com/user/getrid2010/index.html)
Monday, July 11, 2011, 4:00:19 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16119272)
Reply
Very well spoken-----I totally agree with you and most of the
population is finally starting to see the light as well.
Unfortunately there are still a few IGNORAMOUS HATERS out
there. And some in the name of CHRISTIANITY! They should
get their stupid heads out of the sand and wake up and start
loving all humankind just as their "precious JESUS" showed
us how to love one another!
(http://mlive.com/)
rocnbamagirl
(http://connect.mlive.com/user/rocnbamagirl/index.html)
he is really gay him self but the gays don't want him how stupid he
sounds get rid of this a@# hole what a jerk bend over gary glenn the
broom stick is on its way
(http://mlive.com/)
Page 10 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because o...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 53 of 153 Pg ID 1092
Pinterest
0
Email
Sunday, July 10, 2011, 12:15:14 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-10/16104659)
Metta WorldHate
(http://connect.mlive.com/user/MettaWorldHate/index.html)
Sunday, July 10, 2011, 12:07:47 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-10/16104568)
Reply
Christians are bad hires because of low IQs.
(http://mlive.com/)
moss71 (http://connect.mlive.com/user/moss71/index.html)
Saturday, July 09, 2011, 2:05:41 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-09/16096688)
Reply
Because someone labels himself a Conservative Christian it makes it
okay for him to give reasons to perpetuate hatred toward others? That's
the least Christian thing I have ever heard. I do not claim to be a
Christian, but wouldn't it be more Christ-like to embrace our
homosexual brothers and sisters and love them for who they are? I am
an athiest, and it's okay with me if gays want to be gay. Doesn't that
make me more of a Christian than Mr. Glenn?
(http://mlive.com/)
Idiot
(http://connect.mlive.com/user/getrid2010/index.html)
Monday, July 11, 2011, 4:03:15 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16119321)
Reply
YES!!! Mr G.A.G. is the farthest thing from a real Christian. I
would be willing to bet that his middle name is Arnold. Get it?
(http://mlive.com/)
Uncle Festus (http://connect.mlive.com/user/Uncle%
20Festus/index.html)
Saturday, July 09, 2011, 11:30:52 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-09/16095087)
Reply
Where did they find this neanderthal Gary Glenn? It is one thing to be
such a bigot, but another to be willing to go public with your spiteful and
silly ideas.
(http://mlive.com/)
ppwiii (http://connect.mlive.com/user/ppwiii/index.html)
Page 11 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because o...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 54 of 153 Pg ID 1093
Pinterest
0
Email
Saturday, July 09, 2011, 7:35:31 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-09/16092718)
Reply
Gary Glenn is an opportunist idiot. He is keeps beating this drum to
keep the money rolling in from the religious right. He is always taking
the wacko position on gays, strippers, pornography etc. He could do a
lot of good with the money he raises, if he would start working on some
important issues and drop his right wing fluff garbage.
(http://mlive.com/)
Robert Melton
(http://connect.mlive.com/user/robertwmelton/index.html)
Saturday, July 09, 2011, 7:26:53 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-09/16092672)
Reply
First, you cannot be a christian if you believe in gay rights. Secondly,
being gay, is an emotional problem not a genetic or biological problem.
What happens when one of your employees (male) starts showing gay
porn pictures to other workers? Happened to me- talk about disruptive
to the work environment! Like having Bill Clinton judging a beauty
contest.
So, would you hire nutty athiests to work at your company? Why would
you? Business is too difficult now. hire christian family men and you will
have a better workforce.
(http://mlive.com/)
str8ally
(http://connect.mlive.com/user/str8ally/index.html)
Saturday, July 09, 2011, 9:10:18 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-09/16093506)
Reply
I am sorry, but we are Christians and we support gay rights.
You cannot be a Christian and support discrimination, and
fuel hatred by demonizing and outright lying towards other
human beings. We all know who those un-Christians are, the
" Family " groups.
As for the alledged porn pictures shown at work, did anyone
report this person to supervisors ? Was this person
disiplined ? That kind of behaviour, gay or straight, is totally
different than just someone who is gay and wants the same
rights and protections as the heterosexual community has.
(http://mlive.com/)
Uncle Festus
(http://connect.mlive.com/user/Uncle%
20Festus/index.html)
I am a Christian.
I support gay rights.
Page 12 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because o...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 55 of 153 Pg ID 1094
Pinterest
0
Email
Saturday, July 09, 2011, 11:32:21 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-09/16095106)
I do not support stupidity and hatefulness from
fellow Christians.
(http://mlive.com/)
Kevin Rahe
(http://connect.mlive.com/user/KevinRahe2/index.html)
Sunday, July 10, 2011, 10:26:17 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16109911)
Christians are called to treat people with dignity and respect,
but you cannot treat someone with dignity and respect by
affirming acts to which they're inclined that are themselves
undignified and disrespectful. Nor is it treating them with
dignity and respect to treat the inclinations themselves as
positive or even neutral.
(http://mlive.com/)
dmbierlein
(http://connect.mlive.com/user/dmbierlein/index.html)
Monday, July 11, 2011, 10:00:54 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16113316)
Which acts, that are exclusive to the gay community, would
those be, Kevin?
(http://mlive.com/)
Idiot
(http://connect.mlive.com/user/getrid2010/index.html)
Tuesday, July 12, 2011, 12:30:57 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-12/16130361)
what a bunch of rubbish and double-talk you hater!
(http://mlive.com/)
Idiot
(http://connect.mlive.com/user/getrid2010/index.html)
Monday, July 11, 2011, 4:08:23 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-11/16119409)
Reply
You are so full of crap . . . . . I can smell you from here.
(http://mlive.com/)
Idiot (http://connect.mlive.com/user/getrid2010/index.html)
Saturday, July 09, 2011, 12:42:49 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-09/16091530)
Reply
Consider yourself published. Are you happy now? We're not.
(http://mlive.com/)
Page 13 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because o...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 56 of 153 Pg ID 1095
Pinterest
0
Email
str8ally (http://connect.mlive.com/user/str8ally/index.html)
Friday, July 08, 2011, 4:32:33 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-08/16086554)
Reply
Well, Gary Glenn, I will have to say that you aren't fairing too well on
your soapbox by looking at all the comments of the past 3 days. You
have did everything in your power to hurt and divide our families with
your hateful rhetoric. The tide is changing as you can see, and people
see through the lies and distortion. There is help for you, as there are
plenty of mental health clinics around Midland, and the state, to help
you get past your obsession and hatred for our gay AMERICAN
taxpaying citizens. Good luck in overcoming your mental illness.
(http://mlive.com/)
coacheklund
(http://connect.mlive.com/user/coacheklund/index.html)
Friday, July 08, 2011, 7:08:05 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-08/16088534)
Reply
sally; gawd, you are an idiot . . . .
(http://mlive.com/)
Uncle Festus
(http://connect.mlive.com/user/Uncle%
20Festus/index.html)
Saturday, July 09, 2011, 11:33:59 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-09/16095128)
Hey Coach,
You don't know what you are talking about.
(http://mlive.com/)
booknerd
(http://connect.mlive.com/user/booknerd/index.html)
Friday, July 08, 2011, 4:00:16 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-08/16086053)
Reply
So maybe someone should point out that it may not be wise to hire
young married, or single, women of child bearing age because there is a
high probability they will have a baby and cost the employer a lot of
money. Or maybe it isn't the wisest to hire partyers because they are at
high risk for alcoholism or drug addiction and will have all sorts of health
and safety issues. Then again, maybe it isn't wise to hire someone
getting up in years because they have a high probability of having all
sorts of age related issues that may cause them to be absent, reduce
productivity and will potentially cost the employer a lot of money.
Discrimination is discrimination no matter who it is directed at. Shame,
shame, shame!
(http://mlive.com/)
Page 14 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because o...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 57 of 153 Pg ID 1096
Pinterest
0
Email
MLive Media Group
(http://www.mlivemediagroup.com)
Our Team
(http://www.mlivemediagroup.com/about/team/)
Advertise
(http://www.mlive.com/advertise/)
Contact Us
(http://www.mlivemediagroup.com/contact-
us/)
Jobs at MLive
(http://mlivemediagroup.com/jobs/)
FAQ
(http://www.mlive.com/aboutus/index.ssf?/aboutus/content/faq.html)
The Grand Rapids Press (http://www.mlivemediagroup.com/subscribe/grand-rapids-press/)
The Muskegon Chronicle (http://www.mlivemediagroup.com/subscribe/muskegon-chronicle/)
The Kalamazoo Gazette (http://www.mlivemediagroup.com/subscribe/kalamazoo-gazette/)
About Us
Subscriptions
Newspaper
(http://www.mlivemediagroup.com/subscribe/) |
eReplica (http://www.mlive.com/ereplica/) |
eNewsletters (http://www.mlive.com/enewsletters/)
News
(http://www.mlive.com/news/)
Business
(http://www.mlive.com/business/)
Sports
(http://www.mlive.com/sports/)
High School Sports
(http://highschoolsports.mlive.com/)
Entertainment
(http://www.mlive.com/entertainment/)
Living
(http://www.mlive.com/living/)
Opinion
(http://www.mlive.com/opinion/)
Obituaries
(http://www.mlive.com/deathnotices/)
Jobs
(http://www.mlive.com/jobs/)
Autos
(http://autos.mlive.com/)
Real Estate
(http://realestate.mlive.com/)
Apartment Rentals
(http://realestate.mlive.com/for-
rent/)
Classifieds
(http://classifieds.mlive.com/)
Local Deals
(http://www.mlive.com/deals/)
Local Businesses
(http://businessfinder.mlive.com)
Business Resource
Center
(http://www.mlive.com/business-
resource-center/)
MLive Sections
Forums
(http://www.mlive.com/forums/)
Photos
(http://photos.mlive.com/photogallery/)
Video
(http://videos.mlive.com/)
Weather
(http://www.mlive.com/weather/)
Post a job
(http://www.mlive.com/jobs/)
Post a free classified ad
(http://www.mlive.com/classifieds/free/)
Sell your car
(http://www.mlive.com/placead/)
Sell/Rent your home
(http://www.mlive.com/placead/)
Apartments and Rentals
(http://realestate.mlive.com/for-
rent/)
Site Map
(http://www.mlive.com/sitemap/)
More on MLive
Follow Us
Twitter (http://twitter.com/mlive) |
Facebook (http://facebook.com/mlive) |
Google+
(https://plus.google.com/u/0/118382608325892108926)
(http://www.mlive.com/tigers/index.
game_winning.html#incart_hbx#incar
of) Tigers' 12-game winning streak
ends against Yankees...
(http://www.mlive.com/tigers/index.
game_winning.html#incart_hbx#incar
of)
(http://www.mlive.com/lansing-
news/index.ssf/2013/08/prank_caller
of) Prank callers falsely say tiger
loose from Lansing...
(http://www.mlive.com/lansing-
news/index.ssf/2013/08/prank_caller
of)
(http://www.mlive.com/lions/index.s
six_helps.html#incart_2box#incart_hb
of) Ansah's pick-six leads Lions over
Jets 26-17
(http://www.mlive.com/lions/index.s
six_helps.html#incart_2box#incart_hb
of)
Best of MLive.com
Lyn_Behnke_420
(http://connect.mlive.com/user/Lyn_Behnke_420/index.html)
Friday, July 08, 2011, 12:01:17 PM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-08/16081905)
Reply
Wow! Amazing! This gentleman not only doesn't understand Christian
principles, he also has no Christian Values. I am embarrased to have
him represent me or my family as a "Christian" man.
(http://mlive.com/)
Idiot
(http://connect.mlive.com/user/getrid2010/index.html)
Saturday, July 09, 2011, 12:47:23 AM (http://mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html/post/2011-
07-09/16091552)
Reply
very well said.
(http://mlive.com/)
More Comments
Page 15 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because o...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 58 of 153 Pg ID 1097
(http://www.advancedigital.com/)
Registration on or use of this site constitutes acceptance of our User Agreement (http://www.mlive.com/useragreement/) and Privacy Policy
(http://www.mlive.com/privacypolicy/) (Revised November 1, 2011)
2013 MLive Media Group All rights reserved (About Us (http://www.mlive.com/aboutus/)).
The material on this site may not be reproduced, distributed, transmitted, cached or otherwise used, except with the prior written permission of MLive
Media Group
Community Rules (http://www.mlive.com/forums/index.ssf?rules.html) apply to all content you upload or otherwise submit to this site. Contact
interactivity management. (http://www.mlive.com/forums/index.ssf?rules.html)
Ad Choices (http://www.advance.net/advancedigitalUserAgreementPP/#opt_out)
Tweet
40
724
Like
1
Pinterest
0
Email
Jackson Citizen Patriot (http://www.mlivemediagroup.com/subscribe/jackson-citizen-patriot/)
AnnArbor.com (http://www.annarbor.com/newspaper/)
The Flint Journal (http://www.mlivemediagroup.com/subscribe/flint-journal/)
The Saginaw News (http://www.mlivemediagroup.com/subscribe/saginaw-news/)
The Bay City Times (http://www.mlivemediagroup.com/subscribe/bay-city-times/)
Ann Arbor
(http://www.mlive.com/ann-
arbor/)
Bay City
(http://www.mlive.com/bay-
city/)
Detroit
(http://www.mlive.com/detroit/)
Flint
(http://www.mlive.com/flint/)
Grand Rapids
(http://www.mlive.com/grand-
rapids/)
Jackson
(http://www.mlive.com/jackson/)
Kalamazoo
(http://www.mlive.com/kalamazoo/)
Lansing
(http://www.mlive.com/lansing/)
Muskegon
(http://www.mlive.com/muskegon/)
Saginaw
(http://www.mlive.com/saginaw/)
Your Regional News Pages
Mobile
Mobile View (http://mobile.mlive.com/) | Mobile
Apps (http://www.mlive.com/mobile-device/) |
Tablet Apps (http://www.mlive.com/mobile-device/)
Page 16 of 16 Conservative Christian activist Gary Glenn says gay employees are bad hires because o...
8/10/2013 http://www.mlive.com/business/west-michigan/index.ssf/2011/07/conservative_christian_a...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 59 of 153 Pg ID 1098
ATTACHMENT E

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 60 of 153 Pg ID 1099
(http://ads.mlive.com/RealMedia/ads/click_lx.ads/www.mlive.com/news/grand- rapids/2011/07/gary_glenn_steps_into_holland.html/691013949/Tower/MICHIGANLIVE/default/empty.gif/47417374546c4878567a6f4141486253)
All Michigan
Sign in | Join
Search
30
comments
Print (http://blog.mlive.com/grpress/news_impact/print.html?
entry=/2011/07/gary_glenn_steps_into_holland.html)
(http://ads.mlive.com/RealMedia/ads/click_lx.ads/www.mlive.com/news/grand- rapids/2011/07/gary_glenn_steps_into_holland.html/870847030/StoryAd/MICHIG
Gary Glenn
Full Script of Gary Glenn's robocall
"Hi, this is Gary Glenn with
the Campaign for Michigan
Families, urging you to
support Jerry Tonini for
Holland City Council. Jerry
Tonini is the only candidate
who opposes the
discriminatory ordinance
giving special rights to
individuals involved in
homosexual behavior or cross-dressing.
Jay Peters voted in favor of homosexual activists
discriminatory ordinance, and Victor Orozco said he
also supports the homosexual special rights
ordinance.
This discriminatory ordinance supported by Peters
and Orozco threatens your familys religious
freedom. In other states, these sexual orientation
laws have been used in court to legalize homosexual
marriage and to discriminate against churches,
businesses, and individuals plus community groups
such as the Boy Scouts, Salvation Army, and Catholic
Charities -- who refuse to allow homosexual
Scoutmasters or clergy or to support the homosexual
agenda.
Remember, Jay Peters and Victor Orozco support this
discriminatory ordinance that threatens marriage
and religious freedom.
Only one candidate opposes homosexual activists
discriminatory special rights ordinance: Jerry Tonini,
chairman of the Holland Planning Commission.
Jerry Tonini is committed to protecting the
traditional values and religious freedom shared by
families in Holland. Jerry Tonini will vote to protect
(http://connect.mlive.com/user/smartinezgr/index.html) By Shandra Martinez | smartinez@mlive.com
(http://connect.mlive.com/user/smartinezgr/posts.html)
on July 29, 2011 at 8:40 PM, updated July 30, 2011 at 3:28 PM
HOLLAND Conservative
Christian activist Gary Glenn
is keeping his promise to
campaign for candidates
challenging Holland City
Council incumbents who voted
in favor of extending the
city's anti-discrimination
law
Gay rights debate made focus of Holland election
with Gary Glenn's robocalls
Tweet
32
30
Like
0
Pinterest
0
Email
(http://ads.mlive.com/RealMedia/ads/click_lx.ads/www.mlive.com/news/
rapids/2011/07/gary_glenn_steps_into_holland.html/1819533038/SecSp
Get the latest updates
Subscribe to our
newsletters
(http://www.mlive.com/newsle
Experience Michigan
John Gonzalez explores the
Great Lakes State
(http://topics.mlive.com/tag/e
michigan/index.html)
See highlights and hidden places
(http://topics.mlive.com/tag/experience-
michigan/index.html)
(http://topics.mlive.com/tag/experience-
michigan/index.html)
Michigan News Crime Education Opinion Obituaries Lottery Weather Politics eReplica Newsletters
Set Weather
NEWS BUSINESS SPORTS H.S. SPORTS ENTERTAINMENT LOCAL
IN YOUR COMMUNITY: JOBS AUTOS REAL ESTATE RENTALS CLASSIFIEDS OBITUARIES FIND&SAVE LOCAL BUSINESSES PLACE AN AD
Page 1 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive.com
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 61 of 153 Pg ID 1100
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 4, 2013
marriage and religious freedom. Tuesday, please vote
for Jerry Tonini for city council, either at City Hall or
St Frances on West 13th.
This message was paid for by the Campaign for
Michigan Families, including our supporters here in
Holland."
(http://www.mlive.com/news/grand-
rapids/index.ssf/2011/06/holland_votes_against_adding_s.html) to include
sexual orientation and gender identity.
Glenn called Holland voters Thursday night in a robocall message supporting Gerardo
Jerry Tonini who is running for 2nd Ward seat on the City Council against incumbent
Jay Peters.
Peters was one of the four members who unsuccessfully voted in favor of the ordinance.
The three-way race also includes former Councilman Victor Orozco, who supports gay
rights.
Did Glenn's call help Tonini's campaign?
I don't know, admits Tonini. The results will be known on Aug. 2.
Expanding the ordinance to sexual orientation isn't needed, said Tonini, who currently
serves as chairman of the city's Planning Commission.
If we protect a certain group of people, then in essence we create more
discrimination, he said.
Tonini, who works for T2 Communications, says he doesn't buy the argument by some
companies that not expanding the ordinance hurts businesses. Furniture-maker
Herman Miller and other businesses say the council's failure to expand the ordinance
will hurt their efforts to recruit top employees
(http://www.mlive.com/business/west-
michigan/index.ssf/2011/06/businesses_worry_that_hollands.html), no
matter what their sexual orientation.
In a radio interview, Glenn took aim at Herman Miller by suggesting that gay workers
don't number within the ranks of the "best and the brightest" employees
(http://www.mlive.com/business/west-
michigan/index.ssf/2011/07/conservative_christian_activis.html).
Glenn is president of the American Family Association of Michigan.
(http://www.afamichigan.org/) His involvement in the City Council election
comes as the chairman of the political action campaign, Campaign for Michigan
Families. (http://www.facebook.com/pages/Campaign-for-Michigan-
Families/136814623005740)
Glenn recently announced he might mount his own campaign for U.S. Sen. Debbie
Stabenow's seat, which would first pit him against Holland's favorite son and former
Republican Congressman Peter Hoekstra
In the robocall, Glenn hails Tonini for opposing a discriminatory ordinance giving
special rights to individuals involved in homosexual behavior or cross-dressing,"
Some criticize Glenn for stepping into the local election but Tonini says he appreciates
Glenn's support.
"I'm think every resource is valuable when we are dealing with an election," Tonini said.
E-mail Shandra Martinez: smartinez@grpress.com
(mailto:smartinez@grpress.com) and follow her on Twitter at
twitter.com/shandramartinez (http://twitter.com/shandramartinez)
Follow MLive on
Twitter
(https://twitter.com/mlive)
Most Comments Most Read
See more comments
(http://www.mlive.com/interact/)
Live blog recap: Detroit Tigers rally to force
extra innings but lose 4-3 to New York
Yankees
(http://mlive.com/tigers/index.ssf/2013/08/live_blog_detroit_
comments)
1974
(http://mlive.com/tigers/index.ssf/2013/08/
comments)
Blog recap: Max Scherzer silences Indians
to improve to 17-1 and help Detroit Tigers
complete sweep
(http://mlive.com/tigers/index.ssf/2013/08/live_blog_7_pm_c
comments)
1363
(http://mlive.com/tigers/index.ssf/2013/08/
comments)
Live Blog: Detroit Lions host New York Jets
in preseason opener
(http://mlive.com/lions/index.ssf/2013/08/live_blog_detroit_l
comments)
1264
(http://mlive.com/lions/index.ssf/2013/08/l
comments)
Susan J. Demas: Mark Schauer takes on
sexism, could pick running mate this year
(http://mlive.com/politics/index.ssf/2013/08/mark_schauer_b
comments)
558
(http://mlive.com/politics/index.ssf/2013/08
comments)
Detroit Tigers' Justin Verlander accused of
using PEDs by former major leaguer Jack
Clark
(http://mlive.com/tigers/index.ssf/2013/08/detroit_tigers_just
comments)
304
(http://mlive.com/tigers/index.ssf/2013/08/
comments)
Page 2 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive.com
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 62 of 153 Pg ID 1101
(http://www.mlive.com/business/west-
michigan/index.ssf/2013/08/holland_do
Holland doctor honored by North
American Menopause Society
(http://www.mlive.com/business/west-
michigan/index.ssf/2013/08/holland_do
(http://www.mlive.com/entertainment/
rapids/index.ssf/2013/08/salsa_showdo
Salsa Showdown to determine the 'Best
in the West' at Holland Farmers Market
(http://www.mlive.com/entertainment/
rapids/index.ssf/2013/08/salsa_showdo
Sign in with your MLive.com, Facebook or Google account
Most Recent
Sort By:
30 comments so far
Pause Live Updates
rabbitoh
(http://connect.mlive.com/user/donald_martin/index.html)
Tuesday, August 02, 2011, 10:12:52 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-08-
03/16434763)
Reply
Hahaha. Tonini-Glenn lost by a lot tonight. Hahahahaha.
(http://mlive.com/)
anglophile
(http://connect.mlive.com/user/anglophile/index.html)
Tuesday, August 02, 2011, 2:49:35 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-08-
02/16428348)
Reply
It seems to me that the only people who still have land lines (and cell
phone numbers are largely not included in robo-calls) are older people
who mostly already voted via absentee ballot weeks ago. I think Glenn,
er, "screwed the pooch" on this one.
(http://mlive.com/)
Tweet 32 0 Pinterest Email
Related Stories
Add Your Comment
Real Estate
Pinckney, MI Pinckney, MI
Like 30 0
Page 3 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive.com
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 63 of 153 Pg ID 1102
dmbierlein
(http://connect.mlive.com/user/dmbierlein/index.html)
Saturday, July 30, 2011, 2:39:14 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16387557)
Reply
Does Gary's concern for family values and religious freedom extend to
the right of Mormons to have their sense of family and religious
freedom?
(http://mlive.com/)
editann (http://connect.mlive.com/user/editann/index.html)
Saturday, July 30, 2011, 1:00:42 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16386433)
Reply
I remember Gary Glenn getting involved several years in a city vote
about internet access at the Holland library--he lost. The 2nd Ward is
fairly progressive, so I am hoping he has the same effect this time.
Today I got an "independent survey" phone call asking who I support in
the council election. The caller refused to say who was financing it, but
my guess is that it's Glenn and the AFA. So much for the argument by
opponents of the ordinance that "outsiders" should stay out of this fight.
And one more time...it is not about "special rights" any more than race,
ethnicity, age, etc. are "special rights." Nineteen cities in Michigan--
including Grand Rapids--have similar ordinances and the sky has not
fallen, no heterosexual marriages have been damaged, and the world
has gone on in the 21st century.
(http://mlive.com/)
informedone
(http://connect.mlive.com/user/informedone/index.html)
Saturday, July 30, 2011, 11:25:01 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16385181)
Reply
This Glenn guy concerns me. Why would any straight guy be so
obsessed with this subject? Makes you wonder. Closet case maybe? He
needs to do something productive with his life.
(http://mlive.com/)
thrillkiller
(http://connect.mlive.com/user/thrillkiller/index.html)
Saturday, July 30, 2011, 10:09:46 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16384212)
Reply
Wonder what Gary has in his closet?...besides the obvious.
(http://mlive.com/)
fred76 (http://connect.mlive.com/user/fred76/index.html)
Silly issue. No one has explained why the gay rights folk want this
ordinance so bad. The alleged reason is that Herman Miller, Johnson
Controls etc. have problems attracting gay professionals. I want to know
Page 4 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive.com
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 64 of 153 Pg ID 1103
Saturday, July 30, 2011, 9:26:12 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16383639)
Reply
just how many high end homes and condos, especially in this market,
refuse to sell or rent based on sexual preference? I don't approve of the
"lifestyle", but I'd rent to sodomites like anyone else. People mad about
Glenn and others getting involved should thank the culture warriors of
the Left on the city council for starting the fight in the first place.
Apparently the economy is so good in Holland right now, there was
nothing else to talk about.
(http://mlive.com/)
diaghilev
(http://connect.mlive.com/user/diaghilev/index.html)
Saturday, July 30, 2011, 10:46:59 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-
07-30/16384702)
Reply
No one has explained what 'sodomites' are. Fred76, you want
to find people who are sodomites and make them your
tenants? Like, exclusively? I am sorry if everyone already
knows this, but Christians defending moral value use words
sometimes I don't know. And my dictionary filters them out.
When Christians frequently refer to 'beastiality,' 'incest,' etc.
my dictionary has family filters that block those words. Can
someone explain them there?
(http://mlive.com/)
teatax
(http://connect.mlive.com/user/teatax/index.html)
Saturday, July 30, 2011, 2:27:13 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-
07-30/16387406)
Dia: There was a scene in the comedy movie "Young
Frankenstein" when Dr Frankenstein was addressing
his peers about sexual behavior and he happened to
notice two young children in the room. Out of
consideration of them he began to use words that
were substituted for the real words about sex. Here
on MLive we cannot answer your question but I can
tell you that Gene Wilder used words like PP and
woo woo. Don't push a political agenda and expect
NOT to have political opposition.
(http://mlive.com/)
diaghilev
(http://connect.mlive.com/user/diaghilev/index.html)
Sunday, July 31, 2011, 1:06:32 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-
07-31/16392914)
I unfortunately get zero points for understanding what you're
talking about.
(http://mlive.com/)
ppwiii (http://connect.mlive.com/user/ppwiii/index.html)
This guy is a loon. These calls are probably a bonus for the folks he
opposes.
Page 5 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive.com
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 65 of 153 Pg ID 1104
Saturday, July 30, 2011, 8:07:41 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16382845)
Reply
(http://mlive.com/)
regaltdp (http://connect.mlive.com/user/regaltdp/index.html)
Saturday, July 30, 2011, 6:19:58 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16382322)
Reply
Gary Glenn doesn't have a lot to do during the day, does he?
(http://mlive.com/)
trebor (http://connect.mlive.com/user/rs4545/index.html)
Saturday, July 30, 2011, 6:18:54 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16382317)
Reply
Another Bibble thumper showing his hate and bias toward the human
race. For a perfect picture of Glenn, give him a white sheet.
(http://mlive.com/)
chungasrevenge
(http://connect.mlive.com/user/chungasrevenge/index.html)
Saturday, July 30, 2011, 5:57:55 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16382252)
Reply
find his phone number & robo call his bald head right back
(http://mlive.com/)
kb.esq (http://connect.mlive.com/user/https%3A%2F%
2Fwww.google.com%2Faccounts%2Fo8%2Fid%3Fid%
3DAItOawmFGfUcjVtfLUxVT16ieg3rUjLsfZaEyw8/index.html)
Saturday, July 30, 2011, 5:31:53 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16382170)
Reply
Both sides have a point here. On the one hand, the government, most
employers, and most businesses should not be permitted to discriminate
on the basis of sexual orientation. However, religious organizations
should not be punished for refusing to hire otherwise qualified
individuals whose lifestyles are prohibited by the applicable religion.
(Whether or not such organizations should be permitted to retain tax
exempt status under such circumstances is a relevant question, but for
a another debate.) In this instance, I believe there was an exemption
for religious organizations contained within the ordinance in question, so
what's the fuss.
(http://mlive.com/)
diaghilev
(http://connect.mlive.com/user/diaghilev/index.html)
Page 6 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive.com
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 66 of 153 Pg ID 1105
Saturday, July 30, 2011, 2:12:46 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-
07-30/16387265)
Reply
I think exemptions also applied to Hispanics, African-
Americans, Asian-Americans, women, those with disabilities,
and others. So your church could fire any of these folks for
their minority status, if you didn't like it. These exemptions
for churches to fire minorities were part of the ordinance at
an early stage, but I think the Hispanics, African-Americans,
Asian-Americans, women and those with disabilities didn't like
it. It just "felt wrong" I guess, to preserve the right for a
church to fire a black woman because their version of
theology thought being African-American was a sin. They
loved the sinners but they wanted to be able to fire them for
their sin, basically. And the various minorities thought maybe
that sounded weird, so they asked for it to be removed.
That's my understanding.
(http://mlive.com/)
diaghilev
(http://connect.mlive.com/user/diaghilev/index.html)
Saturday, July 30, 2011, 1:33:17 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16381570)
Reply
If we protect a certain group of people, then in essence we create more
discrimination." -Rosa Parks
Actually, to be honest, I'm not sure. It might have been Martin Luther
King, Jr. Or possibly Jerry Tonini. I don't know.
But either way, yes. Finally. Some come on sensei. History has shown
that when the United States protects some people who are being
attacked, it creates unchecked discrimination. Although you may not
have gotten this memo. Or maybe you did get this memo but used it as
a bookmark in your leather bound copy of The Gay Agenda and oh big
surprise, you once again saved your spot on page 69, I'm so totally
shocked.
(http://mlive.com/)
tranesong2
(http://connect.mlive.com/user/tranesong2/index.html)
Saturday, July 30, 2011, 12:28:56 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16381187)
Reply
As for Gary Glenn. I wouldn't trust him watching over my sheep.
(http://mlive.com/)
diaghilev
(http://connect.mlive.com/user/diaghilev/index.html)
That would NOT be the guy hire for that job.
(http://mlive.com/)
Page 7 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive.com
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 67 of 153 Pg ID 1106
Saturday, July 30, 2011, 1:34:44 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-
07-30/16381575)
Reply
tranesong2
(http://connect.mlive.com/user/tranesong2/index.html)
Saturday, July 30, 2011, 12:23:17 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16381142)
Reply
Really? You need to know what your neighbor is doing in the bedroom?
Really? Are you the bedroom police? You are that interested? It's funny.
I certainly don't want to know what YOU do in your bedroom. But you
seem to want to know and understand what complete strangers do.
Seems just a bit deviant in itself. Is it the fact that you believe
homosexuals have more sex, and better than you?
(http://mlive.com/)
umguy (http://connect.mlive.com/user/umguy/index.html)
Friday, July 29, 2011, 11:36:34 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16380704)
Reply
I'm glad someone is standing up for what they believe.
Tolerance of a deviant behavior has now become endorsement, and
those who won't endorse are labeled as intolerant and discriminatory.
I'm not for discriminating against anyone if they can do a job well, but
the media has taken things way too far in one direction. I may tolerate
gay behavior, but I will not endorse it (i.e. gay marriage).
(http://mlive.com/)
diaghilev
(http://connect.mlive.com/user/diaghilev/index.html)
Saturday, July 30, 2011, 11:19:41 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-
07-30/16385101)
Reply
That's funny that you mention deviant behavior. If you
attended the average West Michigan / Dutch bachelorette
party, you might be amazed to discover (during drinking
games, etc.) something that has been true for more than a
decade: 90% of the girls "saving themselves for marriage" in
West Michigan have done every other "deviant" act
imaginable. Just not standard intercourse. Because they think
this means they're still chaste. I don't know, maybe it was Bill
Clinton's scandal, whatever... but this is actually happening,
right now. So I'd be careful before throwing too wide a net of
criticism, regarding deviant behavior. Because there are some
*freaks* in Ottawa Co.
(http://mlive.com/)
anon (http://connect.mlive.com/user/123mego/index.html)
Page 8 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive.com
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 68 of 153 Pg ID 1107
Friday, July 29, 2011, 11:32:12 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16380671)
Reply
I hate robocalls!!!!! Anyone using them should lose votes. I wish they
would be banned. Being on the do not call list doesn't help because
political candidates,charities,and any business you have ever done
business with can still call you legally, and many groups call anyway and
hope they can get away with it.
(http://mlive.com/)
jeffhgr (http://connect.mlive.com/user/jeffhgr/index.html)
Friday, July 29, 2011, 10:42:11 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16380103)
Reply
Kevin Rahe has the keywords "gay" and "Holland" in his google alerts,
apparently.
(http://mlive.com/)
Kevin Rahe
(http://connect.mlive.com/user/KevinRahe2/index.html)
Friday, July 29, 2011, 10:48:30 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-
07-30/16380187)
Reply
Never heard of Google Alerts - interesting technology. I get
quite enough e-mail already, though. And it's not like it's hard
to spot news stories on mlive.com that promote the
homosexual agenda.
(http://mlive.com/)
diaghilev
(http://connect.mlive.com/user/diaghilev/index.html)
Saturday, July 30, 2011, 1:35:48 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-
07-30/16381584)
Kevin, you had me at "not like it's hard".
(http://mlive.com/)
Kevin Rahe
(http://connect.mlive.com/user/KevinRahe2/index.html)
Friday, July 29, 2011, 10:29:25 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16379965)
Reply
The script of the call seems quite fair and accurate. And the issue it
speaks of - that the homosexual agenda is a threat to religious freedom
- is real.
(http://mlive.com/)
diaghilev
(http://connect.mlive.com/user/diaghilev/index.html)
Referring to Gary Glenn as "it" denies his personhood. Next
Page 9 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive.com
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 69 of 153 Pg ID 1108
(http://www.mlive.com/tigers/index.
game_winning.html#incart_hbx#incar
of) Tigers' 12-game winning streak
ends against Yankees...
(http://www.mlive.com/tigers/index.
game_winning.html#incart_hbx#incar
of)
(http://www.mlive.com/lansing-
news/index.ssf/2013/08/prank_caller
of) Prank callers falsely say tiger
loose from Lansing...
(http://www.mlive.com/lansing-
news/index.ssf/2013/08/prank_caller
of)
(http://www.mlive.com/lions/index.s
six_helps.html#incart_2box#incart_hb
of) Ansah's pick-six leads Lions over
Jets 26-17
(http://www.mlive.com/lions/index.s
six_helps.html#incart_2box#incart_hb
of)
Best of MLive.com
Saturday, July 30, 2011, 1:45:41 AM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-
07-30/16381637)
Reply
you're going to want to abort him. That's sad.
(http://mlive.com/)
nightfly (http://connect.mlive.com/user/nightfly/index.html)
Friday, July 29, 2011, 9:35:52 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16379374)
Reply
No big deal. I would make occasional visits to Holland for a bite to eat or
do a little shopping but it's no skin off my nose not to set foot in that
town again.
Hope the intolerance works out well for them.
(http://mlive.com/)
MkyMtn (http://connect.mlive.com/user/MkyMtn/index.html)
Friday, July 29, 2011, 9:32:04 PM (http://mlive.com/news/grand-
rapids/index.ssf/2011/07/gary_glenn_steps_into_holland.html/post/2011-07-
30/16379335)
Reply
A religious fruitcake, through and through. Although he will play to a
receptive audience in Holland, where discrimination and intolerance are
considered religious rights.
(http://mlive.com/)
Page 10 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive....
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 70 of 153 Pg ID 1109
(http://www.advancedigital.com/)
Registration on or use of this site constitutes acceptance of our User Agreement (http://www.mlive.com/useragreement/) and Privacy Policy
(http://www.mlive.com/privacypolicy/) (Revised November 1, 2011)
2013 MLive Media Group All rights reserved (About Us (http://www.mlive.com/aboutus/)).
The material on this site may not be reproduced, distributed, transmitted, cached or otherwise used, except with the prior written permission of MLive
Media Group
Community Rules (http://www.mlive.com/forums/index.ssf?rules.html) apply to all content you upload or otherwise submit to this site. Contact
interactivity management. (http://www.mlive.com/forums/index.ssf?rules.html)
Ad Choices (http://www.advance.net/advancedigitalUserAgreementPP/#opt_out)
MLive Media Group
(http://www.mlivemediagroup.com)
Our Team
(http://www.mlivemediagroup.com/about/team/)
Advertise
(http://www.mlive.com/advertise/)
Contact Us
(http://www.mlivemediagroup.com/contact-
us/)
Jobs at MLive
(http://mlivemediagroup.com/jobs/)
FAQ
(http://www.mlive.com/aboutus/index.ssf?/aboutus/content/faq.html)
The Grand Rapids Press (http://www.mlivemediagroup.com/subscribe/grand-rapids-press/)
The Muskegon Chronicle (http://www.mlivemediagroup.com/subscribe/muskegon-chronicle/)
The Kalamazoo Gazette (http://www.mlivemediagroup.com/subscribe/kalamazoo-gazette/)
Jackson Citizen Patriot (http://www.mlivemediagroup.com/subscribe/jackson-citizen-patriot/)
AnnArbor.com (http://www.annarbor.com/newspaper/)
The Flint Journal (http://www.mlivemediagroup.com/subscribe/flint-journal/)
The Saginaw News (http://www.mlivemediagroup.com/subscribe/saginaw-news/)
The Bay City Times (http://www.mlivemediagroup.com/subscribe/bay-city-times/)
About Us
Subscriptions
Newspaper
(http://www.mlivemediagroup.com/subscribe/) |
eReplica (http://www.mlive.com/ereplica/) |
eNewsletters (http://www.mlive.com/enewsletters/)
News
(http://www.mlive.com/news/)
Business
(http://www.mlive.com/business/)
Sports
(http://www.mlive.com/sports/)
High School Sports
(http://highschoolsports.mlive.com/)
Entertainment
(http://www.mlive.com/entertainment/)
Living
(http://www.mlive.com/living/)
Opinion
(http://www.mlive.com/opinion/)
Obituaries
(http://www.mlive.com/deathnotices/)
Jobs
(http://www.mlive.com/jobs/)
Autos
(http://autos.mlive.com/)
Real Estate
(http://realestate.mlive.com/)
Apartment Rentals
(http://realestate.mlive.com/for-
rent/)
Classifieds
(http://classifieds.mlive.com/)
Local Deals
(http://www.mlive.com/deals/)
Local Businesses
(http://businessfinder.mlive.com)
Business Resource
Center
(http://www.mlive.com/business-
resource-center/)
Ann Arbor
(http://www.mlive.com/ann-
arbor/)
Bay City
(http://www.mlive.com/bay-
city/)
Detroit
(http://www.mlive.com/detroit/)
Flint
(http://www.mlive.com/flint/)
Grand Rapids
(http://www.mlive.com/grand-
rapids/)
Jackson
(http://www.mlive.com/jackson/)
Kalamazoo
(http://www.mlive.com/kalamazoo/)
Lansing
(http://www.mlive.com/lansing/)
Muskegon
(http://www.mlive.com/muskegon/)
Saginaw
(http://www.mlive.com/saginaw/)
MLive Sections
Your Regional News Pages
Mobile
Mobile View (http://mobile.mlive.com/) | Mobile
Apps (http://www.mlive.com/mobile-device/) |
Tablet Apps (http://www.mlive.com/mobile-device/)
Forums
(http://www.mlive.com/forums/)
Photos
(http://photos.mlive.com/photogallery/)
Video
(http://videos.mlive.com/)
Weather
(http://www.mlive.com/weather/)
Post a job
(http://www.mlive.com/jobs/)
Post a free classified ad
(http://www.mlive.com/classifieds/free/)
Sell your car
(http://www.mlive.com/placead/)
Sell/Rent your home
(http://www.mlive.com/placead/)
Apartments and Rentals
(http://realestate.mlive.com/for-
rent/)
Site Map
(http://www.mlive.com/sitemap/)
More on MLive
Follow Us
Twitter (http://twitter.com/mlive) |
Facebook (http://facebook.com/mlive) |
Google+
(https://plus.google.com/u/0/118382608325892108926)
Page 11 of 11 Gay rights debate made focus of Holland election with Gary Glenn's robocalls | MLive....
8/10/2013 http://www.mlive.com/news/grand-rapids/index.ssf/2011/07/gary_glenn_steps_into_hollan...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 71 of 153 Pg ID 1110
ATTACHMENT F

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 72 of 153 Pg ID 1111
AFAMI News
American
Freedom Law
Center files brief in
support of its
petition for U.S.
Supreme Court
review of federal
Hate Crimes law
Marriage
amendment
coauthor warns
children will be
harmed and
taxpayers hit with
increased social
costs if federal judge
overturns vote of the
people
An open letter to
homosexuals
Anti-gay-rights
group sends letter to
Jackson City
Council
AFA-Michigan
President Gary
Glenn participates in
forum on
employment
benefits for
unmarried
partners
Bill Maher And
Andrew Sullivan
Argue Against Hate
Crime Laws
AFA-Michigan
President Gary
Glenn speaks at
Religious Freedom
Rally
Help AFA-
Michigan protect
and promote
traditional family
values and religious
freedom
Testimony to AFA-Michigans effective stand for
traditional family values
February 11, 2012
An ongoing testimony to AFA-Michigans effective stand for
traditional family values- AFA-Michigan President Gary Glenn
CONSIDER In fact, Michigan has only become more hostile
towards same sex couples over the past few months. After an
amendment to our state constitution passed as a referendum in
2004, our state became the first in the nation to ban not only gay
marriage, but also civil unions and any other contract affording
benefits to a same sex couple. On the state level, Michigan
provides no protection against discrimination based on sexual
orientation.
. . . Many of you may also have heard about House Bill 4770,
which bans public institutions in Michigan from offering domestic
partner benefits; this will likely have serious consequences for
professors here at the university.
From a legal standpoint, Michigan is objectively the most hostile
environment for non-hetero people to live.
Read more here
Abortion
Eminent Domain
Homosexual Agenda
AFL-CIO
Boy Scouts
Public Health
In The News
Marriage
News Releases
Pornography
Public Schools and
Universities
Religious Freedom
Religious Heritage
Select Month
Page 1 of 2 AFA Michigan Testimony to AFA-Michigans effective stand for traditional family val...
8/10/2013 http://www.afamichigan.org/2012/02/11/testimony-to-afa-michigans-effective-stand-for-tr...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 73 of 153 Pg ID 1112
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 4, 2013
Conservatives
plot to roll back
LGBT protections
AFA-Michigan
opposes anti-
discrimination law
Search
Search
site designed and hosted by: OptimusMedia.com
Page 2 of 2 AFA Michigan Testimony to AFA-Michigans effective stand for traditional family val...
8/10/2013 http://www.afamichigan.org/2012/02/11/testimony-to-afa-michigans-effective-stand-for-tr...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 74 of 153 Pg ID 1113
ATTACHMENT G

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 75 of 153 Pg ID 1114
PROPOSAL 04-2: Same-sex Marriage Ban
Proposal 04-2 would recognize marriage as only between one man and one woman and prohibit any legal status
similar to marriage.
Subject: Gay & Lesbian Rights - Marriage
Status: PASSED
Home > Michigan 2004 > Ballot Measures > PROPOSAL 04-2: Same-sex Marriage Ban
Overview Candidates Contributors Ballot Measures Party Committees General Election Results Data Sources
Ballot Measure Summary
return to top
Ballot Measure Committees
TABLE 1: Ballot Measure Committees
Ballot Committee Records Total
Pro Ballot Committees
CITIZENS FOR THE PROTECTION OF
MARRIAGE
1177 $1,627,561
FAMILY RESEARCH COUNCIL 2 $186,397
FOCUS ON THE FAMILY 11 $73,649
OAKLAND CITIZENS TO PROTECT MARRIAGE 138 $27,397
MICHIGAN CITIZENS VOTING YES FOR
MARRIAGE
3 $7,000
TRADITIONAL MARRIAGE CRUSADE 160 $4,906
MARRIAGE IN THE PUBLIC INTEREST CMTE 1 $4,500
Pro Total: $1,931,409
Con Ballot Committees
COALITION FOR A FAIR MICHIGAN 1360 $854,212
Con Total: $854,212
Overall Total: $2,785,621
return to top
Page 1 of 2 PROPOSAL 04-2: Same-sex Marriage Ban | Follow The Money
8/10/2013 http://www.followthemoney.org/database/StateGlance/ballot.phtml?m=321
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 76 of 153 Pg ID 1115
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 6, 2013
http://www.followthemoney.org/database/StateGlance/ballot.phtml?m=321
833 N. Last Chance Gulch -- Helena, MT 59601
Phone: (406) 449-2480 | (406) 457-2091 (fax)
Copyright 1999-2013 National Institute on Money in State Politics
Content on this site is licensed under a Creative Commons Attribution-Noncommercial-Share Alike 3.0 United States License by the National Institute on Money in State Politics.
Page 2 of 2 PROPOSAL 04-2: Same-sex Marriage Ban | Follow The Money
8/10/2013 http://www.followthemoney.org/database/StateGlance/ballot.phtml?m=321
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 77 of 153 Pg ID 1116
CITIZENS FOR THE PROTECTION OF
MARRIAGE (Multi-Year Profile)
Disclosure Reports Collected:
4/4
See the Grid
Home > Michigan 2004 > Ballot Measures > CITIZENS FOR THE PROTECTION OF MARRIAGE
Overview Candidates Contributors Ballot Measures Party Committees General Election Results Data Sources
Committee Summary
Total Raised to Date: $1,627,561
Records: 1177 (See all Records)
TABLE 1: Supported or Opposed Ballot Measures
Ballot Measures
Pro
PROPOSAL 04-2: Same-sex Marriage Ban
return to top
Top Contributors
Page 1 of 5 CITIZENS FOR THE PROTECTION OF MARRIAGE | Follow The Money
8/10/2013 http://www.followthemoney.org/database/StateGlance/committee.phtml?c=1068
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 78 of 153 Pg ID 1117
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 6, 2013
TABLE 2: Top 20 Contributors
Contributor Total
% of
Total
Sector
ARCHDIOCESE OF DETROIT $538,100 33.06%
Government
Agencies/Education/Other
See Records
FAMILY RESEARCH COUNCIL $190,000 11.67% Ideology/Single Issue See Records
DIOCESE OF LANSING $133,350 8.19%
Government
Agencies/Education/Other
See Records
DIOCESE OF GRAND RAPIDS $106,100 6.52%
Government
Agencies/Education/Other
See Records
DIOCESE OF SAGINAW $87,500 5.38%
Government
Agencies/Education/Other
See Records
PRINCE-BROEKHUIZEN, ELSA $75,000 4.61% Ideology/Single Issue See Records
MICHIGAN FAMILY FORUM $68,386 4.20% Ideology/Single Issue See Records
DIOCESE OF GAYLORD $49,250 3.03%
Government
Agencies/Education/Other
See Records
DIOCESE OF KALAMAZOO $47,450 2.92%
Government
Agencies/Education/Other
See Records
DIOCESE OF MARQUETTE $38,250 2.35%
Government
Agencies/Education/Other
See Records
LEE, WILLIAM $35,500 2.18% Communications & Electronics See Records
CITIZENS FOR TRADITIONAL
VALUES
$27,000 1.66% Ideology/Single Issue See Records
EASTERN MICHIGAN DISTRICT
CHURCH OF THE NAZARENE
$25,000 1.54%
Government
Agencies/Education/Other
See Records
DEVOS SR, RICHARD M $20,000 1.23% General Business See Records
DEWAN, MICHAEL $20,000 1.23%
Government
Agencies/Education/Other
See Records
DEVOS, MARIA P $15,000 0.92% General Business See Records
DEVOS, DOUGLAS L $15,000 0.92% General Business See Records
PUBLIC INTEREST FORUM $15,000 0.92% Ideology/Single Issue See Records
KELLY, DANIEL $6,461 0.40%
Finance, Insurance & Real
Estate
See Records
THE TIMMIS FAMILY
FOUNDATION
$5,000 0.31% Ideology/Single Issue See Records
Page 2 of 5 CITIZENS FOR THE PROTECTION OF MARRIAGE | Follow The Money
8/10/2013 http://www.followthemoney.org/database/StateGlance/committee.phtml?c=1068
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 79 of 153 Pg ID 1118
TABLE 3: Top 15 Industries
Top Industries Total
Clergy $1,036,323
Christian Conservative $383,441
Retail Sales $50,000
Computer Equipment & Services $35,700
Retired $29,215
Accountants $7,461
Home Builders $6,209
Miscellaneous Manufacturing & Distributing $5,300
Securities & Investment $5,000
Waste Management $5,000
Miscellaneous Services $5,000
Civil Servants/Public Officials $4,367
Business Services $3,372
Construction Services $3,000
Automotive $3,000
return to top
Contributions by Economic Interest
FIGURE A: Sector Breakdown
Page 3 of 5 CITIZENS FOR THE PROTECTION OF MARRIAGE | Follow The Money
8/10/2013 http://www.followthemoney.org/database/StateGlance/committee.phtml?c=1068
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 80 of 153 Pg ID 1119
View Selected Contributions View All Contributions
TABLE 4: Contributions
Sector Records Total
% of
Total
Agriculture 2 $1,580 0.10%
Candidate Contributions 2 $110 0.01%
Communications & Electronics 8 $36,350 2.23%
Construction 10 $10,209 0.63%
Energy & Natural Resources 1 $5,000 0.31%
Finance, Insurance & Real Estate 7 $14,776 0.91%
General Business 17 $64,257 3.95%
Government Agencies/Education/Other 78 $1,070,406 65.77%
Health 1 $250 0.02%
Ideology/Single Issue 25 $383,441 23.56%
Lawyers & Lobbyists 10 $2,950 0.18%
Non-Contributions 1 $979 0.06%
Transportation 3 $3,000 0.18%
Uncoded 1,012 $34,252 2.10%
Total: 1,177 $1,627,561 100%
return to top
Contributions by Contributor Type
FIGURE B: Contributor Type Breakdown
FIGURE C: Individual Vs. Institutional
return to top
Contributions by Geographic Location
FIGURE D: Location Breakdown
Page 4 of 5 CITIZENS FOR THE PROTECTION OF MARRIAGE | Follow The Money
8/10/2013 http://www.followthemoney.org/database/StateGlance/committee.phtml?c=1068
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 81 of 153 Pg ID 1120
http://www.followthemoney.org/database/StateGlance/committee.phtml?c=1068
833 N. Last Chance Gulch -- Helena, MT 59601
Phone: (406) 449-2480 | (406) 457-2091 (fax)
Copyright 1999-2013 National Institute on Money in State Politics
Content on this site is licensed under a Creative Commons Attribution-Noncommercial-Share Alike 3.0 United States License by the National Institute on Money in State Politics.
TABLE 5: Top 15 Cities View by : City State Zip
City, State Total
Detroit, MI $543,393
Lansing, MI $252,571
Washington, DC $190,000
Grand Rapids, MI $157,774
Saginaw, MI $124,734
Holland, MI $75,400
Gaylord, MI $49,310
Kalamazoo, MI $48,320
Marquette, MI $38,250
Fenton, MI $26,105
Bloomfield Hills, MI $21,840
Pinckney, MI $20,120
Flint, MI $5,553
Southfield, MI $5,160
Zeeland, MI $5,085
return to top
Page 5 of 5 CITIZENS FOR THE PROTECTION OF MARRIAGE | Follow The Money
8/10/2013 http://www.followthemoney.org/database/StateGlance/committee.phtml?c=1068
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 82 of 153 Pg ID 1121
ATTACHMENT H

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 83 of 153 Pg ID 1122
CONGREGATION FOR THE DOCTRINE OF THE FAITH
CONSIDERATIONS REGARDING PROPOSALS
TO GIVE LEGAL RECOGNITION
TO UNIONS
BETWEEN HOMOSEXUAL PERSONS
INTRODUCTION
1. In recent years, various questions relating to homosexuality have been addressed with
some frequency by Pope John Paul II and by the relevant Dicasteries of the Holy See.(1)
Homosexuality is a troubling moral and social phenomenon, even in those countries where it
does not present significant legal issues. It gives rise to greater concern in those countries
that have granted or intend to grant legal recognition to homosexual unions, which may
include the possibility of adopting children. The present Considerations do not contain new
doctrinal elements; they seek rather to reiterate the essential points on this question and
provide arguments drawn from reason which could be used by Bishops in preparing more
specific interventions, appropriate to the different situations throughout the world, aimed at
protecting and promoting the dignity of marriage, the foundation of the family, and the
stability of society, of which this institution is a constitutive element. The present
Considerations are also intended to give direction to Catholic politicians by indicating the
approaches to proposed legislation in this area which would be consistent with Christian
conscience.(2) Since this question relates to the natural moral law, the arguments that follow
are addressed not only to those who believe in Christ, but to all persons committed to
promoting and defending the common good of society.
I. THE NATURE OF MARRIAGE
AND ITS INALIENABLE CHARACTERISTICS
2. The Church's teaching on marriage and on the complementarity of the sexes reiterates a
truth that is evident to right reason and recognized as such by all the major cultures of the
world. Marriage is not just any relationship between human beings. It was established by the
Creator with its own nature, essential properties and purpose.(3) No ideology can erase from
the human spirit the certainty that marriage exists solely between a man and a woman, who
by mutual personal gift, proper and exclusive to themselves, tend toward the communion of
their persons. In this way, they mutually perfect each other, in order to cooperate with God in
the procreation and upbringing of new human lives.
Page 1 of 7 Considerations Regarding Proposals To Give Legal Recognition To Unions Between Ho...
8/10/2013 http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_20...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 84 of 153 Pg ID 1123
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 5, 2013
3. The natural truth about marriage was confirmed by the Revelation contained in the biblical
accounts of creation, an expression also of the original human wisdom, in which the voice of
nature itself is heard. There are three fundamental elements of the Creator's plan for
marriage, as narrated in the Book of Genesis.
In the first place, man, the image of God, was created male and female (Gen 1:27). Men
and women are equal as persons and complementary as male and female. Sexuality is
something that pertains to the physical-biological realm and has also been raised to a new
level the personal level where nature and spirit are united.
Marriage is instituted by the Creator as a form of life in which a communion of persons is
realized involving the use of the sexual faculty. That is why a man leaves his father and
mother and clings to his wife and they become one flesh (Gen 2:24).
Third, God has willed to give the union of man and woman a special participation in his
work of creation. Thus, he blessed the man and the woman with the words Be fruitful and
multiply (Gen 1:28). Therefore, in the Creator's plan, sexual complementarity and
fruitfulness belong to the very nature of marriage.
Furthermore, the marital union of man and woman has been elevated by Christ to the dignity
of a sacrament. The Church teaches that Christian marriage is an efficacious sign of the
covenant between Christ and the Church (cf. Eph 5:32). This Christian meaning of marriage,
far from diminishing the profoundly human value of the marital union between man and
woman, confirms and strengthens it (cf. Mt 19:3-12; Mk 10:6-9).
4. There are absolutely no grounds for considering homosexual unions to be in any way
similar or even remotely analogous to God's plan for marriage and family. Marriage is holy,
while homosexual acts go against the natural moral law. Homosexual acts close the sexual
act to the gift of life. They do not proceed from a genuine affective and sexual
complementarity. Under no circumstances can they be approved.(4)
Sacred Scripture condemns homosexual acts as a serious depravity... (cf. Rom 1:24-27; 1
Cor 6:10; 1 Tim 1:10). This judgment of Scripture does not of course permit us to conclude
that all those who suffer from this anomaly are personally responsible for it, but it does attest
to the fact that homosexual acts are intrinsically disordered.(5) This same moral judgment is
found in many Christian writers of the first centuries(6) and is unanimously accepted by
Catholic Tradition.
Nonetheless, according to the teaching of the Church, men and women with homosexual
tendencies must be accepted with respect, compassion and sensitivity. Every sign of unjust
discrimination in their regard should be avoided.(7) They are called, like other Christians, to
live the virtue of chastity.(8) The homosexual inclination is however objectively
disordered(9) and homosexual practices are sins gravely contrary to chastity.(10)
II. POSITIONS ON THE PROBLEM
OF HOMOSEXUAL UNIONS
Page 2 of 7 Considerations Regarding Proposals To Give Legal Recognition To Unions Between Ho...
8/10/2013 http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_20...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 85 of 153 Pg ID 1124
5. Faced with the fact of homosexual unions, civil authorities adopt different positions. At
times they simply tolerate the phenomenon; at other times they advocate legal recognition of
such unions, under the pretext of avoiding, with regard to certain rights, discrimination
against persons who live with someone of the same sex. In other cases, they favour giving
homosexual unions legal equivalence to marriage properly so-called, along with the legal
possibility of adopting children.
Where the government's policy is de facto tolerance and there is no explicit legal recognition
of homosexual unions, it is necessary to distinguish carefully the various aspects of the
problem. Moral conscience requires that, in every occasion, Christians give witness to the
whole moral truth, which is contradicted both by approval of homosexual acts and unjust
discrimination against homosexual persons. Therefore, discreet and prudent actions can be
effective; these might involve: unmasking the way in which such tolerance might be
exploited or used in the service of ideology; stating clearly the immoral nature of these
unions; reminding the government of the need to contain the phenomenon within certain
limits so as to safeguard public morality and, above all, to avoid exposing young people to
erroneous ideas about sexuality and marriage that would deprive them of their necessary
defences and contribute to the spread of the phenomenon. Those who would move from
tolerance to the legitimization of specific rights for cohabiting homosexual persons need to
be reminded that the approval or legalization of evil is something far different from the
toleration of evil.
In those situations where homosexual unions have been legally recognized or have been
given the legal status and rights belonging to marriage, clear and emphatic opposition is a
duty. One must refrain from any kind of formal cooperation in the enactment or application
of such gravely unjust laws and, as far as possible, from material cooperation on the level of
their application. In this area, everyone can exercise the right to conscientious objection.
III. ARGUMENTS FROM REASON AGAINST LEGAL
RECOGNITION OF HOMOSEXUAL UNIONS
6. To understand why it is necessary to oppose legal recognition of homosexual unions,
ethical considerations of different orders need to be taken into consideration.
From the order of right reason
The scope of the civil law is certainly more limited than that of the moral law,(11) but civil
law cannot contradict right reason without losing its binding force on conscience.(12) Every
humanly-created law is legitimate insofar as it is consistent with the natural moral law,
recognized by right reason, and insofar as it respects the inalienable rights of every person.
(13) Laws in favour of homosexual unions are contrary to right reason because they confer
legal guarantees, analogous to those granted to marriage, to unions between persons of the
same sex. Given the values at stake in this question, the State could not grant legal standing
to such unions without failing in its duty to promote and defend marriage as an institution
essential to the common good.
It might be asked how a law can be contrary to the common good if it does not impose any
particular kind of behaviour, but simply gives legal recognition to a de facto reality which
Page 3 of 7 Considerations Regarding Proposals To Give Legal Recognition To Unions Between Ho...
8/10/2013 http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_20...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 86 of 153 Pg ID 1125
does not seem to cause injustice to anyone. In this area, one needs first to reflect on the
difference between homosexual behaviour as a private phenomenon and the same behaviour
as a relationship in society, foreseen and approved by the law, to the point where it becomes
one of the institutions in the legal structure. This second phenomenon is not only more
serious, but also assumes a more wide-reaching and profound influence, and would result in
changes to the entire organization of society, contrary to the common good. Civil laws are
structuring principles of man's life in society, for good or for ill. They play a very important
and sometimes decisive role in influencing patterns of thought and behaviour.(14) Lifestyles
and the underlying presuppositions these express not only externally shape the life of society,
but also tend to modify the younger generation's perception and evaluation of forms of
behaviour. Legal recognition of homosexual unions would obscure certain basic moral values
and cause a devaluation of the institution of marriage.
From the biological and anthropological order
7. Homosexual unions are totally lacking in the biological and anthropological elements of
marriage and family which would be the basis, on the level of reason, for granting them legal
recognition. Such unions are not able to contribute in a proper way to the procreation and
survival of the human race. The possibility of using recently discovered methods of artificial
reproduction, beyond involv- ing a grave lack of respect for human dignity,(15) does nothing
to alter this inadequacy.
Homosexual unions are also totally lacking in the conjugal dimension, which represents the
human and ordered form of sexuality. Sexual relations are human when and insofar as they
express and promote the mutual assistance of the sexes in marriage and are open to the
transmission of new life.
As experience has shown, the absence of sexual complementarity in these unions creates
obstacles in the normal development of children who would be placed in the care of such
persons. They would be deprived of the experience of either fatherhood or motherhood.
Allowing children to be adopted by persons living in such unions would actually mean doing
violence to these children, in the sense that their condition of dependency would be used to
place them in an environment that is not conducive to their full human development. This is
gravely immoral and in open contradiction to the principle, recognized also in the United
Nations Convention on the Rights of the Child, that the best interests of the child, as the
weaker and more vulnerable party, are to be the paramount consideration in every case.
From the social order
8. Society owes its continued survival to the family, founded on marriage. The inevitable
consequence of legal recognition of homosexual unions would be the redefinition of
marriage, which would become, in its legal status, an institution devoid of essential reference
to factors linked to heterosexuality; for example, procreation and raising children. If, from
the legal standpoint, marriage between a man and a woman were to be considered just one
possible form of marriage, the concept of marriage would undergo a radical transformation,
with grave detriment to the common good. By putting homosexual unions on a legal plane
analogous to that of marriage and the family, the State acts arbitrarily and in contradiction
with its duties.
Page 4 of 7 Considerations Regarding Proposals To Give Legal Recognition To Unions Between Ho...
8/10/2013 http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_20...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 87 of 153 Pg ID 1126
The principles of respect and non-discrimination cannot be invoked to support legal
recognition of homosexual unions. Differentiating between persons or refusing social
recognition or benefits is unacceptable only when it is contrary to justice.(16) The denial of
the social and legal status of marriage to forms of cohabitation that are not and cannot be
marital is not opposed to justice; on the contrary, justice requires it.
Nor can the principle of the proper autonomy of the individual be reasonably invoked. It is
one thing to maintain that individual citizens may freely engage in those activities that
interest them and that this falls within the common civil right to freedom; it is something
quite different to hold that activities which do not represent a significant or positive
contribution to the development of the human person in society can receive specific and
categorical legal recognition by the State. Not even in a remote analogous sense do
homosexual unions fulfil the purpose for which marriage and family deserve specific
categorical recognition. On the contrary, there are good reasons for holding that such unions
are harmful to the proper development of human society, especially if their impact on society
were to increase.
From the legal order
9. Because married couples ensure the succession of generations and are therefore eminently
within the public interest, civil law grants them institutional recognition. Homosexual unions,
on the other hand, do not need specific attention from the legal standpoint since they do not
exercise this function for the common good.
Nor is the argument valid according to which legal recognition of homosexual unions is
necessary to avoid situations in which cohabiting homosexual persons, simply because they
live together, might be deprived of real recognition of their rights as persons and citizens. In
reality, they can always make use of the provisions of law like all citizens from the
standpoint of their private autonomy to protect their rights in matters of common interest. It
would be gravely unjust to sacrifice the common good and just laws on the family in order to
protect personal goods that can and must be guaranteed in ways that do not harm the body of
society.(17)
IV. POSITIONS OF CATHOLIC POLITICIANS
WITH REGARD TO LEGISLATION IN FAVOUR
OF HOMOSEXUAL UNIONS
10. If it is true that all Catholics are obliged to oppose the legal recognition of homosexual
unions, Catholic politicians are obliged to do so in a particular way, in keeping with their
responsibility as politicians. Faced with legislative proposals in favour of homosexual
unions, Catholic politicians are to take account of the following ethical indications.
When legislation in favour of the recognition of homosexual unions is proposed for the first
time in a legislative assembly, the Catholic law-maker has a moral duty to express his
opposition clearly and publicly and to vote against it. To vote in favour of a law so harmful
to the common good is gravely immoral.
Page 5 of 7 Considerations Regarding Proposals To Give Legal Recognition To Unions Between Ho...
8/10/2013 http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_20...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 88 of 153 Pg ID 1127
When legislation in favour of the recognition of homosexual unions is already in force, the
Catholic politician must oppose it in the ways that are possible for him and make his
opposition known; it is his duty to witness to the truth. If it is not possible to repeal such a
law completely, the Catholic politician, recalling the indications contained in the Encyclical
Letter Evangelium vitae, could licitly support proposals aimed at limiting the harm done by
such a law and at lessening its negative consequences at the level of general opinion and
public morality, on condition that his absolute personal opposition to such laws was clear
and well known and that the danger of scandal was avoided.(18) This does not mean that a
more restrictive law in this area could be considered just or even acceptable; rather, it is a
question of the legitimate and dutiful attempt to obtain at least the partial repeal of an unjust
law when its total abrogation is not possible at the moment.
CONCLUSION
11. The Church teaches that respect for homosexual persons cannot lead in any way to
approval of homosexual behaviour or to legal recognition of homosexual unions. The
common good requires that laws recognize, promote and protect marriage as the basis of the
family, the primary unit of society. Legal recognition of homosexual unions or placing them
on the same level as marriage would mean not only the approval of deviant behaviour, with
the consequence of making it a model in present-day society, but would also obscure basic
values which belong to the common inheritance of humanity. The Church cannot fail to
defend these values, for the good of men and women and for the good of society itself.
The Sovereign Pontiff John Paul II, in the Audience of March 28, 2003, approved the present
Considerations, adopted in the Ordinary Session of this Congregation, and ordered their
publication.
Rome, from the Offices of the Congregation for the Doctrine of the Faith, June 3, 2003,
Memorial of Saint Charles Lwanga and his Companions, Martyrs.
Joseph Card. Ratzinger
Prefect
Angelo Amato, S.D.B.
Titular Archbishop of Sila
Secretary
NOTES
(1) Cf. John Paul II, Angelus Messages of February 20, 1994, and of June 19, 1994; Address
to the Plenary Meeting of the Pontifical Council for the Family (March 24, 1999); Catechism
of the Catholic Church, Nos. 2357-2359, 2396; Congregation for the Doctrine of the Faith,
Declaration Persona humana (December 29, 1975), 8; Letter on the pastoral care of
homosexual persons (October 1, 1986); Some considerations concerning the response to
legislative proposals on the non-discrimination of homosexual persons (July 24, 1992);
Page 6 of 7 Considerations Regarding Proposals To Give Legal Recognition To Unions Between Ho...
8/10/2013 http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_20...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 89 of 153 Pg ID 1128
Pontifical Council for the Family, Letter to the Presidents of the Bishops' Conferences of
Europe on the resolution of the European Parliament regarding homosexual couples (March
25, 1994); Family, marriage and de facto unions (July 26, 2000), 23.
(2) Cf. Congregation for the Doctrine of the Faith, Doctrinal Note on some questions
regarding the participation of Catholics in political life (November 24, 2002), 4.
(3) Cf. Second Vatican Council, Pastoral Constitution Gaudium et spes, 48.
(4) Catechism of the Catholic Church, No. 2357.
(5) Congregation for the Doctrine of the Faith, Declaration Persona humana (December 29,
1975), 8.
(6) Cf., for example, St. Polycarp, Letter to the Philippians, V, 3; St. Justin Martyr, First
Apology, 27, 1-4; Athenagoras, Supplication for the Christians, 34.
(7) Catechism of the Catholic Church, No. 2358; cf. Congregation for the Doctrine of the
Faith, Letter on the pastoral care of homosexual persons (October 1, 1986), 10.
(8) Cf. Catechism of the Catholic Church, No. 2359; cf. Congregation for the Doctrine of the
Faith, Letter on the pastoral care of homosexual persons (October 1, 1986), 12.
(9) Catechism of the Catholic Church, No. 2358.
(10) Ibid., No. 2396.
(11) Cf. John Paul II, Encyclical Letter Evangelium vitae (March 25, 1995), 71.
(12) Cf. ibid., 72.
(13) Cf. St. Thomas Aquinas, Summa Theologiae, I-II, q. 95, a. 2.
(14) John Paul II, Encyclical Letter Evangelium vitae (March 25, 1995), 90.
(15) Cf. Congregation for the Doctrine of the Faith, Instruction Donum vitae (February 22,
1987), II. A. 1-3.
(16) Cf. St. Thomas Aquinas, Summa Theologiae, II-II, q. 63, a.1, c.
(17) It should not be forgotten that there is always a danger that legislation which would
make homosexuality a basis for entitlements could actually encourage a person with a
homosexual orientation to declare his homosexuality or even to seek a partner in order to
exploit the provisions of the law (Congregation for the Doctrine of the Faith, Some
considerations concerning the response to legislative proposals on the non-discrimination of
homosexual persons [July 24, 1992], 14).
(18) John Paul II, Encyclical Letter Evangelium vitae (March 25, 1995), 73.
Page 7 of 7 Considerations Regarding Proposals To Give Legal Recognition To Unions Between Ho...
8/10/2013 http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_20...
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 90 of 153 Pg ID 1129
ATTACHMENT I

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 91 of 153 Pg ID 1130
Family Research Council (http://www.frc.org/)
Issues (http://www.frc.org/Issues)
Life (http://www.frc.org/Life)
Marriage and Family (http://www.frc.org/Marriage-and-Family)
Religious Liberty (http://www.frc.org/Religious-Liberty)
Radio (http://www.frc.org/get.cfm?c=RADIO)
Events (http://www.frc.org/events)
Action (http://www.frc.org/action)
Blog (http://www.frcblog.com)
About (http://www.frc.org/about-frc)
More (http://www.frc.org/)
Who are you?
Activist (http://www.frc.org/action)
Media (http://www.frc.org/media)
Pastor (http://www.watchmenpastors.org)
Researcher (http://marri.us)
Students (http://www.frc.org/internships)
New to FRC? (http://www.frc.org/about-frc)
State Groups (http://www.frc.org/state-policy-organizations)
Contact Officials (https://www.votervoice.net/FRCA/Directory)
Facebook
FRC (http://www.facebook.com/familyresearchcouncil)
Tony Perkins (http://www.facebook.com/tony.perkins1?ref=ts&fref=ts)
Call2Fall (http://www.facebook.com/call2fall?ref=ts&fref=ts)
FRC Action (http://www.facebook.com/FRCAction?ref=ts&fref=ts)
MARRI (http://www.facebook.com/marriresearch?ref=ts&fref=ts)
Stem Cell Research Facts (http://www.facebook.com/stemcellresearchfacts)
Watchmen Pastors (http://www.facebook.com/WatchmenPastors?ref=ts&fref=ts)
Twitter
FRC (http://twitter.com/FRCdc)
MARRI (https://twitter.com/marriresearch)
Call2Fall (https://twitter.com/Call2Fall)
FRC Action (https://twitter.com/FRCAction)
Watchmen Pastors (https://twitter.com/WatchmenPastors)
Tony Perkins (http://twitter.com/tperkins)
Gen. Jerry Boykin (https://twitter.com/GenBoykin)
Ken Blackwell (https://twitter.com/kenblackwell)
Rob Schwarzwalder (http://twitter.com/SchwarzSpeaks)
Tom McClusky (http://twitter.com/TMcClusky)
Peter Sprigg (http://twitter.com/spriggfrc)
JP Duffy (http://twitter.com/jpduffy)
About FRC
Vision & Mission Statements
(http://www.frc.org/mission-statement)
History
(http://www.frc.org/historymission)
FRC Staff (http://www.frc.org/experts)
FAQs (http://www.frc.org/faqs)
Directions (http://www.frc.org/directions-
to-frc)
Employment
(http://www.frc.org/employment)
Job Listings (http://www.frc.org/job-
listings)
Volunteer (http://www.frc.org/volunteer)
Internships
(http://www.frc.org/internships)
(https://portal.frc.org/process.cfm?get=item&load=input_item&item_code=WX13B02)
History of Family Research
Council
Thirty Years of Advancing Faith, Family
and Freedom
When Family Research Council opened its doors in 1983, official Washington paid it little attention.
After all, cause-oriented nonprofits are a dime a dozen in the nation's capital, new policy shops come
and go, and most wither away over time.
(https://portal.frc.org/process.cfm?get=item&load=input_item&item_code=PG13B02)
Donate (http://www.frc.org/contribute)
Go Search
Page 1 of 3 Family Research Council
8/10/2013 http://www.frc.org/historymission
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 92 of 153 Pg ID 1131
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 6, 2013
Employment Inquiries
(http://www.frc.org/employment-
inquiries)
How Your Gifts Help
(http://www.frc.org/how-your-gifts-help)
Contact Us (http://www.frc.org/contact-
frc)
Stay Informed
eSubscriptions (http://www.frc.org/ways-
to-connect)
Podcasts (http://www.frc.org/podcasts)
RSS Feeds (http://www.frc.org/rss-
feeds)
Twitter (http://twitter.com/FRCdc)
Facebook
(http://www.facebook.com/familyresearchcouncil)
Not Family Research Council. FRC would prove to have lasting influence on the affairs of the nation.
In time, FRC became one of America's most creative and effective policy organizations.
The Early Years
The seeds for FRC's growth were planted in a time of turmoil and watered
with work and prayer. After attending a research planning meeting for
President Carter's 1980 White House Conference on Families, Dr. James
Dobson met and prayed with a group of eight Christian leaders at a
Washington hotel. From that beginning resolve was formed to establish
Family Research Council, and one of those present that night, Gerald P.
Regier, became our first president. FRC's immediate goal was to counter
the credentialed voices arrayed against life and family with equally capable
men and women of faith.
Drawing upon his experience at the Department of Health and Human Services in the Reagan
administration, Regier developed fresh means to link pro-family experts with government research and
policy making offices. He arranged for Congressional testimony, provided reports to elected officials,
amassed evidence for legal briefs on family issues, helped secure appointments on government
panels, and offered media commentary. This foundational work formed the core for FRC's long-term
success.
Rolling Up the Sleeves
In 1988 FRC merged with and became a division of Focus on the Family. Gary L. Bauer, former Under
Secretary of Education and domestic policy adviser to President Reagan, assumed leadership of FRC.
With an infusion of funding from a generous family, he immediately helped raise its public profile and
impact. With new battles over a national child care system and the arrival of the Clinton administration,
FRC was thrust into the midst of several social issue debates that gripped the nation.
In response, Bauer gave close attention to building a national network of concerned citizens and
educated activists eager to engage the national issues. Throughout the 1990s FRC's expert and
grassroots networks grew exponentially.
FRC moved to establish permanent bases from which to fight for "the permanent things." Thanks to
the generosity of the DeVos and Prince families of Western Michigan, a home office was established
in the heart of a revitalized Washington, D.C., and a dynamic distribution center was opened in
Holland, Michigan. This strategic presence distinguishes FRC and its intention to make a lasting
difference for timeless values across our land. Today our Washington home at Gallery Place stands at
the hub of a thriving city, a sign of our determination to preserve and advance the heritage of religious
belief and family values handed down from generation to generation.
In 1992, FRC made another strategic decision that afforded it greater scope, once again becoming an
independent nonprofit. An independent board was created, sharing three members, including Dr.
Dobson, with the board of directors of Focus on the Family.
Standing Strong in a New Era
In 2000, FRC's board of directors appointed Kenneth L. Connor -- a prominent Florida attorney and
national pro-life leader -- as our third president.
During his time at the helm, Connor sought to sharpen FRC's public policy
agenda, with special focus on the sanctity of human life, defense of man-woman
marriage, humane elder care, religious liberty, parental choice in education, and
family tax relief.
Connor also sought to ensure that FRC would be better known for what it
advocated than what it opposed. He attracted prominent scholars to partner with
FRC, spoke passionately for the most vulnerable members of society, and promoted the highly
respected Witherspoon Fellowship. Under his leadership the Fellowship rose to new influence as a
Biblically-based, semester-long academic and practical training ground for future cultural and civic
leaders.
Emboldening Pastoral Voices for Faith and Family
Page 2 of 3 Family Research Council
8/10/2013 http://www.frc.org/historymission
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 93 of 153 Pg ID 1132
Tony began his tenure at FRC just as the nationwide struggle to preserve man-
woman marriage exploded. With the unprecedented decision of Massachusetts'
highest court, a new issue was joined and the stakes in the judicial confirmation
process at the federal level were raised another notch. To all this Tony brought
the profound conviction that campaigns to protect the family and the church
could not succeed without a renewal of cultural engagement among the
pastorate.
Guided by this vision, FRC established Church Ministries, its first new
department in nearly a decade, to reach out to pastors and to equip and embolden them. At a time of
global political uncertainty where foundational institutions are endangered as never before, where
marriage is undermined and human life itself is being redefined, leaders must stand strong in the
pulpits as well as the halls of power.
As FRC deepens its mission and renews its vision, we look forward with hope and confidence to the
future.
Today our policy department is assembling a new team of credentialed experts equipped with cutting-
edge analysis and research. Our government affairs division, recognized by friend and foe alike for its
excellence and character, is a force on Capitol Hill and in the Executive Branch. Our communications
team and the spokesmen it puts forward daily have become the "family voice" of choice for the national
and even international media.
FRC is going wherever technology will carry words and images. Through broadcast video, the Internet,
and radio, via RSS feeds and IPod downloads, by guest editorials and print interviews, through legal
briefs and on-campus debates, using sermon notes and even tracking votes, FRC is making the cause
of faith, family and freedom real and immediate. Not content to champion our cause for this day only,
we continue to work with the rising generation through student internships to make a permanent home
for family advocacy here at the seat of national government.
Thanks to the vision and dedication of its founders and leaders, past and present, along with the
faithful prayers and generosity of its friends, today's Family Research Council continues to bring
evidence and argument to the public square. We have had the privilege for 30 years to champion all
that the Author of Life has given us. We ask His blessing anew as we strive to preserve His gifts of
faith, family and freedom for years to come.
Subscribe to the Washington Update
Go
Ways To Connect With FRC (http://www.frc.org/ways-to-connect) Make a Donation to FRC (http://www.frc.org/donate)

RT ashleyskidmore @ : So
thankful for my friend and
coworker Leo.
weeklystandard.com/articles/m
edia SPLC # hatemap #
corkins # tcot # Marriage #
FRC FRCdc @
RT cmarlink @ : Every-day
courage ow.ly/nMrxD
FRC FRCdc @
14h
16h
Tweets
Follow @FRCdc
Tweet to @FRCdc
Join the Conversation
(http://www.twitter.com/FRCdc)
(http://www.frc.org/)
2012 Family Research Council 801 G Street
NW, Washington, D.C. 20001
1-800/225-4008 (tel:+18002254008)
Contact Us (http://www.frc.org/contact-frc)
Privacy Policy (new.frc.org)
Facebook (http://www.frc.org/facebook)
Twitter (http://twitter.com/FRCdc)
YouTube (http://www.youtube.com/frcblog)
Email (http://www.frc.org/contact-frc)
Other FRC Sites
Other FRC Sites
(http://www.washingtonwatchradio.org)
Download the Radio App Today!
Your Email
iPhone (https://itunes.apple.com/us/app/frc-rad
Page 3 of 3 Family Research Council
8/10/2013 http://www.frc.org/historymission
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 94 of 153 Pg ID 1133
ATTACHMENT J

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 95 of 153 Pg ID 1134
1
The Top Ten Harms of
Same-Sex Marriage
by peter sprigg
Some advocates of same-sex
marriage scoff at the idea
that it could harm anyone.
Here are ten ways in which
society could be harmed by
legalizing same-sex mar-
riage. Most of these effects
would become evident only
in the long run, but several
would occur immediately.
Immediate Effects
Taxpayers, consumers, and
businesses would be forced to
subsidize homosexual relationships.
One of the key arguments often heard in support of
homosexual civil marriage revolves around all the
government benets that homosexuals claim they
are denied. Many of these benets involve one
thingtaxpayer money that homosexuals are eager
to get their hands on. For example, one of the goals
of homosexual activists is to take part in the biggest
government entitlement program of allSocial Se-
curity. Homosexuals want their partners to be eligible
for Social Security survivors benets when one part-
ner dies.
The fact that Social Security survivors benets were
intended to help stay-at-home mothers who did not
have retirement benets from a former employer has
not kept homosexuals from demanding the benet.
1
Homosexual activists are also demanding that chil-
dren raised by a homosexual couple be eligible for
benets when one of the partners dieseven if the
deceased partner was not the childs biological or
adoptive parent.
As another example, homosexuals who are employed
by the government want to be able to name their ho-
mosexual partners as dependents in order to get the
taxpayers to pay for health insurance for them. Nev-
er mind that most homosexual couples include two
wage-earners, each of whom can obtain their own
insurance. Never mind that dependents were, when
the tax code was developed, assumed to be children
and stay-at-home mothers. And never mind that
homosexuals have higher rates of physical disease,
mental illness, and substance abuse,
2
leading to more
medical claims and higher insurance premiums. No,
all of these logical considerations must give way in the
face of the demand for taxpayer subsidies of homo-
sexual relationships.
But these costs would be imposed not only upon
governments, but upon businesses and private orga-
nizations as well. Some organizations already offer
domestic partner benets to same-sex couples as a
matter of choice. Social conservatives have discour-
aged such policies, but we have not attempted to for-
bid them by law.
Imagine, though, what the impact on employee ben-
et programs would be if homosexual marriage is
legalized nationwide. Right now, marriage still pro-
vides a clear, bright line, both legally and socially,
to distinguish those who receive dependent benets
and those who dont. But if homosexual couples are
granted the full legal status of civil marriage, then
employers who do not want to grant benets to ho-
mosexual partnerswhether out of principle, or sim-
ply because of a prudent economic judgmentwould
undoubtedly be coerced by court orders to do so.
Schools would teach that
homosexual relationships are
identical to heterosexual ones.
The advocates of same-sex marriage argue that it
will have little impact on anyone other than the cou-
ples who marry. However, even the brief experience
in Massachusetts, where same-sex marriage was
imposed by the states Supreme Judicial Court and
began on May 17, 2004, has demonstrated that the
impact of such a social revolution will extend much

%
&

t
would occur
%
&

1
2
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 96 of 153 Pg ID 1135
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 6, 2013
2
furtherincluding into the public schools. In Sep-
tember 2004, National Public Radio reported, Al-
ready, some gay and lesbian advocates are working on
a new gay-friendly curriculum for kindergarten and
up. They also featured an interview with Deb Al-
len, a lesbian who teaches eighth-grade sex education
in Brookline, Mass. Allen now feels emboldened
in teaching a gay-friendly curriculum, declaring,
If somebody wants to challenge me, Ill say, Give
me a break. Its legal now. Her lessons include de-
scriptions of homosexual sex given thoroughly and
explicitly with a chart. Allen reports she will ask her
students, Can a woman and a woman have vaginal
intercourse, and they will all say no. And Ill say,
Hold it. Of course, they can. They can use a sex toy.
They could useand we talkand we discuss that.
So the answer there is yes.
3
The parents of a kindergarten student in Lexington,
Massachusetts were upset when their sons school
sent home a book featuring same-sex couples with the
child in a Diversity Bag. David Parker, the childs
father, met with his sons principal to insist that the
school notify him and allow his child to opt out of
discussions of homosexuality in the classroom. State
law specically guarantees parents the right to opt
their child out of any curriculum involving human
sexuality issues.
4
Nevertheless, the principal refused,
and because Parker was unwilling to leave without
such assurances, he was arrested for trespassing and
spent a night in jailstripped of my shoes, my belt,
my wedding ring, and my parental rights, as he later
put it.
5
Lexington school superintendent Paul Ash
evaded the state law by insisting that books about ho-
mosexual couples dealt with family experiences and
diversity, not human sexuality.
6
Six months later,
the criminal charges against Parker were dropped
but Ash continued to bar Parker from all school
property,
7
meaning that he is banned from voting,
teacher-parent conferences, and school committee
meetings.
8
Freedom of conscience and religious
liberty would be threatened.
Another important and immediate result of same-sex
marriage would be serious damage to religious lib-
erty.
Religious liberty means much more than liturgical
rituals. It applies not only to formal houses of wor-
ship, but to para-church ministries, religious educa-
tional and social service organizations, and individual
believers trying to live their lives in accordance with
their faith not only at church, but at home, in their
neighborhoods, and in the workplace. These, more
than your pastor or parish priest, are the entities
whose religious liberty is most threatened by same-
sex marriage.
Some of these threats to religious liberty can arise
from nondiscrimination laws based on sexual orien-
tation, even without same-sex marriage. But when
homosexual marriage becomes legal, then laws
which once applied to homosexuals only as individu-
als then apply to homosexual couples as well. So, for
example, when Catholic Charities in Boston insisted
that they would stay true to principle and refuse to
place children for adoption with same-sex couples,
they were told by the state that they could no longer
do adoptions at all.
9
In other cases, a variety of benets or opportunities
that the state makes available to religious nonprots
could be withheld based on the organizations refusal
to treat same-sex couples and marriages the same
as opposite-sex marriages. Organizations might be
denied government grants or aid otherwise available
to faith-based groups; they might be denied access to
public facilities for events; and they might even have
their tax-exempt status removed.
10
That is what hap-
pened to the Ocean Grove Camp Meeting Associa-
tion in New Jersey when they refused to rent facilities
for a lesbian civil union ceremony.
11
Religious educational institutions are particularly at
risk, because in some cases they may allow students
who are not believers to attend and even have staff
who are not adherents of their religion, but still de-
sire to maintain certain religiously-informed norms
and standards of behavior. Yet a Lutheran school in
California has been sued for expelling two girls who
were in a lesbian relationship.
12
Yeshiva University,
a Jewish school in New York City, was forced to al-
low same-sex domestic partners in married-student
housing.
13
Religious clubs on secular campuses may
be denied recognition if they oppose homosexual
conductthis happened to the Christian Legal Soci-
ety at the University of Californias Hastings School
of Law.
14
3
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 97 of 153 Pg ID 1136
3
20% of the total identied by the Census.
21
By con-
trast, 91% of opposite-sex couples who lived together
in California were married.
22
In other words, only 9%
of heterosexual couples in California have rejected the
institution of marriage, while over 80% of the homo-
sexual couples rejected marriage when it was offered
to them in 2008.
In Massachusetts, the number of same-sex marriages
between 2004 and the end of 2006
23
represented only
52% of the number of same-sex cohabiting couples in
the state identied by the 2000 census.
24
By contrast,
91% of opposite-sex couples who lived together were
married.
25
In other words, 48% of same-sex couples
rejected marriage, a rate more than ve times higher
than the 9% of opposite-sex couples who did so.
In the Netherlands, the rst country in the world to
legalize same-sex civil marriage, the gures are even
more dramatic. A 2005 report indicated that only
12% of same-sex cohabiting couples in that country
have married, with another 10% in what are called
registered partnerships.
26
By contrast, 82% of het-
erosexual couples in the Netherlands (as of 2004)
were married.
27
This means that 78% of the same-
sex couples in the Netherlands have seen no neces-
sity for legal recognition of their relationships at all,
while only 18% of opposite-sex couples have similarly
rejected marriage.
These gures show that a large percentage, and pos-
sibly even an outright majority, of homosexuals
even those already living with a partnerneither
need nor desire to participate in the institution of
marriage. Legalizing same-sex marriage would be
very effective in sending a message of endorsement
of homosexual behavior. But the indifference of most
homosexuals to marriage would send a message to
society that marriage does not matterthat it is no
longer the normative setting for sexual relations and
child-rearing, but is instead nothing more than one
relationship option among many, made available as a
government entitlement program to those who seek
taxpayer-funded benets.
Couples who could marry, but choose instead to co-
habit without the benet of marriage, harm the in-
stitution of marriage by setting an example for other
couples, making non-marital cohabitation seem more
acceptable as well. If same-sex marriage were le-
galized, the evidence suggests that the percentage of
homosexual couples who would choose cohabitation
over marriage would be much larger than the cur-
Professionals would face lawsuits or even a denial of
licensing if they refuse to treat homosexual relation-
ships the same as heterosexual ones. A California
fertility doctor was sued for declining to articially
inseminate a lesbian woman.
15
And the online dat-
ing service eHarmony succumbed to the pressure of
a lawsuit and agreed to provide services for same-sex
couples as well.
16
Individual believers who disapprove of homosexual
relationships may be the most vulnerable of all, facing
a choice at work between forfeiting their freedom of
speech and being red.
17

Religious liberty is one of the deepest American val-
ues. We must not sacrice it on the altar of political
correctness that homosexual marriage would create.
Long-Term Effects
Fewer people would marry.
Even where legal recognition and marital rights and
benets are available to same-sex couples (whether
through same-sex civil marriages, civil unions,
or domestic partnerships), relatively few same-sex
couples even bother to seek such recognition or claim such
benets.
The most simple way to document this is by compar-
ing the number of same-sex couples who have sought
such legal recognition in a given state
18
with the num-
ber of same-sex unmarried-partner households in
the most recent U.S. Census.
19

When a relatively small percentage of same-sex cou-
pleseven among those already living together as
partnerseven bother to seek legal recognition of
their relationships, while an overwhelming majority
of heterosexual couples who live together are legally
married, it suggests that homosexuals are far more
likely than heterosexuals to reject the institution of
marriage or its legal equivalent.
In California, same-sex marriage was only legal for
a few months, from the time that the California Su-
preme Court ruled in May of 2008 until the voters
adopted Proposition 8 in November of the same year.
Press reports have indicated that about 18,000 same-
sex couples got married in California
20
less than
4
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 98 of 153 Pg ID 1137
4
rent percentage of heterosexual couples who choose
cohabitation over marriage. It is likely that the poor
example set by homosexual couples would, over time,
lead to lower marriage rates among heterosexuals as
well.
28

Fewer people would remain
monogamous and sexually faithful.
One value that remains remarkably strong, even
among people who have multiple sexual partners
before marriage, is the belief that marriage itself is a
sexually exclusive relationship. Among married het-
erosexuals, having sexual relations with anyone other
than ones spouse is still considered a grave breach of
trust and a violation of the marriage covenant by the
vast majority of people.
Yet the same cannot be said of homosexualspar-
ticularly of homosexual men. Numerous studies of
homosexual relationships, including partnered re-
lationships, covering a span of decades, have shown
that sex with multiple partners is tolerated and often
expected, even when one has a long-term partner.
Perhaps the most startling of these studies was pub-
lished in the journal AIDS. In the context of studying
HIV risk behavior among young homosexual men in
the Netherlands (coincidentally, the rst country in
the world to legalize homosexual civil marriage), the
researchers found that homosexual men who were in
partnered relationships had an average of eight sexual
partners per year outside of the primary relationship.
29

(It must be conceded that having such a partnership
did have some taming effect upon such menthose
without a permanent partner had an average of 22
sexual partners per year). This is an astonishing con-
trast to the typical behavior of married heterosexuals,
among whom 75% of the men and 85% of the women
report never having had extra-marital sex even once
during the entire duration of their marriage.
30
Again, the conservative argument for homosexual
marriage suggests that granting the rights of civil
marriage to homosexuals would tame such pro-
miscuous behavior. (To be fair, it must be pointed
out that the data in the Dutch study mentioned above
were collected before the legalization of homosexual
marriage in that country, albeit after most of the
rights of marriage had been granted through civil
unions). However, the implausibility of this claim is
illustrated not only by the experience of the Neth-
erlands and other northern European countries that
recognize homosexual partnerships, but also by the
open declarations of many homosexuals themselves.
31
Rather than marriage changing the behavior of ho-
mosexuals to match the relative sexual delity of het-
erosexuals, it seems likely that the opposite would oc-
cur. If homosexual relationships, promiscuity and all,
are held up to society as being a fully equal part of the
social ideal that is called marriage, then the value
of sexual delity as an expected standard of behavior
for married people will further erodeeven among
heterosexuals.
Fewer people would remain
married for a lifetime.
Lawrence Kurdek, a homosexual psychologist from
Ohios Wright State University,
32
who has done ex-
tensive research on the nature of homosexual rela-
tionships, has correctly stated, Perhaps the most im-
portant bottom-line question about gay and lesbian
couples is whether their relationships last.
33
After
extensive research, he determined that it is safe to
conclude that gay and lesbian couples dissolve their
relationships more frequently than heterosexual cou-
ples, especially heterosexual couples with children.
34
Once again, abundant research has borne out this
point. Older studies came to similar conclusions. In
one study of 156 male couples, for instance, only sev-
en had been together for longer than ve years (and
none of those seven had remained sexually faithful to
each other).
35

International ndings are similar. The Dutch study
mentioned earlier, which highlighted so dramatically
the promiscuous nature of male homosexual relation-
ships, also showed their transience. It found that the
average male homosexual partnership lasted only 1.5
years.
36
In contrast, more than 50 percent of hetero-
sexual marriages last fteen years or longer.
37
Some may argue that granting homosexual relation-
ships legal recognition as marriages would make
them as stable as heterosexual marriages. However, a
study of married same-sex couples in Massachusetts
found that after only a year or less of marriage, more
5
6
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 99 of 153 Pg ID 1138
5
than a third (35%) of the male couples and nearly half
(46%) of the female couples had already seriously
discussed ending their relationship.
38
And a study
of same-sex divorce among homosexual couples in
registered partnerships in Sweden found that the
divorce risk in partnerships of men appears 50 percent
higher than the corresponding risk in heterosexual
marriages, and that the divorce risk in partnerships
of women is about the double of that of menthus
making lesbian divorces almost three times as likely
as heterosexual ones.
39
How would this affect heterosexual couples? If the
unstable nature of homosexual partnerships becomes
part of the ideal of marriage that is being held up to
society, it will inevitably affect the future behavior of
everyone in societyheterosexuals included. There-
fore, we can predict the following:
If homosexual marriage is legalized, the percent-
age of homosexual couples that remain together for
a lifetime will always be lower than the percentage of
heterosexual couples that do so; but the percentage
of heterosexual couples demonstrating lifelong com-
mitment will also decline, to the harm of society as a
whole.
Fewer children would be raised by a
married mother and father.
The greatest tragedy resulting from the legalization
of homosexual marriage would not be its effect on
adults, but its effect on children. For the rst time
in history, society would be placing its highest stamp
of ofcial government approval on the deliberate cre-
ation of permanently motherless or fatherless house-
holds for children.
There simply cannot be any serious debate, based on
the mass of scholarly literature available to us, about
the ideal family form for children. It consists of a
mother and father who are committed to one another
in marriage. Children raised by their married mother
and father experience lower rates of many social pa-
thologies, including:
premarital childbearing;
40
illicit drug use;
41

arrest;
42

health, emotional, or behavioral problems;
43
poverty;
44

or school failure or expulsion.
45

These benets are then passed on to future genera-
tions as well, because children raised by their married
mother and father are themselves less likely to cohabit
or to divorce as adults.
46

In a perfect world, every child would have that kind
of household provided by his or her own loving and
capable biological parents (and every husband and
wife who wanted children would be able to conceive
them together). Of course, we do not live in a perfect
world.
But the parent who says, Im gay, is telling his or
her child that he or she has no intention of providing
a parent of both sexes for that child. And a homo-
sexual who marries someone of the same sex is de-
claring that this deprivation is to be permanentand
with the blessing of the state.
Homosexual activists argue that research on homo-
sexual parenting does not show differences among
the children raised by homosexuals and those raised
by heterosexuals. Even leading professional organiza-
tions such as the American Academy of Pediatrics,
under the inuence of homosexual activists, have is-
sued policy statements making such claims.
47
A close examination of the actual research, however,
shows that such claims are unsupportable. The truth
is that most research on homosexual parents thus
far has been marred by serious methodological prob-
lems.
48
However, even pro-homosexual sociologists
Judith Stacey and Timothy Biblarz report that the
actual data from key studies show the no differences
claim to be false.
Surveying the research (primarily regarding lesbians)
in an American Sociological Review article in 2001,
they found that:
% Children of lesbians are less likely to conform to
traditional gender norms.
% Children of lesbians are more likely to engage in
homosexual behavior.
% Daughters of lesbians are more sexually adven-
turous and less chaste.
% Lesbian co-parent relationships are more likely
to break up than heterosexual marriages.
49
7
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 100 of 153 Pg ID 1139
6
A 1996 study by an Australian sociologist compared
children raised by heterosexual married couples, het-
erosexual cohabiting couples, and homosexual cohab-
iting couples. It found that the children of hetero-
sexual married couples did the best, and children of
homosexual couples the worst, in nine of the thirteen
academic and social categories measured.
50
As scholar Stanley Kurtz says,
If, as in Norway, gay marriage were imposed
here by a socially liberal cultural elite, it would
likely speed us on the way toward the classic
Nordic pattern of less frequent marriage, more
frequent out-of-wedlock birth, and skyrocket-
ing family dissolution. In the American con-
text, this would be a disaster.
51
More children would
grow up fatherless.
This harm is closely related to the previous one, but
worth noting separately. As more children grow up
without a married mother and father, they will be
deprived of the tangible and intangible benets and
security that come from that family structure. How-
ever, most of those who live with only one biologi-
cal parent will live with their mothers. In the gen-
eral population, 79% of single-parent households are
headed by the mother, compared to only 10% which
are headed by the father.
52
Among homosexual cou-
ples, as identied in the 2000 census, 34% of lesbian
couples have children living at home, while only 22%
of male couples were raising children.
53
The encour-
agement of homosexual relationships that is intrinsic
in the legalization of same-sex marriage would thus
result in an increase in the number of children who
suffer a specic set of negative consequences that are
clearly associated with fatherlessness.
Homosexual activists say that having both a mother
and a father simply does not matterit is having two
loving parents that counts. But social science research
simply does not support this claim. Dr. Kyle Pruett of
Yale Medical School, for example, has demonstrated
in his book Fatherneed that fathers contribute to par-
enting in ways that mothers do not. Pruett declares,
From deep within their biological and psychological
being, children need to connect to fathers . . . to live
life whole.
54
Childrenboth sons and daughterssuffer without
a father in their lives. The body of evidence support-
ing this conclusion is both large and growing.
55
For
example, research has shown that youth incarcera-
tion risks in a national male cohort were elevated for
adolescents in father-absent households, even after
controlling for other factors.
56
Among daughters, fa-
ther absence was strongly associated with elevated risk
for early sexual activity and adolescent pregnancy.
57

Author David Blankenhorn puts these risks more
succinctly: One primary result of growing fatherless-
ness is more boys with guns. Another is more girls
with babies.
58
Even researchers who are support-
ive of homosexual parenting have had to admit that
children raised in fatherless families from infancy,
while closer to their mothers, perceived themselves
to be less cognitively and physically competent than
their peers from father-present families.
59

Some lesbian couples are deliberately creating new
children in order to raise them fatherless from birth.
It is quite striking to read, for example, the model
Donor Agreement for sperm donors offered on the
Human Rights Campaign website, and to see the
lengths to which they will go to legally insure that
the actual biological father plays no role in the life of
a lesbian mothers child.
60
Yet a recent study of chil-
dren conceived through sperm donation found, Do-
nor offspring are signicantly more likely than those
raised by their biological parents to struggle with
serious, negative outcomes such as delinquency, sub-
stance abuse, and depression, even when controlling
for socio-economic and other factors.
61
Remarkably,
38% of donor offspring born to lesbian couples in the
study agreed that it is wrong deliberately to conceive
a fatherless child.
62
Birth rates would fall.
One of the most fundamental tasks of any society is
to reproduce itself. That is why virtually every human
society up until the present day has given a privileged
social status to male-female sexual relationshipsthe
only type capable of resulting in natural procreation.
This privileged social status is what we call marriage.
Extending the benets and status of marriage to
couples who are intrinsically incapable of natural pro-
creation (i.e., two men or two women) would dramat-
8
9
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 101 of 153 Pg ID 1140
7
ically change the social meaning of the institution. It
would become impossible to argue that marriage
is about encouraging the formation of life-long, po-
tentially procreative (i.e., opposite-sex) relationships.
The likely long-term result would be that fewer such
relationships would be formed, fewer such couples
would choose to procreate, and fewer babies would
be born.
There is already evidence of at least a correlation be-
tween low birth rates and the legalization of same-
sex marriage. At this writing, ve U.S. states grant
marriage licenses to same-sex couples. As of 2007,
the last year for which complete data are available,
four of those ve states ranked within the bottom
eight out of all fty states in both birth rate (measured
in relation to the total population) and fertility rate
(measured in relation to the population of women of
childbearing age).
63

Even granting marriage-related benets to same-sex
couples is associated with low birth and fertility rates.
There are sixteen states which offer at least some
recognition or benets to same-sex relationships.
64

Twelve of these sixteen states rank in the bottom
twenty states in birth rate, while eleven of them rank
in the bottom seventeen in fertility rate. Vermont, the
rst state in the U. S. to offer 100% of the rights and
benets of marriage to same-sex couples through pas-
sage of its civil unions law in 2000
65
, ranks dead last
in both birth rate and fertility rate.
66
Similar data are available on the international level.
Currently there are ten countries which permit same-
sex marriage.
67
Six of these ten fall well within the
bottom quarter in both birth rates and fertility rates
among 223 countries and territories. All ten fall be-
low the total world fertility rate, while only South Af-
rica has a birth rate that is higher (barely) than the
world rate.
68
It could be argued that the widespread availability
and use of articial birth control, together with other
social trends, has already weakened the perceived link
between marriage and procreation and led to a de-
cline in birth rates. These changes may have helped
clear a path for same-sex marriage, rather than
the reverse.
69
Nevertheless, legalization of same-sex
marriage would reinforce a declining emphasis on
procreation as a key purpose of marriageresulting
in lower birth rates than if it had not been legalized.
Of course, there are some who are still locked in the
alarmism of the 1960s over warnings of over-popula-
tion.
70
However, in recent years it has become clear,
particularly in the developed world, that declining
birth rates now pose a much greater threat. Declining
birth rates lead to an aging population, and demogra-
phers have warned of the consequences,
. . . from the potentially devastating effects
on an unprepared welfare state to shortages
of blood for transfusions. Pension provisions
will be stretched to the limit. The traditional
model of the working young paying for the re-
tired old will not work if the latter group is
twice the size of the former. . . . In addition, .
. . healthcare costs will rise.
71
The contribution of same-sex marriage to declining
birth rates would clearly lead to signicant harm for
society.
Demands for legalization of
polygamy would grow.
If the natural sexual complementarity of male and
female and the theoretical procreative capacity of an
opposite-sex union are to be discarded as principles
central to the denition of marriage, then what is left?
According to the arguments of the homosexual mar-
riage advocates, only love and companionship are
truly necessary elements of marriage.
But if that is the case, then why should other rela-
tionships that provide love, companionship, and a
lifelong commitment not also be recognized as mar-
riagesincluding relationships between adults and
children, or between blood relatives, or between three
or more adults? And if it violates the equal protection
of the laws to deny homosexuals their rst choice of
marital partner, why would it not do the same to deny
pedophiles, polygamists, or the incestuous the right
to marry the person (or persons) of their choice?
Of these, the road to polygamy seems the best-
pavedand it is the most difcult for homosexual
marriage advocates to deny. If, as they claim, it is
arbitrary and unjust to limit the gender of ones mari-
tal partner, it is hard to explain why it would not be
10
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 102 of 153 Pg ID 1141
8
equally arbitrary and unjust to limit the number of
marital partners.
There are also two other reasons why same-sex mar-
riage advocates have trouble refuting warnings of a
slippery slope toward polygamy. The rst is that there
is far more precedent cross-culturally for polygamy as
an accepted marital structure than there is for homo-
sexual marriage. The second is that there is a genu-
ine movement for polygamy or polyamory in some
circles.
The San Francisco Chronicles religion writer did a fea-
ture on the polyamory movement in 2004. It even
quoted Jasmine Walston, the president of Unitarian
Universalists for Polyamory Awareness, as saying,
Were where the gay rights movement was 30 years
ago. The story also quoted Barb Greve, a program
associate with the Association of Unitarian Universal-
ists Ofce of Bisexual, Gay, Lesbian and Transgen-
der Concerns in Boston. Greve, helpfully described
as a transgender person who likes to be called he,
said, There are people who want to be in committed
relationshipswhether its heterosexual marriage,
same-sex marriage or polyamoryand that should
be acknowledged religiously and legally.
72
The gay oriented newspaper the Washington Blade
has also featured this topic in a full-page article un-
der the headline Polygamy advocates buoyed by gay
court wins. It quotes Art Spitzer of the American
Civil Liberties Union acknowledging, Yes, I think
[the Supreme Court decision in Lawrence v. Texas]
would give a lawyer a foothold to argue such a case.
The general framework of that case, that states cant
make it a crime to engage in private consensual inti-
mate relationships, is a strong argument.
73
This argument is already being pressed in the courts.
Two convicted bigamists in Utah, Tom Green and
Rodney Holm, have appealed to have their convic-
tions overturnedciting the Supreme Courts deci-
sion in the Lawrence case as precedent.
74
And another
attorney has led suit challenging the refusal of the
Salt Lake County clerk to grant a marriage license for
G. Lee Cook to take a second wife.
75
Make no mistake about itif same-sex marriage is
not stopped now, we will have the exact same debate
about plural marriages only one generation from
now.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 103 of 153 Pg ID 1142
9
Endnotes
1 One of the architects of Social Security, Abraham Ep-
stein, said, [T]he American standard assumes a nor-
mal family of man, wife, and two or three children, with
the father fully able to provide for them out of his own
income. Abraham Epstein, Insecurity: A Challenge to
America (New York: Harrison Smith and Robert Haas,
1933), 101-102; cited in Allan Carlson, The American
Way: Family and Community in the Shaping of the Ameri-
can Identity (Wilmington, DE: ISI Books, 2003), 69. See
generally Carlsons entire chapter on Sanctifying the
Traditional Family: The New Deal and National Soli-
darity, 55-77.
2 See Victor M. B. Silenzio, Top 10 Things Gay Men
Should Discuss with their Healthcare Provider (San
Francisco: Gay & Lesbian Medical Association);
accessed April 1, 2010; online at: http://www.glma.org/_
data/n_0001/resources/live/Top%20Ten%20Gay%20
Men.pdf; and Katherine A. OHanlan, Top 10 Things
Lesbians Should Discuss with their Healthcare Provider
(San Francisco: Gay & Lesbian Medical Association);
accessed April 1, 2010; online at: http://www.glma.org/_
data/n_0001/resources/live/Top%20Ten%20Lesbians.
pdf
3 Debate in Massachusetts over how to address the issue
of discussing gay relationships and sex in public school
classrooms, All Things Considered, National Public Ra-
dio, September 13, 2004.
4 Massachusetts General Laws, Chapter 71, Section 32A.
Online at: http://www.mass.gov/legis/laws/mgl/71-32a.
htm
5 David Parkers speech on the Lexington Battle Green to
rally the parents of Massachusetts, September 6, 2005;
online at: http://www.article8.org/docs/news_events/
parker/rally_090605/parker_speech.html
6 Paul Ash, What does the law say schools have to do?
Lexkington Minuteman, September 22, 2005. Quoted
online at: http://www.article8.org/docs/news_events/
parker/paul_ash_letter.htm
7 Ralph Ranalli, Lawyer Says State to Drop Case vs. Lex-
ington Father, The Boston Globe, October 20, 2005, p.
B2. Online. Nexis.
8 David Parkers speech on the Lexington Battle Green,
op. cit.
9 Maggie Gallagher, Banned in Boston: The coming con-
ict between same-sex marriage and religious liberty,
The Weekly Standard Vol. 11, Issue 33, May 15, 2006;
online at: http://weeklystandard.com/Content/Public/
Articles/000/000/012/191kgwgh.asp
10 Roger Severino, Or for Poorer? How Same-Sex Mar-
riage Threatens Religious Liberty, Harvard Journal of
Law and Public Policy 30, Issue 3 (Summer 2007), 939-
82.
11 Jill P. Capuzzo, Group Loses Tax Break Over Gay
Union Issue, The New York Times, September 18, 2007,
p. B2. Online at: http://www.nytimes.com/2007/09/18/
nyregion/18grove.html?_r=1&scp=1&sq=Ocean%20
Grove%20Camp%20Meeting%20&%20civil%20
union&st=cse
12 Associated Press, Teens Suspected of Being Lesbians
Sue School, December 30, 2005; online at: http://www.
msnbc.msn.com/id/10646475/. In this case, the school
ultimately prevailed in courtbut only after three and
a half years of litigation. See Jessica Garrison, Califor-
nia Supreme Court backs private school in bias case, Los
Angeles Times, May 2, 2009; online at: http://articles.lat-
imes.com/2009/may/02/local/me-lesbian2
13 Levin v. Yeshiva University, New York Court of Appeals,
96 N.Y.2d 484, 754 N.E.2d 1099, 730 N.Y.S.2d 15, July
2, 2001.
14 Christian Legal Society v. Martinez, Supreme Court of the
United States, No. 08-1371, slip op., June 28, 2010.
15 The California Supreme Court ruled unanimously
against the doctors freedom of conscience in North Coast
Womens Care Medical Group vs. Superior Court (44 Cal.
4th 1145), August 18, 2008.
16 Joshua Rhett Miller, eHarmony to Provide Gay Dating
Service After Lawsuit, FoxNews.com; online at: http://
www.foxnews.com/story/0,2933,454904,00.html
17 Insurance giant Allstate red J. Matt Barber (now a
prominent pro-family advocate with Liberty Counsel)
for the views expressed in a column he wrote and pub-
lished on his own time. Ron Strom, Allstate terminates
manager over homosexuality column, WorldNetDaily.
com, June 24, 2005; online at: http://www.wnd.com/
news/article.asp?ARTICLE_ID=44961
18 This is a matter of public record, although some states do
not track same-sex marriages separately from opposite-
sex ones.
19 The 2000 Census was the rst in which cohabiting in-
dividuals (both opposite-sex and same-sex) were given
the option of declaring themselves to be partners. Since
people who are merely roommates or housemates can still
identify themselves as such, the presumption is that the
term partners will only be used by those in a sexual re-
lationship. See Tavia Simmons and Martin OConnell,
Married-Couple and Unmarried Partner Households:
2000, Census 2000 Special Reports CENSR-5 (Washing-
ton, DC: U.S. Census Bureau). Online at: http://www.
census.gov/prod/2003pubs/censr_5.pdf
20 Jessica Garrison, Angrier response to Prop. 8 steps
up, Los Angeles Times, November 13, 2008. Online
at: http://www.latimes.com/news/la-me-prop813-
2008nov13,0,3589281.story?track=ntothtml
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 104 of 153 Pg ID 1143
10
21 There were 92,138 same-sex unmarried partner house-
holds in California. Simmons and OConnell, op. cit., p.
4, Table 2.
22 California had 5,877,084 married couples and 591,378
opposite-sex unmarried partner households. Simmons
and OConnell, op. cit.
23 There were 8,935 same-sex marriages in Massachusetts
in this time period. Kevin Foster, Massachusetts Registry
of Vital Records and Statistics, e-mail message to author,
April 30, 2007.
24 There were 17,099 same-sex unmarried partner house-
holds in Massachusetts.
25 Massachusetts had 1,197,917 married (opposite-sex)
couples and 113,820 opposite-sex unmarried partner
households.
26 Over 50 thousand lesbian and gay couples, Statistics
Netherlands Web magazine, November 15, 2005. On-
line at: http://www.cbs.nl/en-GB/menu/themas/mens-
maatschappij/bevolking/publicaties/artikelen/2005-
1823-wm.htm
27 Nederlands Jeugd instituut, Types of house-
holds in the Netherlands 1995-2004; online at:
http://www.youthpolicy.nl/eCache/DEF/1/06/357.html
28 For example, in the Netherlands, the percentage of het-
erosexual couples rejecting marriage jumped by more than
a third, from 13% to 18%, between 1995 and 2004dur-
ing the very time period when same-sex marriage was
legalized. Types of households in the Netherlands 1995-
2004, op.cit.
29 Maria Xiridou, et al, The Contribution of Steady and
Casual Partnerships to the Incidence of HIV Infection
among Homosexual Men in Amsterdam, AIDS 17
(2003): 1031.
30 E. O. Laumann et al., The Social Organization of Sexual-
ity: Sexual Practices in the United States (Chicago: Univer-
sity of Chicago Press, 1994 ): 216.
31 See, for example: Meredith May, Many gay couples ne-
gotiate open relationships, San Francisco Chronicle, July
16, 2010; online at: http://www.sfgate.com/cgi-bin/ar-
ticle.cgi?f=/c/a/2010/07/16/DD4C1EDP1A.DTL
32 Peter Freiberg, Couples study shows strengths, The
Washington Blade, March 16, 2001.
33 Lawrence Kurdek, What Do We Know about Gay and
Lesbian Couples? Current Directions in Psychological Sci-
ence 14 (2005): 252.
34 Lawrence Kurdek, Are Gay and Lesbian Cohabiting
Couples Really Different from Heterosexual Married
Couples? Journal of Marriage and Family 66 (November
2004): 896.
35 David P. McWhirter and Andrew M. Mattison, The
Male Couple: How Relationships Develop (Englewood
Cliffs: Prentice-Hall, 1984): 252, 253.
36 Xiridou, et al., 1031.
37 National Center for Health Statistics, Centers for Dis-
ease Control, 43 Percent of First Marriages Break Up
Within 15 Years (May 24, 2001); online at: http://www.
cdc.gov/nchs/releases/01news/rstmarr.htm
38 Esther D. Rothblum, Kimberly F. Balsam, and Sondra
E. Solomon, Comparison of Same-Sex Couples Who
Were Married in Massachusetts, Had Domestic Partner-
ships in California, or Had Civil Unions in Vermont,
Journal of Family Issues 29 ( January 2008): Table 2, p. 64.
39 Gunnar Andersson, Turid Noack, Ane Seies-
tad, and Harald Weedon-Fekjaer, Divorce-
Risk Patterns in Same-Sex Marriages in Nor-
way and Sweden, paper presented at the 2004
Annual Meeting of the Population Association of Amer-
ica (April 3, 2004), p. 16; see also Table 5, p. 28; online at
http://paa2004.princton.edu/download.
asp?submissionId=40208
40 Kristin A. Moore, Nonmarital School-Age Mother-
hood: Family, Individual, and School Characteristics,
Journal of Adolescent Research 13, October 1998: 433-457.
41 John P. Hoffman and Robert A. Johnson, A National
Portrait of Family Structure and Adolescent Drug Use,
Journal of Marriage and the Family 60, August 1998: 633-
645.
42 Chris Coughlin and Samuel Vucinich, Family Experi-
ence in Preadolescence and the Development of Male
Delinquency, Journal of Marriage and the Family 58, May
1996: 491-501.
43 Debra L. Blackwell, Family structure and childrens
health in the United States: Findings from the National
Health Interview Survey, 20012007, Vital and Health
Statistics, Series 10, No. 246 (Hyattsville, MD: National
Center for Health Statistics, December 2010). Online
at: http://www.cdc.gov/nchs/data/series/sr_10/sr10_246.
pdf
44 Federal Interagency Forum on Child and Family Statis-
tics, Americas Children: Key Indicators of Well-Being 2001,
Washington, D.C., p. 14.
45 Deborah A. Dawson, Family Structure and Childrens
Health and Well-Being: Data from the 1988 National
Health Interview Survey on Child Health, Journal of
Marriage and the Family 53, August 1991: 573-584.
46 Paul R. Amato and Alan Booth, A Generation at Risk:
Growing Up in an Era of Family Upheaval, Cambridge,
Massachusetts: Harvard University Press, 1997, pp. 111-
115.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 105 of 153 Pg ID 1144
11
47 Committee on Psychosocial Aspects of Child and Family
Health, American Academy of Pediatrics, Policy State-
ment: Coparent or Second-Parent Adoption by Same-
Sex Parents, Pediatrics Vol. 109, No. 2, February 2002,
pp. 339-340 (Reafrmed May 2009; online at: http://
aappolicy.aappublications.org/cgi/content/full/pediat-
rics;125/2/e444).
48 Robert Lerner and Althea K. Nagai, No Basis: What the
Studies Dont Tell Us About Same Sex Parenting (Washing-
ton: Ethics and Public Policy Center, 2001).
49 Judith Stacey and Timothy J. Biblarz, (How) Does the
Sexual Orientation of Parents Matter? American Socio-
logical Review 66 (2001), pp. 159-183.
50 Sotirios Sarantakos, Children in three contexts: Family,
education and social development, Children Australia 21,
No. 3 (1996): 23-31.
51 Stanley Kurtz, The End of Marriage in Scandinavia:
The conservative case for same-sex marriage collapses,
The Weekly Standard 9, No. 20 (February 2, 2004): 26-33.
52 Rose M. Kreider, Living Arrangements of Children:
2004, Current Population Reports P70-114 (Washington,
DC: U.S. Census Bureau), February 2008, Figure 1, p. 5.
53 Simmons and OConnell, op. cit., Table 4, p. 9.
54 Kyle D. Pruett, Fatherneed: Why Father Care is as Essential
as Mother Care for Your Child (New York: The Free Press,
2000), p. 16.
55 A good recent summary is Paul C. Vitz, The Im-
portance of Fathers: Evidence and Theory from So-
cial Science (Arlington, VA: Institute for the Psy-
chological Sciences, June 2010); online at:
http://www.profam.org/docs/thc.vitz.1006.htm
56 Cynthia C. Harper and Sara S. McLanahan, Father
Absence and Youth Incarceration, Journal of Research on
Adolescence 14(3), 2004, p. 388.
57 Bruce J. Ellis, John E. Bates, Kenneth A. Dodge,
David M. Fergusson, L. John Horwood, Grego-
ry S. Pettit, Lianne Woodward, Does Father Ab-
sence Place Daughters at Special Risk for Early
Sexual Activity and Teenage Pregnancy? Child Devel-
opment Vol. 74, Issue 3, May 2003; abstract online at:
http://onlinelibrary.wiley.com/doi/10.1111/1467-
8624.00569/abstract
58 David Blankenhorn, Fatherless America: Confronting
Our Most Urgent Social Problem (New York: BasicBooks,
1995), p. 45.
59 Susan Golombok, Fiona Tasker, Clare Murray, Chil-
dren Raised in Fatherless Families from Infancy: Family
Relationships and the Socioemotional Development of
Children of Lesbian and Single Heterosexual Mothers,
Journal of Child Psychologyc and Psychiatry Vol. 38, Issue 7
(October 1997); abstract online at: http://onlinelibrary.
wiley.com/doi/10.1111/j.1469-7610.1997.tb01596.x/ab-
stract
60 Human Rights Campaign, Donor Agreement; online at:
http://www.hrc.org/Template.cfm?Section=Search_the_
Law_Database&Template=/ContentManagement/Con-
tentDisplay.cfm&ContentID=18669
61 Elizabeth Marquardt, Norval D. Glenn, and Karen Clark,
My Daddys Name is Donor: A New Study of Young Adults
Conceived Through Sperm Donation (New York: Institute
for American Values, 2010) p. 9.
62 Ibid., Table 2, p. 110.
63 Joyce A. Martin, Brady E. Hamilton, Paul D. Sutton,
Stephanie J. Ventura, T. J. Mathews, Sharon Kirmeyer,
and Michelle J. K. Osterman, U.S. Department of Health
and Human Services, Centers for Disease Control and
Prevention, National Center for Health Statistics, Na-
tional Vital Statistics System, Births: Final Data for
2007, National Vital Statistics Reports Vol. 58, No. 24,
August, 2010, Table 11. Rankings calculated by the au-
thor.
64 Human Rights Campaign, Marriage Equality and Oth-
er Relationship Recognition Laws, April 2, 2010; online
at: http://www.hrc.org/documents/Relationship_Recog-
nition_Laws_Map.pdf
65 An Act Relating to Civil Unions, H. 847, adopted
April 26, 2000; online at: http://www.leg.state.vt.us/
docs/2000/bills/passed/h-847.htm
66 Martin et al., op. cit.
67 The Netherlands, Spain, Canada, Belgium, South Africa,
Norway, Sweden, Portugal, Iceland, and Argentina. See
Dan Fastenberg, A Brief History of International Gay
Marriage, Time, July 22, 2010; http://www.time.com/
time/world/article/0,8599,2005678,00.html
68 Country Comparison: Birth Rate, The World
Factbook (Central Intelligence Agency); online at:
https://www.cia.gov/library/publications/the-world
-factbook/rankorder/2054rank.html; and Coun-
try Comparison: Total Fertility Rate, The World
Factbook (Central Intelligence Agency); online at:
https://www.cia.gov/library/publications/the-world
-factbook/rankorder/2127rank.html?countryName=Bur
ma&countryCode=bm&regionCode=eas#bm
69 Note, for example, that in 2007, the last year for which -
nal birth rate and fertility rate data are available, only one
state (Massachusetts) had legalized same-sex marriage.
70 The most well-known representative being Paul R. Eh-
rlich, The Population Bomb (New York: Ballantine Books,
1968).
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 106 of 153 Pg ID 1145
12
peter sprigg is Senior Fellow for Policy Studies at Family Re-
search Council in Washington, D. C. He is the author of Outrage:
How Gay Activists and Liberal Judges are Trashing Democracy to
Redene Marriage and co-author of Getting It Straight: What the
Research Shows about Homosexuality.
About the Author
the top ten harms of same-sex marriage
by peter sprigg
2011 family research council
all rights reserved.
printed in the united states
tony perkins, president
801 g street, nw
washington, d.c. 20001
order line 800-225-4008
www.frc.org
%&$
71 Jonathan Grant and Stijn Hoorens, Consequences of a
Graying World, The Christian Science Monitor, June 29,
2007; online at: http://www.csmonitor.com/2007/0629/
p09s02-coop.html; see also Jonathan Grant, Stijn Hoo-
rens, Juja Sivadasan, Mirjam van het Loo, Julie DaVanzo,
Lauren Hale, Shawna Gibson, William Butz, Low Fertil-
ity and Population Ageing: Causes, Consequences, and Policy
Options (Santa Monica, Calif.: The RAND Corporation,
2004).
72 Don Lattin, Committed to marriage for the masses:
Polyamorists say they relate honestly to multiple part-
ners, San Francisco Chronicle (April 20, 2004): B-1.
73 Joe Crea, Polygamy advocates buoyed by gay court wins:
Some see sodomy, marriage opinions as helping their
cause, Washington Blade (December 26, 2003): 14.
74 Both appeals failedbut legalization of same-sex mar-
riage would create a stronger argument than the one
based on Lawrence v. Texas, which was not related to
marriage. See: Warren Richey, Supreme Court declines
polygamy case: The husband of three wives claimed the
courts landmark ruling on gays applies to polygamists,
The Christian Science Monitor, February 27, 2007; online
at: http://www.csmonitor.com/2007/0227/p25s01-usju.
html; and Brooke Adams, Polygamist Green wants a
private, quiet life after Tuesday parole, Salt Lake Tri-
bune, August 6, 2007. Online. Nexis
75 Alexandria Sage, Attorney challenges Utah ban on po-
lygamy, cites Texas sodomy case, Associated Press ( Janu-
ary 12, 2004).
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 107 of 153 Pg ID 1146
13
To order these resources or to see more FRC publications,
visit our website at www. frc.org or call 800-225-4008.
Thank you for choosing
this resource. Our
pamphlets are designed
for grassroots activists
and concerned
citizensin other
words, people who
want to make a difference in their families, in
their communities, and in their culture.
History has clearly shown the inuence that
the Values Voter can have in the political
process. FRC is committed to enabling
and motivating individuals to bring about
even more positive change in our nation
and around the world. I invite you to use
this pamphlet as a resource for educating
yourself and others about some of the most
pressing issues of our day.
FRC has a wide range of papers and
publications. To learn more about other FRC
publications and to nd out more about our
work, visit our website at www.frc.org or call
1-800-225-4008.
I look forward to working with you as we
bring about a society that respects life and
protects marriage.
President
Family Research Council

ADDITIONAL RESOURCES FROM


FAMILY RESEARCH COUNCIL
Outrage: How Gay Activists and Liberal Judges are
Trashing Democracy to Redene Marriage BK04H01
Here is the book America needs to make sense
of the debate over same-sex marriage. Author
Peter Sprigg demolishes stereotypes on this
issue, showing why homosexual civil marriage
should be opposed by libertarians, Democrats,
women, men, and even homosexuals themselves.
Sprigg demonstrates that this culture war was
not started by conservatives, but by homosexual
activists and radical judges.
Washington Update wusub
Family Research Councils agship subscription: a daily email update with
the latest pro-family take on Washingtons hottest issues. Complimentary
Take Action Alerts catsub
Alerts notify you about opportunities to actively participate in Family Re-
search Council efforts to uphold pro-life, pro-family, and pro-freedom values
in Washington. Complimentary
The Top Ten Myths About Homosexuality
BC10E01 Homosexual activists have a clear agenda. It
is an agenda that demands the universal acceptance
of homosexual acts and relationships--morally, socially,
legally, religiously, politically and nancially. Indeed,
it calls for not only acceptance, but afrmation and
celebration of this behavior as normal, natural, and
even as desirable for those who desire it. However,
this agenda is founded on myths rather than facts.
For breaking news and
commentary, follow FRCs Senior
Fellow for Policy Studies, Peter Sprigg
on Twitter @spriggfrc
Care about life, marriage, and the family? Join the
discussion at: facebook.com/FamilyResearchCouncil

d
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 108 of 153 Pg ID 1147
ATTACHMENT K

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 109 of 153 Pg ID 1148
tony perkins, president
801 g street nw
washington, dc 20001
order line 800-225-4008
www.frc.org
Founded in 1983, Family Research Council is a
nonprot research and educational organization
dedicated to articulating and advancing a family-
centered philosophy of public life. In addition to
providing policy research and analysis for the
legislative, executive, and judicial branches of the
federal government, FRC seeks to inform the news
media, the academic community, business leaders,
and the general public about family issues that affect
the nation.
Family Research Council relies solely on the
generosity of individuals, families, foundations,
and businesses for nancial support. The Internal
Revenue Service recognizes FRC as a tax-exempt,
501(c)(3) charitable organization. Donations to FRC
are therefore tax-deductible in accordance with
Section 170 of the Internal Revenue Code.
To see other FRC publications and to nd out more
about FRCs work, visit www.frc.org.
B
C
1
0
E
0
1
r
d
at
a
a
h
a
y
ro
b
n
)
h
o
e
t
B
C
tony perkins ns, , pr preesident rkins, pr
880 8011 ggg sst street nw 801 g st
red philosophy of public life. In addition to
ding policy research and analysis for the
tive, executive, and judicial branches of the
al government, FRC seeks to inform the news
, the academic community, business leaders,
he general public about family issues that affect
ation.
y Research Council relies solely on the
osity of individuals, families, foundations,
usinesses for nancial support. The Internal
ue Service recognizes FRC as a tax-exempt,
)(3) charitable organization. Donations to FRC
herefore tax-deductible in accordance with
n 170 of the Internal Revenue Code.
e other FRC publications and to nd out more
FRCs work, visit www.frc.org.
B
family research council
Washington, DC
The Top Ten
Myths About Homosexuality
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 110 of 153 Pg ID 1149
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 6, 2013
Thank you for choosing this
resource. Our pamphlets are
designed for grassroots activ-
ists and concerned citizensin
other words, people who want
to make a difference in their families, in their com-
munities and in their culture.
History has clearly shown the inuence that the
Values Voter can have in the political process.
FRC is committed to enabling and motivating indi-
viduals to bring about even more positive change
in our nation and around the world. I invite you
to use this pamphlet as a resource for educating
yourself and others about some of the most press-
ing issues of our day.
FRC has a wide range of papers and publica-
tions. To learn more about other FRC publications
and to nd out more about our work, visit our
website at www.frc.org or call 1-800-225-4008.
I look forward to working with you as we
bring about a society that respects life and pro-
tects marriage.
President
Family Research Council
the top ten myths about homosexuality
by peter sprigg
2010 family research council
all rights reserved.
printed in the united states
The Top Ten
Myths About Homosexuality
by peter sprigg
peter sprigg is Senior Fellow for Policy Studies at Fam-
ily Research Council in Washington, D. C. and the co-author
of Getting It Straight: What the Research Shows about Homo-
sexuality and author of Outrage: How Gay Activists and Liberal
Judges are Trashing Democracy to Redene Marriage.
The homosexual activist movement is now over
forty years old. Conservatives sometimes refer to
the array of goals this movement has pursued
hate crime laws, employment non-discrimina-
tion laws, same-sex marriage, etc.as the
homosexual agenda.
Occasionally, we are mocked for the use of this
term, as though we are suggesting that this move-
ment represents some sinister and shadowy con-
spiracy. However, the term agenda is a perfectly
neutral one. We in the pro-family movement
certainly have our own agenda. Its elements in-
clude: protecting the safety and dignity of human
life from the moment of conception to the mo-
ment of natural death; encouraging the practice
of sexuality only within the context of marriage
between one man and one woman; and promot-
ing the natural family, headed by a married, bio-
logical mother and father, as the ideal setting for
raising children. We are proud of this agenda,
and will continue to vigorously pursue it.
By the same token, homosexual activists have
a clear agenda as well. It is an agenda that de-
mands the universal acceptance of homosexual
acts and relationshipsmorally, socially, legally,
religiously, politically and nancially. Indeed, it
calls for not only acceptance, but afrmation and
celebration of this behavior as normal, natural,
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 111 of 153 Pg ID 1150
and even as desirable for those who desire it.
There is nothing shadowy or secretive about this
agendain fact, it has become nearly impossible
to avoid encountering it.
There is at least one key difference between the
pro-family agenda and the pro-homosexual
agenda. In the case of the pro-family agenda,
there is a growing and impressive body of social
science research and other evidence conrming
that the theoretical foundations of pro-family
policies are sound, and that pro-family practices
benet society. New technologies like advanced
ultrasound imaging and fetal surgery have con-
rmed the essential humanity of the unborn.
Sexual relations outside of marriage have been
shown to lead to an array of negative physical and
psychological consequences. And social science
research has clearly shown that children who are
raised by their own, married, biological mother
and father have a signicant advantage in a broad
range of outcome measures.
The same cannot be said of the homosexual agen-
da. In large measure, the pursuit of this agenda
has involved an effort to dene the benets ho-
mosexuals seek as a matter of civil rights, com-
parable to that which African Americans fought
for in the 1960s; and to dene disapproval of
homosexual conduct as a form of bigotry, com-
parable to a racist ideology of white supremacy.
However, these themes only make sense if, in fact,
a homosexual orientation is a characteristic that
1 Homosexual attractions may be involuntary (but they
are not immutable); engaging in homosexual rela-
tions, however, is clearly voluntary.
3 2
is comparable to race. But racial discrimination is
not wrong merely because a group of people com-
plained loudly and long that it is wrong. Racial
discrimination is irrational and invidious because
of what I call the ve Isthe fact that, as a per-
sonal characteristic, race is inborn, involuntary,
immutable, innocuous and in the Constitution.
Homosexual activists would have us believe that
the same is true of their homosexuality. They
want us to believe that their homosexual orien-
tation is something they are born with, cannot
choose whether to accept or reject, and cannot
change; and that it does no harm (to themselves
or to society), while being protected by the prin-
ciples of the Constitution.
However, these are empirical questions, subject
to being veried or refuted based on the evi-
dence. And the evidence produced by research
has simply not been kind to this theoretical un-
derpinning of the homosexual movement. It has
become more and more clear that none of the
ve-I criteria apply to the choice to engage in
homosexual conduct.
1

The homosexual movement is built, not on facts
or research, but on mythology. Unfortunately,
these myths have come to be widely accepted in
societyparticularly in schools, universities and
the media. It is our hope that by understanding
what these key myths areand then reading a
brief summary of the evidence against them
the reader will be empowered to challenge these
myths when he or she encounters them.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 112 of 153 Pg ID 1151
4
Myth No. 1:
People are born gay.
Fact:
The research does not show that anyone is born
gay, and suggests instead that homosexuality
results from a complex mix of developmental
factors.
The widespread, popular belief that science has
proven a biological or genetic origin to homo-
sexuality can be traced to the publicity which
surrounded three studies published in the early
1990s. In August of 1991, researcher Simon
LeVay published a study based on post-mor-
tem examinations of the brains of cadavers. He
concluded that differences in a particular brain
structure suggested that sexual orientation has a
biological substrate.
2
In December of 1991, re-
searchers J. Michael Bailey and Richard C. Pillard
published a study of identical and fraternal twins
and adoptive brothers, and found that the pat-
tern of rates of homosexuality . . . was generally
consistent with substantial genetic inuence.
3

Finally, in 1993, researcher Dean Hamer claimed
to have found a specic chromosomal region
containing a gene that contributes to homosexu-
al orientation in males.
4

myth 1 - footnotes
2 Simon LeVay, A Difference in Hypothalamic
Structure Between Heterosexual and Homosexual
Men, Science, 253: 1034 (August 1991).
3 J. Michael Bailey and Richard C. Pillard, A
Genetic Study of Male Sexual Orientation, Archives
of General Psychiatry, 48: 1089 (December 1991).
5
These studies suffered from serious methodologi-
cal weaknesses, such as small sample sizes, non-
random samples and even possible mis-classica-
tion of their subjects. Other scientists have been
unable to replicate these dramatic ndings. These
problems led two psychiatrists to conclude,
Critical review shows the evidence favoring a
biologic theory to be lacking. . . . In fact, the
current trend may be to underrate the explana-
tory power of extant psychosocial models.
5
Subsequently, more rigorous studies of identical
twin pairs have essentially made it impossible to
argue for the genetic determination of homo-
sexuality. Since identical (monozygotic, in the
scientic literature) twins have identical genes,
if homosexuality were genetically xed at birth,
we should expect that whenever one twin is ho-
4 Dean H. Hamer, et al., A Linkage Between DNA
Markers on the X Chromosome and Male Sexual
Orientation, Science 261 (1993): 325.
5 William Byne and Bruce Parsons, Human Sexual
Orientation: The Biologic Theories Reappraised,
Archives of General Psychiatry, 50 (March 1993): 228,
236.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 113 of 153 Pg ID 1152
mosexual, the other twin would be homosexual
(a concordance rate of 100%). Even Michael
Bailey himself, co-author of the landmark 1991
twins study (which supposedly found a concor-
dance rate of about 50%), conducted a subsequent
study on a larger sample of Australian twins. As
summarized by other researchers, They found
twenty-seven identical male twin pairs where at
least one of the twin brothers was gay, but in only
three of the pairs was the second twin brother gay
as well
6
(a concordance rate of only eleven per-
cent).
Researchers Peter Bearman and Hannah
Brckner, from Columbia and Yale respectively,
studied data from the National Longitudinal
Study of Adolescent Health, and found even
lower concordance rates of only 6.7% for male
and 5.3% for female identical twins. In fact, their
study neatly refuted several of the biological theo-
ries for the origin of homosexuality, nding social
experiences in childhood to be far more signi-
cant:
[T]he pattern

of concordance (similarity across

pairs) of same-sex preference

for sibling pairs
does

not suggest genetic inuence

independent
of social context.

Our data falsify the

hormone
transfer hypothesis by

isolating a single condi-
6 Stanton L. Jones and Mark A Yarhouse, Ex-gays?
A Longitudinal Study of Religiously Mediated Change
in Sexual Orientation (Downers Grove, Ill.: IVP
Academic, 2007), p. 124; summarizing ndings of:
J. Michael Bailey, Michael P. Dunne, and Nicholas
G. Martin, Genetic and environmental inu-
ences on sexual orientation and its correlates in an
Australian twin sample, Journal of Personality and
Social Psychology, Vol. 78(3), March 2000, 524-536.
6
tion

that eliminates the opposite-sex

twin effect
we observethe

presence of an older

same-sex
sibling. We also

consider and reject a

specula-
tive evolutionary theory that

rests on observing
birth-order

effects on same-sex orientation.

In
contrast, our results

support the hypothesis that

less gendered socialization in

early childhood
and preadolescence

shapes subsequent same-
sex romantic

preferences.
7
If it was not clear in the 1990s, it certainly is
nowno one is born gay.
7
7 Peter S. Bearman and Hannah Brckner, Oppo-
site-Sex Twins and Adolescent Same-Sex Attrac-
tion, American Journal of Sociology Vol. 107, No. 5,
(March 2002), 1179-1205.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 114 of 153 Pg ID 1153
myth 2 - footnotes
8 See Edward O. Laumann, John H. Gagnon, Robert
T. Michael, and Stuart Michaels, The Social Orga-
nization of Sexuality: Sexual Practices in the United
States (Chicago: University of Chicago Press, 1994),
pp. 290-301.
9 Calculated from Tables 2 and 3 in Robert E. Fay,
Charles F. Turner, Albert D. Klassen, John H.
8
Myth No. 2:
Sexual orientation can never change.
Fact:
Thousands of men and women have testied to
experiencing a change in their sexual orientation
from homosexual to heterosexual. Research
conrms that such change does occur
sometimes spontaneously, and sometimes as
a result of therapeutic interventions.
When talking about sexual orientation, one
important clarication must be made. While
most people assume that sexual orientation is
one trait and clearly dened, this is not the case.
Sexual orientation is actually an umbrella term
for three quite different phenomenaa persons
sexual attractions or desires; a persons sexual be-
havior; and a persons self-identication, either
publicly or internally (as gay, lesbian, straight,
etc.). While we tend to assume that a person with
homosexual attractions will also engage in ho-
mosexual relationships and self-identify as gay
or lesbian, survey research on human sexuality
clearly shows that this is not the case. An individ-
uals sexual attractions, sexual behavior and sexual
self-identication are not always consistent with
each other, let alone static over time.
8
This understanding sheds new light on the ques-
tion of whether homosexuality is a choice.
Homosexual attractions are clearly not a choice
in the vast majority of cases. However, it would
actually be insulting to people with same-sex at-
tractions to suggest that they are compelled to act
on those attractions. Homosexual conduct (if it is
consensual) clearly is a choiceas is self-identify-
ing as gay or lesbian. Ones self-identication
can be changed at will, as can ones sexual be-
havior (although perhaps with difcultyjust as
other behavioral habits such as overeating can be
changed).
Although much attention has been focused on
counseling techniques or therapies for unwanted
same-sex attractions and on the work of ex-gay
ministries, there is startling evidence that consid-
erable numbers of people experience signicant
change in some aspects of sexual orientation,
particularly their behavior, quite spontaneously,
without therapeutic intervention. For example,
two studies have found that a large percentage
(46% in one survey,
9
and more than half in an-
other
10
) of all men who have ever engaged in ho-
9
Gagnon, Prevalence and Patterns of Same-Gender
Sexual Contact among Men, Science, New Series,
Vol. 243, Issue 4889 (20 January 1989): 341-42.
10 John H. Gagnon and William Simon, Sexual con-
duct: The social sources of human sexuality (Chicago:
Aldine, 1993), pp. 131-32; cited in Laumann et al.,
p. 289, footnote 8.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 115 of 153 Pg ID 1154
11 At least four sources reporting such cases, published
between 1969 and 1992, are cited in: James E.
Phelan, Neil Whitehead, Philip M. Sutton, What
Research Shows: NARTHs Response to the APA
Claims on Homosexuality, Journal of Human Sexu-
ality Vol. 1 (National Association for Research and
Therapy of Homosexuality, 2009), pp. 23, 30.
12 Stanton L. Jones and Mark A Yarhouse, Homo-
sexuality: The use of scientic research in the churchs
moral debate (Downers Grove, Ill.: InterVarsity
Press, 2000); cited in: James E. Phelan, Neil White-
head, Philip M. Sutton, What Research Shows:
NARTHs Response to the APA Claims on Ho-
10 11
mosexuality, Journal of Human Sexuality Vol. 1
(National Association for Research and Therapy of
Homosexuality, 2009), p. 32.
13 J. Nicolosi, A. D. Byrd, and R. W. Potts, Retro-
spective self-reports of changes in homosexual ori-
entation: A consumer survey of conversion therapy
clients, Psychological Reports 86, pp. 689-702. Cited
in: Phelan et al., p. 12.
14 Stanton L. Jones and Mark A Yarhouse, Ex-gays? A
Longitudinal Study of Religiously Mediated Change in
Sexual Orientation (Downers Grove, Ill.: IVP Aca-
demic, 2007), p. 369.
mosexual conduct did so only before age 15 and
never since.
Ones internal sexual desires or attractions are
undoubtedly the most difcult aspect of sexual
orientation to change, but the evidence demon-
strates that many people have experienced change
in that way as well. Some people in therapy have
experienced signicant reductions in their same-
sex attractions, even when that was not the goal of
therapy, as a result of the resolution of other per-
sonal issues in their lives.
11
One meta-analysis
combining data from thirty studies on reorienta-
tion therapy, conducted between 1954 and 1994,
showed that 33% of subjects had made some shift
toward heterosexuality.
12
Similarly, a survey of
over 800 individuals who had participated in a
variety of efforts to change from a homosexual
orientation found that 34.3% had shifted to an
exclusively or almost exclusively heterosexual ori-
entation.
13
The most methodologically rigorous
(prospective and longitudinal) study yet conduct-
ed, on subjects who had sought change through
religious ministries, which was published in a
414-page book, showed that 38% achieved suc-
cess, dened as either substantial conversion to
heterosexual attraction (15%) or chastity with
homosexual attraction either missing or present
only incidentally.
14

One of the strongest pieces of evidence for the
possibility of change came from an unlikely
sourceDr. Robert Spitzer, a psychiatrist who
was instrumental in the pivotal 1973 decision of
the American Psychiatric Association to remove
homosexuality from its ofcial list of mental dis-
orders. Spitzer studied two hundred people who
had reported some measure of change from a ho-
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 116 of 153 Pg ID 1155
15 Strictly speaking, reparative therapy describes a
specic therapeutic technique which is not used by
all therapists who treat unwanted same-sex attrac-
tions. Change therapy or reorientation therapy
would be more inclusive terms. See Phelan et al., p.
6, footnote 1.
12 13
16 Robert L. Spitzer, M.D., Can Some Gay Men and
Lesbians Change Their Sexual Orientation? 200
Participants Reporting a Change from Homosexual
to Heterosexual Orientation, Archives of Sexual Be-
havior 32, no. 5 (October 2003): 413.
mosexual to a heterosexual orientation as a result
of what is sometimes called reparative therapy
15

for unwanted same-sex attractions. He conclud-
ed,
The changes following reparative therapy were
not limited to sexual behavior and sexual orien-
tation self-identity. The changes encompassed
sexual attraction, arousal, fantasy, yearning,
and being bothered by homosexual feelings.
The changes encompassed the core aspects of
sexual orientation.
16
This is not to say that change is easy, that it is
typically accomplished through prayer or will-
power alone, or that the success of reorientation
therapy can be guaranteed. However, personal
testimonies, survey data and clinical research all
make clear that change from a predominantly ho-
mosexual to a predominantly heterosexual orien-
tation is possible.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 117 of 153 Pg ID 1156
myth 3 - footnotes
17 For example, see Finally Free: Personal Stories: How
Love and Self-Acceptance Saved Us from Ex-Gay
Ministries (Washington, DC: Human Rights Cam-
paign Foundation, July 2000); online at: http://
www.hrc.org/documents/nallyfree.pdf
18 For example, see Bob Davies with Lela Gilbert, Por-
traits of Freedom: 14 People Who Came Out of Homo-
sexuality (Downers Grove, Ill.: InterVarsity Press,
2001).
19 P. H. DeLeon, Proceedings of the American Psy-
chological Association . . . for 1997, American Psy-
chologist 53, pp. 882-939; cited in: James E. Phelan,
Neil Whitehead, Philip M. Sutton, What Research
14
Shows: NARTHs Response to the APA Claims on
Homosexuality, Journal of Human Sexuality Vol. 1
(National Association for Research and Therapy of
Homosexuality, 2009), p. 5.
20 Joseph Nicolosi, A. Dean Byrd, Richard W. Potts,
Retrospective self-reports of changes in homosex-
ual orientation: A consumer survey of conversion
therapy clients, Psychological Reports 86, pp. 1071-
88; cited in Phelan, et al., p. 42.
15
Myth No. 3:
Efforts to change someones sexual orientation
from homosexual to heterosexual are harmful and
unethical.
Fact :
There is no scientic evidence that change efforts
create greater harm than the homosexual lifestyle
itself. The real ethical violation is when clients
are denied the opportunity to set their own goals
for therapy.
Homosexual activists regularly present anecdotal
evidence of the harms suffered by clients of re-
orientation therapists
17
even while simultane-
ously denying the validity of anecdotal evidence
in support of the benets and effectiveness of
such change therapies.
18
Opponents of change
therapies have largely succeeded in codifying
their views in policy statements of the American
Psychological Association, which has expressed
concern about the ethics, efcacy, benets, and
potential for harm of therapies that seek to reduce
or eliminate same-gender sexual orientation.
19

However, the best scientic studies analyzing the
outcome of such change therapies simply do not
validate the claims of substantial harm. In one
survey of over 800 clients of change therapies,
participants were given a list of seventy poten-
tial negative consequences of therapy. Only 7.1%
said they were worse in as many as three of the
seventy categories.
20
The authors of the most
methodologically rigorous study ever conducted
on persons seeking to change from a homosexual
orientation looked for evidence of harm using
standardized measures of psychological dis-
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 118 of 153 Pg ID 1157
21 Stanton L. Jones and Mark A Yarhouse, Ex-gays? A
Longitudinal Study of Religiously Mediated Change in
Sexual Orientation (Downers Grove, Ill.: IVP Aca-
demic, 2007), 333-344.
22 Ibid., 344-349.
23 Ibid., 349-353.
24 Ibid., 359.
25 Robert L. Spitzer, M.D., Can Some Gay Men and
Lesbians Change Their Sexual Orientation? 200
16
Participants Reporting a Change from Homosexual
to Heterosexual Orientation, Archives of Sexual Be-
havior 32, no. 5 (October 2003): 414.
26 Ibid., 413.
27 Online at: http://www.narth.com/
28 Answers to your questions: For a better understanding
of sexual orientation and homosexuality (Washington,
DC: American Psychological Association, 2008), p.
3. Online at: www.apa.org/topics/sorientation.pdf
17
tress,
21
spiritual well-being,
22
and faith matu-
rity.
23
They concluded, We found no empirical
evidence in this study to support the claim that
the attempt to change sexual orientation is harm-
ful.
24
Even Robert Spitzer, a pro-gay psychia-
trist who found that change therapies can be ef-
fective, also declared, For the participants in our
study, there was no evidence of harm.
25

In fact, even some who have failed in efforts to
change their sexual orientation have nevertheless
experienced benets in other areas of their lives
as a result of their participation in reorientation
therapy. Spitzer also acknowledged this point,
declaring:
Even participants who only made a limited
change nevertheless regarded the therapy as
extremely benecial. Participants reported
benet from nonsexual changes, such as de-
creased depression, a greater sense of mascu-
linity in males, and femininity in females, and
developing intimate nonsexual relations with
members of the same sex.
26
It is important to note that responsible reorienta-
tion therapists, such as those afliated with the
National Association for Research and Therapy
of Homosexuality (NARTH),
27
offer their ser-
vices only to those who experience unwanted
same-sex attractions and desire to change. No
one supports forcing any adult into reorientation
therapy against his or her willand such coercion
would be ineffective, since a clients motivation to
change is crucial to the success of therapy. It is
actually the opponents of reparative therapy who
are violating a long-standing ethical principle in
the eld of psychologynamely, the autonomy
of the client to determine his or her own goals
for therapy. Even the American Psychological
Association, which is highly critical of reorienta-
tion therapy, has been forced to afrm, Mental
health professional organizations call on their
members to respect a persons (clients) right to
self-determination . . . .
28
Of course, any form of counseling or psychologi-
cal therapylike any surgery or pharmaceutical
drugmay have unintended negative side effects
for some clients or patients. The question is not
whether some harm is possible. The real question
is whether the potential benets outweigh the po-
tential for harm. Given the potential benet of
mitigating the signicant harms associated with
the homosexual lifestyle itself (see Myths 5 and
6), it seems clear that therapy to overcome a ho-
mosexual orientation easily meets that standard.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 119 of 153 Pg ID 1158
myth 4 - footnotes
29 For two book-length critiques of Kinseys research
and his ethicsor lack thereofsee Judith A. Reis-
man and Edward W. Eichel, Kinsey, Sex and Fraud:
The Indoctrination of a People (Lafayette, La.: Hun-
tington House, 1990); and Judith A. Reisman, Kin-
sey: Crimes & Consequences: The Red Queen and the
Grand Scheme (Arlington, Va.: Institute for Media
Education, 1998).
30 Edward O. Laumann, John H. Gagnon, Robert T.
Michael, and Stuart Michaels, The Social Organiza-
tion of Sexuality: Sexual Practices in the United States
(Chicago: University of Chicago Press, 1994), p. 35.
See also Robert T. Michael, John H. Gagnon, Ed-
18
ward O. Laumann, and Gina Kolata, Sex in America:
A Denitive Survey (Boston: Little, Brown and Co.,
1994), pp. 17-19.
31 Alfred C. Kinsey, Wardell B. Pomeroy, and Clyde
E. Martin, Sexual behavior in the human male (Phila-
delphia: Saunders, 1948), pp. 650-51; cited in: Lau-
mann, et al., The Social Organization of Sexuality, p.
288.
32 See the website of the Kinsey Institute for Research
in Sex, Gender, and Reproduction, online at: http://
www.kinseyinstitute.org/research/ak-hhscale.html
19
Myth No. 4:
Ten percent of the population is gay.
Fact:
Less than three percent of American adults
identify themselves as homosexual or bisexual.
The myth that ten percent of the population is
homosexual arose from the work of the notorious
early sex researcher Alfred Kinsey.
29
His surveys
of the sexual behaviors of Americans in the
1940s have been thoroughly discredited, because
he failed to meet even the most elementary
requirements for drawing a truly representative
sample of the population at large.
30
And Kinsey
did not claim that ten percent of the population
was exclusively homosexual throughout their
lifetimeseven among Kinseys subjects, only
four percent met that standard. Instead, he
claimed that 10 percent of the males are more or
less exclusively homosexual for at least three years . .
. (emphasis added).
31
Indeed, the famous Kinsey
Scale classied sexual orientation on a continuum
(from zero, for exclusively heterosexual, to six, for
exclusively homosexual), based on the assumption
that few people are exclusively homosexual or
exclusively heterosexual.
32
More modern survey data has modied even that
claim. In fact, an overwhelming majority of the
population are exclusively heterosexual. However,
of the small number of people who have ever ex-
perienced homosexuality on any of the three mea-
sures of sexual orientation (attractions, behavior,
and self-identication), the number who have
been exclusively homosexual on all three measures
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 120 of 153 Pg ID 1159
33 Laumann, et al., The Social Organization of Sexuality,
p. 312.
34 Lawrence v. Texas, Docket No. 02-102 (U.S. Supreme
Court), brief of amici curiae Human Rights Cam-
paign et al., 16 January 2003, p. 16 (footnote 42).
35 April 1, 2010.
20 21
and Social Life Survey (NHSLS). The NHSLS
found that 2.8% of the male, and 1.4% of the
female, population identify themselves as gay,
lesbian, or bisexual. See Laumann et al., The
Social Organization of Sex: Sexual Practices in
the United States (1994).
34
1.4%
98.6%
FEMALE POPULATION
2.8%
97.2%
MALE POPULATION
The NHSLS found that 2.8%
of the male population identify
themselves as gay or bisexual.
The NHSLS found that 1.4%
of the female population identify
themselves as gay, lesbian, or bisexual.
So its fair to say that the ten percent myth has
been discredited even by pro-homosexual groups
themselvesyet a recent
35
Google search for the
words ten percent gay still turned up 2,970,000
hits.
throughout their lives is vanishingly smallonly
0.6% of men and 0.2% of women.
33

Even if we go by the measure of self-identica-
tion alone, the percentage of the population who
identify as homosexual or bisexual is quite small.
Convincing evidence of these has come from
an unlikely sourcea consortium of 31 of the
leading homosexual rights groups in America.
In a friend-of-the-court brief they led in the
Supreme Courts Lawrence v. Texas sodomy case
in 2003, they admitted the following:
The most widely accepted study of sexual prac-
tices in the United States is the National Health
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 121 of 153 Pg ID 1160
myth 5 - footnotes
36 James E. Phelan, Neil Whitehead, Philip M. Sut-
ton, What Research Shows: NARTHs Response
to the APA Claims on Homosexuality, Journal of
Human Sexuality Vol. 1, p. 93 (National Association
for Research and Therapy of Homosexuality, 2009).
37 See the very balanced account offered in Ronald
Bayer, Homosexuality and American Psychiatry: The
Politics of Diagnosis (Princeton, N.J.: Princeton Uni-
versity Press, 1981).
38 Ibid., p. 167, citing Sexual Survey #4: Current
Thinking on Homosexuality, Medical Aspects of Hu-
man Sexuality 11 (November 1977), pp. 110-11.
22
Myth No. 5:
Homosexuals do not experience a higher level of
psychological disorders than heterosexuals.
Fact :
Homosexuals experience considerably higher
levels of mental illness and substance abuse than
heterosexuals. A detailed review of the research
has shown that no other group of comparable
size in society experiences such intense and
widespread pathology.
36
One of the rst triumphs of the modern homo-
sexual movement was the removal of homosexu-
ality from the American Psychiatric Associations
ofcial list of mental disorders in 1973. That
decision was far more political than scientic
in nature,
37
and an actual survey of psychiatrists
several years later showed that a large majority
still believed homosexuality to be pathological.
38

Nevertheless, regardless of whether one considers
homosexuality itself to be a mental disorder, there
can be no question that it is associated with higher
levels of a whole range of mental disorders.
39 Ron Stall, Thomas C. Mills, John Williamson,
Trevor Hart, Greg Greenwood, Jay Paul, Lance
Pollack, Diane Binson, Dennis Osmond, Joseph A.
Catania, Association of Co-Occurring Psychoso-
cial Health Problems and Increased Vulnerability
to HIV/AIDS Among Urban Men Who Have Sex
With Men, American Journal of Public Health, Vol.
93, No. 6 (June 2003), p. 941.
40 Ibid., 940-42.
23
Ron Stall, one of the nations leading AIDS re-
searchers, has been warning for years that ad-
ditive psychosocial health problemsotherwise
known collectively as a syndemicexist among
urban MSM
39
[men who have sex with men].
For example, in 2003, his research team reported
in the American Journal of Public Health that ho-
mosexual conduct in this population is associated
with higher rates of multiple drug use, depres-
sion, domestic violence and a history of having
been sexually abused as a child.
40
Findings released in 2005 from an on-going,
population-based study of young people in New
Zealand showed that homosexuality is
. . . associated with increasing rates of depres-
sion, anxiety, illicit drug dependence, suicidal
thoughts and attempts. Gay males, the study
shows, have mental health problems ve times
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 122 of 153 Pg ID 1161
41 Study: Young Gay Men At Higher Risk Of Sui-
cide, 365Gay.com, August 2, 2005; online at: http://
www.365gay.com/newscon05/08/080205suicide.
htm (page not available February 13, 2010; on le
with author).
42 Michael King, Joanna Semlyen, Sharon See Tai,
Helen Killaspy, David Osborn, Dmitri Popelyuk

and Irwin Nazareth, A systematic review of mental
disorder, suicide, and deliberate self harm in lesbian,
gay and bisexual people, BMC Psychiatry 2008, 8:70
(August 18, 2008); online at: http://www.biomed-
central.com/content/pdf/1471-244X-8-70.pdf
43 Victor M. B. Silenzio, Top 10 Things Gay Men
Should Discuss with their Healthcare Provider
(San Francisco: Gay & Lesbian Medical Associa-
tion); accessed April 1, 2010; online at: http://www.
glma.org/_data/n_0001/resources/live/Top%20
Ten%20Gay%20Men.pdf
44 Katherine A. OHanlan, Top 10 Things Lesbians
Should Discuss with their Healthcare Provider
(San Francisco: Gay & Lesbian Medical Associa-
tion); accessed April 1, 2010; online at: http://www.
glma.org/_data/n_0001/resources/live/Top%20
Ten%20Lesbians.pdf
45 Theo G. M. Sandfort, Ron de Graaf, Rob V.
Bijl, Paul Schnabel, Same-Sex Sexual Behavior
and Psychiatric Disorders: Findings From the
Netherlands Mental Health Survey and Incidence
Study (NEMESIS), Archives of General Psychiatry
58 (January 2001), pp. 88-89.
24 25
higher than young heterosexual males. Lesbi-
ans have mental health problems nearly twice
those of exclusively heterosexual females.
41
A 2008 meta-analysis reviewed over 13,000 pa-
pers on this subject and compiled the data from
the 28 most rigorous studies. Their conclusion
was: LGB [lesbian, gay, bisexual] people are at
higher risk of mental disorder, suicidal ideation,
substance misuse and deliberate self harm than
heterosexual people.
42
Even the pro-homosexual Gay & Lesbian
Medical Association (GLMA) acknowledges:
Gay men use substances at a higher rate than
the general population . . .
Depression and anxiety appear to affect gay
men at a higher rate . . . .
. . . [G]ay men have higher rates of alcohol
dependence and abuse . . . .
. . . [G]ay men use tobacco at much higher
rates than straight men . . . .
Problems with body image are more com-
mon among gay men . . . and gay men are
much more likely to experience an eating
disorder . . . .
43
The GLMA also conrms that:
. . . [L]esbians may use tobacco and smok-
ing products more often than heterosexual
women use them.
Alcohol use and abuse may be higher among
lesbians.
. . . [L]esbians may use illicit drugs more
often than heterosexual women.
44
Homosexual activists generally attempt to explain
these problems as results of homophobic dis-
crimination. However, there is a serious problem
with that theorythere is no empirical evidence
that such psychological problems are greater in
areas where disapproval of homosexuality is more
intense. On the contrary, even a study in the
Netherlandsperhaps the most gay-friendly
country in the worldshowed a higher preva-
lence of substance use disorders in homosexual
women and a higher prevalence of mood and
anxiety disorders in homosexual men.
45
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 123 of 153 Pg ID 1162
Myth No. 6:
Homosexual conduct is not harmful to ones
physical health.
Fact:
Both because of high-risk behavior patterns,
such as sexual promiscuity, and because of
the harm to the body from specic sexual
acts, homosexuals are at greater risk than
heterosexuals for sexually transmitted diseases
and other forms of illness and injury.
The most obvious and dramatic example of the
negative consequences of homosexual conduct
among men is the AIDS epidemic. In 2009, a
gay newspaper reported, Gay and bisexual men
account for half of new HIV infections in the
U.S. and have AIDS at a rate more than 50 times
greater than other groups, according to Centers
for Disease Control & Prevention data . . . .
46

Through 2007, 274,184 American men had died
of AIDS whose only risk factor was sex with
other men. When men who had sex with men
and engaged in injection drug use are added to
that total, we nd that more than two thirds of
the total male AIDS deaths in America (68%)
have been among homosexual men.
47

HIV/AIDS is not the only sexually transmitted
disease for which homosexual men are at risk.
myth 6 - footnotes
46 Dyana Bagby, Gay, bi men 50 times more likely to
have HIV: CDC reports hard data at National HIV
Prevention Conference, Washington Blade, August
28, 2009.
47 Centers for Disease Control and Prevention. HIV/
AIDS Surveillance Report, 2007. Vol. 19. Atlanta:
U.S. Department of Health and Human Services,
Centers for Disease Control and Prevention; 2009;
p. 19. http://www.cdc.gov/hiv/topics/surveillance/
resources/reports/
48 Centers for Disease Control and Prevention, Vi-
ral Hepatitis And Men Who Have Sex With Men,
online at: http://www.cdc.gov/hepatitis/Popula-
tions/msm.htm (accessed February 5, 2010).
26 27
The CDC warns, Men who have sex with men
(MSM) are at elevated risk for certain sexually
transmitted diseases (STDs), including Hepatitis
A, Hepatitis B, HIV/AIDS, syphilis, gonorrhea,
and chlamydia.
48
As early as 1976even before the onset of the
AIDS epidemicdoctors had identied a clini-
cal pattern of anorectal and colon diseases en-
countered with unusual frequency in . . . [male]
homosexual patients, resulting from the practice
of anal intercourse, which they dubbed the gay
bowel syndrome. An analysis of 260 medical
records reported in the Annals of Clinical and
Laboratory Science found:
The clinical diagnoses in decreasing order of
frequency include condyloma acuminata, hem-
orrhoids, nonspecic proctitis, anal stula,
perirectal abscess, anal ssure, amebiasis, be-
nign polyps, viral hepatitis, gonorrhea, syphilis,
anorectal trauma and foreign bodies, shigellosis,
rectal ulcers and lymphogranuloma venereum.
. . . In evaluating proctologic problems in the
gay male, all of the known sexually transmitted
diseases should be considered. . . . Concurrent
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 124 of 153 Pg ID 1163
49 H. L. Kazal, N. Sohn, J. I. Carrasco, J. G. Robi-
lotti, and W. E. Delaney, The gay bowel syndrome:
clinico-pathologic correlation in 260 cases, Annals
of Clinical and Laboratory Science 1976, Vol 6, Issue
2, 184-192; abstract online at: http://www.annclin-
labsci.org/cgi/content/abstract/6/2/184
50 Amy L. Evans, Andrew J. Scally, Sarah J. Wellard,
Janet D. Wilson, Prevalence of bacterial vaginosis
in lesbians and heterosexual women in a commu-
nity setting, Sexually Transmitted Infections 2007;
83:470-475; abstract; online at: http://sti.bmj.com/
content/83/6/470.abstract
51 Victor M. B. Silenzio, Top 10 Things Gay Men
Should Discuss with their Healthcare Provider
(San Francisco: Gay & Lesbian Medical Associa-
tion); accessed April 1, 2010; online at: http://www.
glma.org/_data/n_0001/resources/live/Top%20
Ten%20Gay%20Men.pdf
52 Katherine A. OHanlan, Top 10 Things Lesbians
Should Discuss with their Healthcare Provider
(San Francisco: Gay & Lesbian Medical Associa-
tion); accessed April 1, 2010; online at: http://www.
glma.org/_data/n_0001/resources/live/Top%20
Ten%20Lesbians.pdf
28 29
infections with 2 or more pathogens should be
anticipated.
49

Although not as dramatic, similar problems are
also found among lesbians. In 2007, a medical
journal reported, Women who identied as les-
bians have a 2.5-fold increased likelihood of BV
[bacterial vaginosis] compared with heterosexual
women.
50
As with mental health problems (see Myth No.5),
the Gay and Lesbian Medical Association has
neatly summarized the elevated risks to physical
health experienced by homosexuals:
That men who have sex with men are at an
increased risk of HIV infection is well known
. . . . However, the last few years have seen the
return of many unsafe sex practices.
Men who have sex with men are at an in-
creased risk of sexually transmitted infection
with the viruses that cause the serious con-
dition of the liver known as hepatitis. These
infections can be potentially fatal, and can
lead to very serious long-term issues such as
cirrhosis and liver cancer.
Sexually transmitted diseases (STDs) occur in
sexually active gay men at a high rate. This
includes STD infections for which effective
treatment is available (syphilis, gonorrhea,
chlamydia, pubic lice, and others), and for
which no cure is available (HIV, Hepatitis A,
B, or C virus, Human Papilloma Virus, etc.).
Of all the sexually transmitted infections gay
men are at risk for, human papilloma virus
which cause anal and genital warts is often
thought to be little more than an unsightly
inconvenience. However, these infections
may play a role in the increased rates of anal
cancers in gay men. . . . [R]ecurrences of the
warts are very common, and the rate at which
the infection can be spread between partners
is very high.
51
Lesbians also face signicant risks, according to
the GLMA:
Lesbians have the richest concentration of risk
factors for breast cancer than [sic] any subset
of women in the world.
Smoking and obesity are the most prevalent
risk factors for heart disease among lesbians
. . .
Lesbians have higher risks for many of the
gynecologic cancers.
Research conrms that lesbians have higher
body mass than heterosexual women. Obesity
is associated with higher rates of heart dis-
ease, cancers, and premature death.
52
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 125 of 153 Pg ID 1164
myth 7 - footnotes
53 Kristin Anderson Moore, et al., 2002. Marriage
from a Childs Perspective: How Does Family
Structure Affect Children and What Can We Do
About It?, Child Trends Research Brief (Washington,
D.C.: Child Trends) (June): 1 (available at http://
www.childtrends.org/PDF/MarriageRB602.pdf).
54 Kyle D. Pruett, Fatherneed: Why Father Care is as Es-
sential as Mother Care for Your Child (New York: The
Free Press, 2000).
55 Brenda Hunter, The Power of Mother Love: Trans-
forming Both Mother and Child (Colorado Springs:
Waterbrook Press, 1997).
56 Robert Lerner and Althea K. Nagai, No Basis: What
the Studies Dont Tell Us About Same Sex Parenting
(Washington: Ethics and Public Policy Center,
2001).
30 31
Myth No. 7:
Children raised by homosexuals are no different
from children raised by heterosexuals, nor do they
suffer harm.
Fact:
An overwhelming body of social science
research shows that children do best when
raised by their own biological mother and father
who are committed to one another in a lifelong
marriage. Research specically on children
of homosexuals has major methodological
problems, but does show specic differences.
Few ndings in the social sciences have been
more denitively demonstrated than the fact
that children do best when raised by their own
married mother and father. The non-partisan re-
search group Child Trends summarized the evi-
dence this way:
Research clearly demonstrates that family
structure matters for children, and the family
structure that helps the most is a family headed
by two biological parents who are in a low-con-
ict marriage.
53
Homosexual activists say that having both a
mother and a father does not matterit is hav-
ing two loving parents that counts. But social sci-
ence research simply does not support this claim.
Dr. Kyle Pruett of Yale Medical School, for ex-
ample, has demonstrated in his book Fatherneed
that fathers contribute to parenting in ways that
mothers do not.
54
On the other hand, Dr. Brenda
Hunter has documented the unique contribu-
tions that mothers make in her book, The Power
of Mother Love.
55
The truth is that most research on homosexu-
al parents thus far has been marred by serious
methodological problems.
56
However, even pro-
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 126 of 153 Pg ID 1165
homosexual sociologists Judith Stacey and Timo-
thy Biblarz report that the actual data from key
studies show the no differences claim to be false.
Surveying the research (primarily regarding lesbi-
ans) in an American Sociological Review article in
2001, they found that:
Children of lesbians are less likely to conform
to traditional gender norms.
Children of lesbians are more likely to engage
in homosexual behavior.
Daughters of lesbians are more sexually ad-
venturous and less chaste.
Lesbian co-parent relationships are more
likely to break up than heterosexual mar-
riages.
57
Footnotes for Myth 7
57 Judith Stacey and Timothy J. Biblarz, (How) Does
the Sexual Orientation of Parents Matter, American
Sociological Review 66 (2001), pp. 159-83.
58 Sotirios Sarantakos, Children in three contexts:
Family, education and social development, Children
Australia 21, No. 3 (1996): 23-31.
32 33
A 1996 study by an Australian sociologist com-
pared children raised by heterosexual married
couples, heterosexual cohabiting couples and ho-
mosexual cohabiting couples. It found that the
children of heterosexual married couples did the
best, and children of homosexual couples did the
worst, in nine of the thirteen academic and social
categories measured.
58
The clear superiority (in outcomes for children)
of households with a married, biological mother
and father; the limited but revealing research on
children raised by homosexual parents; and the
inherent mental and physical health risks (see
Myths 5 and 6) and dysfunctional behaviors (see
Myths 8 and 10) associated with homosexual re-
lationshipsall of these combine to suggest that
we should be exceedingly cautious about deliber-
ately placing children in the care of homosexuals,
whether through foster care, adoption, or the use
of articial reproductive technologies.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 127 of 153 Pg ID 1166
Myth No. 8:
Homosexuals are no more likely to molest
children than heterosexuals.
Fact:
The percentage of child sexual abuse cases in
which men molest boys is many times higher
than the percentage of adult males who are
homosexual, and most men who molest boys
self-identify as homosexual or bisexual.
If this myth were true, it would support the no-
tion that homosexuals should be allowed to work
with children as schoolteachers, Boy Scout lead-
ers and Big Brothers or Big Sisters. However, it
is not true. The research clearly shows that same-
sex child sexual abuse (mostly men molesting
boys) occurs at rates far higher, proportionally,
than adult homosexual behavior, and it strongly
suggests that many of those abusers are homo-
sexual in their adult orientation as well.
As this is perhaps the most explosive claim about
homosexuals, a couple of clarications are in or-
der. This does not mean that all homosexuals are
child molestersno one has ever claimed that. It
does not even mean that most homosexuals are
child molestersthere is no evidence to support
that. But there is evidence that the relative rate
of child sexual abuse among homosexuals is far
higher than it is among heterosexuals.
myth 8 - footnotes
59 John Briere, et al., eds., The APSAC Handbook on
Child Maltreatment (Thousand Oaks, California:
Sage Publications, 1996), pp. 52, 53.
This conclusion rests on three key facts:
Pedophiles are invariably males: A report
by the American Professional Society on the
Abuse of Children states: In both clinical and
non-clinical samples, the vast majority of of-
fenders are male.
59
The book Sexual Offending
Against Children reports that only 12 of 3,000
incarcerated pedophiles in England were
women.
60
Signicant numbers of victims are males: A
study of 457 male sex offenders against chil-
dren in Journal of Sex & Marital Therapy found
that approximately one-third of these sexual
offenders directed their sexual activity against
60 Dawn Fisher, Adult Sex Offenders: Who are They?
Why and How Do They Do It? in Tony Morrison,
et al., eds., Sexual Offending Against Children (Lon-
don: Routledge, 1994), p. 11.
34 35
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 128 of 153 Pg ID 1167
61 Kurt Freund, et al., Pedophilia and Heterosexuality
vs. Homosexuality, Journal of Sex & Marital Thera-
py 10 (1984): 197.
62 Kurt Freund, Robin Watson, and Douglas Rienzo,
Heterosexuality, Homosexuality, and Erotic Age
Preference, The Journal of Sex Research 26, No. 1
(February, 1989): 107.
63 W. D. Erickson, Behavior Patterns of Child Mo-
lesters, Archives of Sexual Behavior 17 (1988): 83.
64 Edward O. Laumann, John H. Gagnon, Robert
T. Michael, and Stuart Michaels, The Social Orga-
nization of Sexuality: Sexual Practices in the United
States (Chicago: University of Chicago Press, 1994),
p. 293Altogether, 2.8 percent of the men and 1.4
percent of the women reported some level of homo-
sexual (or bisexual) identity.
65 See Bruce Rind, Gay and bisexual adolescent
boys sexual experiences with men: An empiri-
cal examination of psychological correlates in a
nonclinical sample, Archives of Sexual Behavior
Vol. 30, Issue 4, August 1, 2001; also Jessica L.
Stanley, Kim Bartholomew, Doug Oram, Gay and
Bisexual Mens Age-Discrepant Childhood Sexual
Experiences, The Journal of Sex Research, Vol. 41,
Number 4, November, 2004: pp. 381-389: online
at: http://ndarticles.com/p/articles/mi_m2372/
is_4_41/ai_n9488757/
36 37
males.
61
A study in the Journal of Sex Research
found that although heterosexuals outnumber
homosexuals by a ratio of at least 20 to 1, ho-
mosexual pedophiles commit about one-third
of the total number of child sex offenses.
62
Many pedophiles consider themselves to be
homosexual: Many people who write about
the issue of pedophilia argue that most men
who molest boys are merely attracted to chil-
dren, not to adult males, but they do not cite
any specic data to support that assertion. In
fact, a study of 229 convicted child molest-
ers in Archives of Sexual Behavior found that
eighty-six percent of offenders against males
described themselves as homosexual or bisex-
ual.
63

Since almost thirty percent of child sexual abuse is
committed by homosexual or bisexual men (one-
third male-on-male abuse times 86% identifying
as homosexual or bisexual), but less than 3% of
American men identify themselves as homosex-
ual or bisexual,
64
we can infer that homosexual or
bisexual men are approximately ten times more
likely to molest children than heterosexual men.
In addition to the actual data on elevated rates
of homosexual child abuse, there is clearly a sub-
culture among homosexual men that openly cel-
ebrates the idea of sexual relationships between
adult men and underage boys, whether pre-pu-
bescent or adolescent. Such relationships are re-
ferred to in some research literature using neutral-
sounding euphemisms such as age-discrepant
sexual relations (ADSRs)
65
or intergenerational
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 129 of 153 Pg ID 1168
38 39
66 Gerald P. Jones, The Study of Intergenerational
Intimacy in North America: Beyond Politics and
Pedophilia, Journal of Homosexuality, Vol. 20, Is-
sue 1 & 2 (February 1990), pp. 275 295. This en-
tire journal of the Journal of Homosexualityat least
nineteen articleswas devoted to this topic.
67 Paula Martinac, Do We Condone Pedophilia,
PlanetOut.com, February 27, 2002.
intimacy.
66
Lesbian writer Paula Martinac sum-
marized this phenomenon:
. . . [S]ome gay men still maintain that an
adult who has same-sex relations with some-
one under the legal age of consent is on some
level doing the kid a favor by helping to bring
him or her out. . . . [A]dult-youth sex is
viewed as an important aspect of gay culture,
with a history dating back to Greek love of
ancient times. This romanticized vision of
adult-youth sexual relations has been a staple
of gay literature and has made appearances,
too, in gay-themed lms. . . .
Last summer, I attended a reading in which
a gay poet read a long piece about being
aroused by a irtatious young boy in his
charge. In response, the man went into the
boys bedroom and [sexually abused the boy
as he] slept. . . . Disturbingly, most of the gay
audience gave the poet an appreciative round
of applause. . . .
. . . The lesbian and gay community will nev-
er be successful in ghting the pedophile ste-
reotype until we all stop condoning sex with
young people.
67
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 130 of 153 Pg ID 1169
Myth No. 9:
Homosexuals are seriously disadvantaged by
discrimination.
Fact:
Research shows that homosexuals actually
have signicantly higher levels of educational
attainment than the general public, while
the ndings on homosexual incomes are, at
worst, mixed.
One obvious measure of social disadvantage in
America is reduced educational attainment. For
example, this is an area in which there are ob-
vious racial differences. According to 2008 data
from the Census Bureau, 21.1% of non-Hispanic
whites over the age of 25 have at least a bachelors
degree, while the same is true of only 13.6% of
blacks and 9.4% of Hispanics.
68
However, studies have uniformly shown that ho-
mosexuals have higher levels of education than
heterosexuals, which hardly suggests that they
are disadvantaged. The groundbreaking National
Health and Social Life Survey found that twice
as many college-educated men identify them-
selves as homosexual as men with high-school
educations. . . . For women the trend is even
more striking. Women with college educations
myth 9 - footnotes
68 Calculated from tables in Educational Attainment
of the Population 18 Years and Over, by Age, Sex,
Race, and Hispanic Origin: 2008, U.S. Census Bu-
reau; online at: http://www.census.gov/population/
www/socdemo/education/cps2008.html
69 Robert T. Michael, John H. Gagnon, Edward
O. Laumann, and Gina Kolata, Sex in America: A
Denitive Survey (Boston: Little, Brown and Co.,
1994), p. 182.
are eight times more likely to identify themselves
as lesbians . . . .
69
One study of homosexual men,
using data from the Urban Mens Health Study,
reported that 65.7 percent of the respondents
fall within the relatively narrow range of having
a B.A. or an M.A.
70
The data on the incomes of homosexuals tends to
be more mixed. Some data, drawn primarily from
marketing surveys, suggest that homosexuals have
considerably higher incomes than heterosexu-
als. For example, a 2009 survey of over 20,000
readers of gay magazines and newspapers found
that they had an average household income of
about $80,000;
71
whereas the Census Bureau re-
70 Donald C. Barrett, Lance M. Pollack, and Mary
L. Tilden Teenage Sexual Orientation, Adult
Openness, and Status Attainment in Gay Males,
Sociological Perspectives, 45 (2002): 170.
71 Community Marketing, Inc., Gay & Lesbian Con-
sumer Index, November 25, 2009: online at: http://
www.communitymarketinginc.com/mkt_int_gld.php
40 41
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 131 of 153 Pg ID 1170
72 Carmen DeNavas-Walt, Bernadette D. Proctor,
and Jessica C. Smith, U.S. Census Bureau, Current
Population Reports, P60-236, Income, Poverty, and
Health Insurance Coverage in the United States: 2008
(Washington, DC: U.S. Government Printing
Ofce, 2009), p. 5; online at: http://www.census.
gov/prod/2009pubs/p60-236.pdf
73 For example, see M. V. Lee Badgett, Income Ina-
tion: The Myth of Afuence Among Gay, Lesbian, and
Bisexual Americans, Joint publication of NGLTF
Policy Institute and Institute for Gay and Lesbian
Strategic Studies, 1998; online at: http://www.the-
taskforce.org/downloads/reports/reports/IncomeIn-
ationMyth.pdf
74 Randy Albelda, M. V. Lee Badgett, Alyssa Schnee-
baum, and Gary Gates, Poverty in the Lesbian, Gay,
and Bisexual Community, the Williams Institute,
UCLA School of Law, March 2009, p. i; online at:
http://www.law.ucla.edu/williamsinstitute/pdf/LG-
BPovertyReport.pdf
75 Heather Antecol, Anneke Jong, and Michael D.
Steinberger, Sexual Orientation Wage Gap: The
Role of Occupational Sorting and Human Capital,
Industrial & Labor Relations Review Vol. 61, Issue 4,
p. 523: online at: http://digitalcommons.ilr.cornell.
edu/cgi/viewcontent.cgi?article=1346&context=ilrre
view
76 Marieka M. Klawitter and Victor Flatt, The Effects
of State and Local Antidiscrimination Policies on
Earnings for Gays and Lesbians, Journal of Policy
Analysis and Management, 17 (4): 676 (1998).
ports that the average household income for all
Americans in 2008 was only $50,303.
72
Other researchers have argued that such surveys
may not be reaching a truly representative sample
of American homosexuals. Lesbian economist
M. V. Lee Badgett has virtually made a career of
debunking what she calls the myth of gay and
lesbian afuence.
73
But even Badgett nds the
data are, at worst, mixed. A 2009 publication on
poverty in the lesbian, gay, and bisexual commu-
nity which she co-authored, found that accord-
ing to one national study, both homosexual men
and women were more likely to live in poverty
than heterosexuals, but in one California study,
both were less likely to do so. And census data
which applies only to couples shows that same-
sex female couples are more likely to be in poverty
than opposite-sex married couples, but same-sex
male couples are less likely to live in poverty than
are opposite-sex married couples.
74
A 2008 study using data on couples available
from the 2000 census reported:
Lesbian women earned substantially more than
both married and cohabiting women. . . . While
gay men suffered a small wage penalty relative to
their married counterparts (4.5%), they actually
enjoyed a large wage advantage relative to their
cohabiting counterparts (28.2%).
75
Homosexual activists like to attribute the small
disadvantage in income for some subpopulations
of homosexuals to societal discrimination, and
use that as an argument for employment non-
discrimination laws. However, other explana-
tions, such as different career choices, are also
possible.
If discrimination presented serious limits to the
economic opportunities available to homosexu-
als, one would expect non-discrimination laws
to improve their economic standing. However,
research has not shown such laws to have that ef-
fect. A journal article on the issue declared,
In contrast to studies of antidiscrimination laws for
women and ethnic minorities, we have produced
no evidence that employment protections for
sexual orientation directly increase average
earnings for members of same-sex households.
76
42 43
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 132 of 153 Pg ID 1171
Myth No. 10:
Homosexual relationships are just the same as
heterosexual ones, except for the gender of the
partners.
Fact:
Homosexuals are less likely to enter into
a committed relationship, less likely to be
sexually faithful to a partner, even if they have
one, and are less likely to remain committed
for a lifetime, than are heterosexuals. They also
experience higher rates of domestic violence
than heterosexual married couples.
Homosexual men and women are far less likely
to be in any kind of committed relationship than
heterosexuals are. A 2006 study by researchers at
UCLA concluded:
We found that lesbians, and particularly gay
men, are less likely to be in a relationship com-
pared to heterosexual women and men. Perhaps
the most outstanding nding is also the most
simplethat over half of gay men (51%) were
not in a relationship. Compared to only 21% of
heterosexual females and 15% of heterosexual
males, this gure is quite striking.
77
Secondly, even homosexuals (especially men)
who are in a partnered relationship are much less
likely to be sexually faithful to that partner.
myth 10 - footnotes
77 Charles Strohm, et al., Couple Relationships
among Lesbians, Gay Men, and Heterosexuals in
California: A Social Demographic Perspective, Pa-
per presented at the annual meeting of the Ameri-
can Sociological Association, Montreal Conven-
tion Center, Montreal, Quebec, Canada, (Aug 10,
2006): 18. Accessed at: http://www.allacademic.
com/meta/p104912_index.html
78 Maria Xiridou, et al, The Contribution of Steady
and Casual Partnerships to the Incidence of HIV
Infection among Homosexual Men in Amsterdam,
AIDS 17 (2003): 1031.
79 Ryan Lee, Gay Couples Likely to Try Non-
monogamy, Study Shows, Washington Blade
(August 22, 2003): 18.
A Dutch study of partnered homosexuals,
which was published in the journal AIDS,
found that men with a steady partner had
an average of eight sexual partners per year.
78
A Canadian study of homosexual men who
had been in committed relationships lasting
longer than one year found that only 25 per-
cent of those interviewed reported being mo-
nogamous. According to study author Barry
Adam, Gay culture allows men to explore
different . . . forms of relationships besides
the monogamy coveted by heterosexuals.
79
A 2005 study in the journal Sex Roles found that
40.3% of homosexual men in civil unions and
49.3% of homosexual men not in civil unions had
discussed and decided it is ok under some cir-
cumstances to have sex outside of the relation-
44 45
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 133 of 153 Pg ID 1172
80 Sondra E. Solomon, Esther D. Rothblum, and
Kimberly F. Balsam, Money, Housework, Sex, and
Conict: Same-Sex Couples in Civil Unions, Those
Not in Civil Unions, and Heterosexual Married
Siblings, Sex Roles 52 (May 2005): 569.
81 Lawrence Kurdek, Are Gay and Lesbian Cohab-
iting Couples Really Different from Heterosexual
Married Couples? Journal of Marriage and Family
66 (November 2004): 893.
82 Ibid., 896.
83 P. A. Brand and A. H. Kidd, Frequency of physical
aggression in heterosexual and female homosexual
dyads, Psychological Reports 59, pp. 1307-1313;
cited in James E. Phelan, Neil Whitehead, Philip
M. Sutton, What Research Shows: NARTHs
Response to the APA Claims on Homosexuality,
Journal of Human Sexuality Vol. 1, p. 85 (National
Association for Research and Therapy of Homo-
sexuality, 2009).
84 Bryan N. Cochran and Ana Mari Cauce,
Characteristics of lesbian, gay, bisexual, and trans-
gender individuals entering substance abuse treat-
ment, Journal of Substance Abuse Treatment Vol. 30,
Issue 2 (March 2006), pp. 135-146.
ship. By comparison, only 3.5% of heterosexual
married men and their wives agreed that sex out-
side of the relationship was acceptable.
80
Finally, research shows that homosexual relation-
ships tend to be of shorter duration and much
less likely to last a lifetime than heterosexual ones
(especially heterosexual marriages). A 2005 jour-
nal article cites one large-scale longitudinal study
comparing the dissolution rates of heterosexual
married couples, heterosexual cohabiting couples,
homosexual couples, and lesbian couples:
On the basis of the responses to the follow-up
survey, the percentage of dissolved couples was
4% (heterosexual married couples), 14% (het-
erosexual cohabiting couples), 13% (homosex-
ual couples) and 18% (lesbian couples).
81
In other words, the dissolution rate of homosex-
ual couples during the period of this study was
more than three times that of heterosexual married
couples, and the dissolution rate of lesbian cou-
ples was more than four-fold that of heterosexual
married couples.
82
Since men are generally more likely to engage in
acts of violence than women, it is not surprising
that there would be differences in rates of domes-
tic violence based on the gender of partners in a
relationship. One might expect, for instance, that
women with a female partner would be less likely
to be abused than women with a male partner.
However, one early study (1986) showed that
women with female partners were nearly as likely
to be abused (25%) as those with male partners
(27%).
83

Meanwhile, a 2002 study showed that the ve-
year prevalence of battering among urban ho-
mosexual men (22%) was nearly double the rate
among heterosexual women living with men
(11.6%)despite the fact that one might expect
mens greater size and strength to be a deterrent
against a would-be batterer. A 2006 studyone
of the few with a direct homosexual/heterosexual
comparison for both men and womenfound
that of persons entering substance abuse pro-
grams, 4.4% of homosexuals had been abused by
a partner in the last month, as opposed to 2.9% of
the heterosexuals. The lifetime prevalence rates
for domestic violence were 55% for the homo-
sexuals and 36% for heterosexuals.
84
The myth that homosexual relationships in gen-
eral are qualitatively the same as heterosexual
relationshipa myth that is crucial to the current
push for legalization of same-sex marriageis
simply not borne out by the evidence.
46 47
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 134 of 153 Pg ID 1173
32

FAMILY RESEARCH COUNCIL


The Family Research Council champions marriage
and family as the foundation of civilization, the
seedbed of virtue, and the wellspring of society. We
shape public debate and formulate public policy that
values human life and upholds the institutions of
marriage and the family. Believing that God is the
author of life, liberty, and the family, we promote the
Judeo-Christian worldview as the basis for a just, free,
and stable society.
Located in the heart of Washington, D.C., the
headquarters of the Family Research Council
provides its staff with strategic access to government
decision-making centers, national media ofces, and
information sources.
To order these resources or to see more FRC publications,
visit our website at www. frc.org or call 800-225-4008.

ADDITIONAL RESOURCES FROM


FAMILY RESEARCH COUNCIL
Outrage: How Gay Activists and Liberal
Judges are Trashing Democracy to Redene
Marriage BK04H01
Here is the book America needs to
make sense of the debate over same-
sex marriage. Author Peter Sprigg
demolishes stereotypes on this issue,
showing why homosexual civil marriage
should be opposed by libertarians,
Democrats, women, men, and even
homosexuals themselves. Sprigg
demonstrates that this culture war was
not started by conservatives, but by homosexual
activists and radical judges.
Washington Update wusub
Family Research Councils agship subscription: a daily email update with
the latest pro-family take on Washingtons hottest issues. Complimentary
Take Action Alerts catsub
Alerts notify you about opportunities to actively participate in Family
Research Council efforts to uphold pro-life, pro-family, and pro-freedom
values in Washington. Complimentary
Homosexuality Is Not a Civil Right BC0701
This pamphlet claries certain misconceptions
about the meaning of discrimination and of civil
rights and explains why homosexual conduct is
not comparable to other characteristics usually
protected by civil rights laws. Protection against
private discrimination has historically been
offered only for characteristics that are inborn,
involuntary, immutable, innocuous, and/or in
the Constitution-yet none of these describe
homosexual behavior.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 135 of 153 Pg ID 1174
ATTACHMENT L

2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 136 of 153 Pg ID 1175
BioMed Central
Page 1 of 17
(page number not for citation purposes)
BMC Psychiatry
Open Access
Research article
A systematic review of mental disorder, suicide, and deliberate self
harm in lesbian, gay and bisexual people
Michael King*
1,2
, Joanna Semlyen
1
, Sharon See Tai
3
, Helen Killaspy
1,2
,
David Osborn
1,2
, Dmitri Popelyuk
1
and Irwin Nazareth
3,4
Address:
1
Department of Mental Health Sciences, Royal Free and University College Medical School, Hampstead Campus, University College
London, London, NW3 2PF, UK,
2
Camden and Islington Mental Health and Social Care Trust, St Pancras Hospital, London, NW1, UK,
3
Department of Primary Care and Population Sciences, Royal Free and University College Medical School, Hampstead Campus, University College
London, London, NW3 2PF, UK and
4
General Practice Research Framework, Medical Research Council, 158-60 North Gower Street, London, NW1
2ND, UK
Email: Michael King* - m.king@medsch.ucl.ac.uk; Joanna Semlyen - josemlyen@hotmail.com; Sharon See Tai - s.seetai@pcps.ucl.ac.uk;
Helen Killaspy - h.killaspy@medsch.ucl.ac.uk; David Osborn - d.osborn@medsch.ucl.ac.uk; Dmitri Popelyuk - d_popelyuk@hotmail.com;
Irwin Nazareth - i.nazareth@pcps.ucl.ac.uk
* Corresponding author
Abstract
Background: Lesbian, gay and bisexual (LGB) people may be at higher risk of mental disorders than heterosexual
people.
Method: We conducted a systematic review and meta-analysis of the prevalence of mental disorder, substance misuse,
suicide, suicidal ideation and deliberate self harm in LGB people. We searched Medline, Embase, PsycInfo, Cinahl, the
Cochrane Library Database, the Web of Knowledge, the Applied Social Sciences Index and Abstracts, the International
Bibliography of the Social Sciences, Sociological Abstracts, the Campbell Collaboration and grey literature databases for
articles published January 1966 to April 2005. We also used Google and Google Scholar and contacted authors where
necessary. We searched all terms related to homosexual, lesbian and bisexual people and all terms related to mental
disorders, suicide, and deliberate self harm. We included papers on population based studies which contained concurrent
heterosexual comparison groups and valid definition of sexual orientation and mental health outcomes.
Results: Of 13706 papers identified, 476 were initially selected and 28 (25 studies) met inclusion criteria. Only one study
met all our four quality criteria and seven met three of these criteria. Data was extracted on 214,344 heterosexual and
11,971 non heterosexual people. Meta-analyses revealed a two fold excess in suicide attempts in lesbian, gay and bisexual
people [pooled risk ratio for lifetime risk 2.47 (CI 1.87, 3.28)]. The risk for depression and anxiety disorders (over a
period of 12 months or a lifetime) on meta-analyses were at least 1.5 times higher in lesbian, gay and bisexual people (RR
range 1.542.58) and alcohol and other substance dependence over 12 months was also 1.5 times higher (RR range 1.51
4.00). Results were similar in both sexes but meta analyses revealed that lesbian and bisexual women were particularly
at risk of substance dependence (alcohol 12 months: RR 4.00, CI 2.85, 5.61; drug dependence: RR 3.50, CI 1.87, 6.53;
any substance use disorder RR 3.42, CI 1.975.92), while lifetime prevalence of suicide attempt was especially high in gay
and bisexual men (RR 4.28, CI 2.32, 7.88).
Conclusion: LGB people are at higher risk of mental disorder, suicidal ideation, substance misuse, and deliberate self
harm than heterosexual people.
Published: 18 August 2008
BMC Psychiatry 2008, 8:70 doi:10.1186/1471-244X-8-70
Received: 16 June 2008
Accepted: 18 August 2008
This article is available from: http://www.biomedcentral.com/1471-244X/8/70
2008 King et al; licensee BioMed Central Ltd.
This is an Open Access article distributed under the terms of the Creative Commons Attribution License (http://creativecommons.org/licenses/by/2.0),
which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 137 of 153 Pg ID 1176
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 6, 2013
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 2 of 17
(page number not for citation purposes)
Background
Lesbian, gay and bisexual (LGB) people appear to be at
greater risk than heterosexual people of mental disorders
and suicidal behaviour [1,2]. LGB people are subject to
institutionalised prejudice, social stress, social exclusion
(even within families) and anti-homosexual hatred and
violence and often internalise a sense of shame about
their sexuality [1,2]. Lifestyle factors such as alcohol and
drugs misuse also increase the risk of morbidity [1] as well
as suicide attempts [3]. Deliberate self harm (DSH) is
intentional self poisoning or injury, irrespective of the
apparent purpose of the act. DSH is one of the leading
causes of acute medical admissions in the UK. Incidence
rose steadily from the mid 1980s to the late 1990s with a
peak incidence rate of 400 per 100,000 per annum [4],
one of the highest in Europe. However there is evidence of
a steady drop in suicide in England (and other developed
countries) since 2000 [5]. The evidence on mental health
of LGB people is inconclusive partly because of the diffi-
culty of defining or recruiting samples that are representa-
tive of all non-heterosexual people. Specific
methodological obstacles include variation in the defini-
tion of sexual orientation, DSH and mental illness; diffi-
culty in achieving random samples; reliance on
participants' recall; unwillingness of people to be open
about their sexual orientation; lack of information on sex-
uality in suicide victims who are part of psychological post
mortem studies; the complexity of choosing appropriate
comparison groups and poor or absent adjustment for
confounding influences such as substance use and per-
sonality factors.
There is an urgent need to quantify the risk for mental dis-
order, DSH and suicide in LGB people, to understand the
precipitants and to examine the efficacy of prevention
efforts. There is also a need to make a judgement about
the quality of the evidence available. We undertook a sys-
tematic review of the world literature on risk of mental
disorder, substance misuse, DSH, suicidal ideation and
suicide in LGB people. These parameters are the main
ones reported in the literature and provide a comprehen-
sive picture of mental health and well being.
Hypothesis
Gay, lesbian and bisexual people have higher risks than
heterosexual people of mental disorder, substance misuse
and dependence, suicide, suicidal ideation and DSH.
Objective
To undertake a systematic review of the international
research literature to establish whether LGB people are at
higher risk of mental disorder, substance misuse, suicide,
suicidal ideation and DSH than heterosexual people and
to quantify this risk.
Method
We searched for studies of mental disorder, drug and alco-
hol misuse and dependence, DSH, suicidal ideation and/
or suicide in general (community) or selected (e.g. stu-
dent) populations in which sexual orientation was
reported. We use the following abbreviations: GB (gay
and bisexual men); LB (lesbians and bisexual women)
and LGB (lesbians, gay men and bisexual men and
women).
Data sources
We searched Medline, Embase, PsycInfo, Cinahl, the
Cochrane Library Database, the Web of Knowledge, the
Applied Social Sciences Index and Abstracts, the Interna-
tional Bibliography of the Social Sciences, Sociological
Abstracts, the Campbell Collaboration and grey literature
databases for articles published between January 1966
and April 2005. We searched all terms related to homosex-
ual, lesbian and bisexual people and all terms related to
mental disorders, suicide, and deliberate self harm. No
language limits were imposed. A full internet search was
also carried out using Google and Google Scholar and
authors were contacted where necessary. We also searched
the reference lists of relevant papers.
Study selection
Eligibility
We included papers that provided valid definition of sex-
ual orientation and mental health outcomes. Random
sampling is hampered by participants' reluctance to dis-
close their sexual orientation and the small numbers of
LGB people recruited. Thus other methods such as snow-
ball sampling (initial LGB participants recruit other LGB
people in successive waves) were regarded as acceptable if
the study met other inclusion criteria. We included studies
in which people defined themselves as: gay, lesbian,
homosexual, bisexual and/or in which they reported lev-
els of same sex attraction or behaviour. We excluded stud-
ies based in clinical or psychological services. We only
included studies in which there was a concurrent hetero-
sexual comparison group within either a cohort, case-con-
trol or cross sectional study. Outcomes were defined as: a)
a psychiatric disorder according to the International Clas-
sification of Diseases or the American Psychiatric Associa-
tion's Diagnostic and Statistical Manual (including
substance misuse disorders); b) scores or a recognised
threshold for psychiatric morbidity on standardised scales
(including alcohol or drug dependence); c) alcohol mis-
use: consumption above UK Government recommended
maximum weekly limits (21 units men, 14 units women);
d) suicide (the intentional taking one's own life) e) sui-
cidal ideation (i.e. thoughts of taking one's life without
acting on them); f) DSH: intentional self poisoning or
injury irrespective of the apparent purpose of the act [5].
These outcomes were extracted for both the LGB and het-
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 138 of 153 Pg ID 1177
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 3 of 17
(page number not for citation purposes)
erosexual comparison groups as cumulative incidence
rates in prospective cohort studies or period prevalence
rates in cross sectional studies.
Screening process and assessment of eligibility
The titles and abstracts of citations were screened by JS
and DP and those not meeting eligibility criteria, unpub-
lished dissertation theses, case reports, letters, commen-
taries, or review papers were excluded. Decisions on
papers included in the final review were made by pairs of
authors and disagreements discussed at steering group
meetings involving all authors.
Data extraction
At least two of the authors extracted data from each paper
on study setting, study design, population and sampling
details, attrition and response rate. We recorded the defi-
nition of LGB sexual orientation (same sex attraction;
same sex behaviour; self identification as lesbian gay or
bisexual; a score above zero on the Kinsey scale [6]) and
outcome (mental disorder, substance misuse, DSH, sui-
cidal ideation and suicide). Where appropriate we
extracted prevalence estimates and/or odds ratios; for con-
tinuous data we extracted means and standard deviations.
In instances of disagreement, each case was discussed by
all authors.
Quality of studies reviewed
We used the Cochrane Handbook's general guidance on
non-experimental studies to inform our choice of quality
indicators (2 indicating higher quality than 1). We exam-
ined for: sampling: non random = 1, random = 2; represent-
ativeness: response rates: <60% = 1, 60% or more = 2;
population definition: selected sample (e.g. school students)
= 1; general population = 2 and sample size: <100 LB or GB
people = 1, >100 LB or GB people = 2.
Data synthesis
Studies were grouped according to lifetime or 12 month
prevalence and where possible we analysed outcomes for
lesbians, gay men and bisexual people separately and col-
lectively. We calculated risk ratios and attributable risks
(differences between rates in LGB and non LGB people)
from extracted prevalence data. We examined suicide
attempts when reported instead of or in addition to DSH.
For continuous outcomes we calculated the effect size as
standardised mean difference in scores between LGB peo-
ple and controls.
Meta-analytic approach
We adopted standard methods for conducting meta-anal-
yses where there were two or more studies with useable
outcome data. We used a random effects model which
used inverse variance methods to calculate the pooled
effect estimate in which the weight given to each study is
the inverse of the variance of the study estimate together
with the common heterogeneity variance. We quantified
the effect of heterogeneity [7] by using I
2
which describes
the percentage of total variation across studies that can be
attributed to heterogeneity rather than chance [8].
Results
From 13706 citations identified, 476 papers were
retrieved of which 429 were excluded (figure 1). Eighty-
three of those excluded were controlled studies [36-120],
122123]; two [39,40] were excluded because the data
were repeated elsewhere [29]; seven did not meet sam-
pling criteria [36-38,75,76,118,119]; 34 did not report
suicide, DSH or diagnostic outcomes [41-74]; 37 involved
unrepresentative populations [77-113] and three on
closer inspection did not concern LGB people [114-116].
There were insufficient data in three studies on completed
suicide to include it as an outcome in the review. One that
involved suicide in a cohort of bisexual and gay men was
excluded because it was uncontrolled [117]; one study
comparing clinical characteristics of a subpopulation of
gay and non-gay male suicides was excluded because of
Study inclusion process Figure 1
Study inclusion process.


Pot ent ially r elevant t it les ident ified on
sear ch
N = 13706
Full t ext papers r et r ieved f or pot ent ial inclusion
N = 476

Dat a papers
N= 111
Papers excluded:
134 uncont r olled st udies
212 review paper/ comment ary
Papers excluded [ N = 83] :
37 not a populat ion based st udy
34 not a psychiat ric diagnosis
7 poor sampling
2 duplicat ed dat a
3 not about LGB

Papers excluded:
3257 duplicat es
8873 by t it le
999 by abst ract
101 dissert at ions

Qualit at ive Paper s
N = 19
Paper s i ncl uded
N = 28
Number of st udi es
N= 25
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 139 of 153 Pg ID 1178
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 4 of 17
(page number not for citation purposes)
sampling concerns [118] and a psychological autopsy
study carried out in 1995 [119] was excluded as it con-
tained only three gay male suicides.
Study characteristics
Twenty-eight papers [1,9-35] reporting on 25 studies [1,9-
12,14,15,17-31,33-35] met our inclusion criteria (Addi-
tional file 1); six papers [12,13,15,16,31,32] reported data
on three studies. Five studies could not be included in a
meta-analysis because the data were not extractable or in
a format that allowed comparison [10,11,22,27,34].
Three of the four longitudinal cohorts [11,18,33] pre-
sented nested cross-sectional data on sexual orientation
and mental health at one time point. One cohort study,
however, conducted a longitudinal analysis of cumulative
incidence of suicidal attempts but did not provide extract-
able data [34]. No case-control studies were identified.
The studies were conducted in seven countries in North
America, Europe and Australasia, with most based in the
USA (17/25, 67%). The papers were published between
1997 and 2004, with two thirds published between 2000
and 2003. Participation rates ranged from 25% [23] to
95% [28].
Population
The papers contained data on 214,344 heterosexual and
11,971 non heterosexual people aged 12 and over. Four
studies involved people aged under 18 [10,17,29,30] and
18 involved people under 25 years. Four studies included
only women [11,20,24,26], three only men [9,14,21] and
18 both sexes. Eight studies [10,17,21,25,26,28-30,34]
concerned high school and college students. Of the 21
cross sectional studies, nine used random sampling
[9,15,19,20,22,25,26,31,35]; two multi-stage sampling
[12,14]; two snowball sampling [1,24]; one systematic
sampling (i.e. 26 years follow up data on a birth cohort)
[23]; and seven did not specify their sampling method
[10,17,21,27-30].
Definition of sexuality
Sexuality was defined in a number of ways even within the
same study: four studies used same sex attraction
[24,30,33,34]; 13 used same sex behaviour
[9,10,12,14,17-19,21,24,29-31,34,35]; 15 used partici-
pant self identification [1,9-11,15,18,20,22,23,25-29];
and three used a score above zero on the Kinsey scale
[1,28,34] (see Additional file 1). Nine studies used two
definitions of sexual orientation [1,9,10,18,24,28-30,35]
and one used three definitions [34]. Self-identified sexual-
ity was based on the categories heterosexual, homosexual
or bisexual [9,15,18,20,22,23,28] or included the choices
gay or lesbian [1,10,11,25-27,29]. Eighteen studies used a
specific time frame to assess sexuality. Lifetime same sex
attraction was assessed in two studies [30,33]; current
same sex attraction assessed in four [24,33-35] and in one
study both were assessed [33]. Same sex behaviour was
assessed as occurring 'in the last year' in two studies
[12,24], 'in the last five years' in one study [19] or 'ever' in
nine studies [9,10,14,17,18,21,29,30,34].
Outcomes of interest
Fifteen studies assessed suicide attempts or DSH
[1,9,10,14,17-19,21,23,24,28-30,33,34] and 12 assessed
suicidal ideation [14,17-19,21-24,26,28,30,33]. Data on
mental disorder were assessed in 10 studies
[1,9,11,12,14,15,18,19,22,31], substance dependence in
six studies [12,15,18,19,31,35] and substance misuse in
nine studies [1,19,20,22,25-27,31,35]. Eighteen studies
assessed more than one of these outcomes
[1,9,12,14,15,17-19,21-24,26,28,30,31,33,35] and one
study assessed all [19]. Risk ratios and attributable risks
were calculated for all outcomes of interest (figures 2, 3, 4,
5, 6, 7, 8, 9).
Quality of cross sectional studies
Nine studies were based on random populations but only
seven of these were sampled from the community rather
than from specific groups (e.g. schools). Only four of
these reported responses of at least 60% and of these only
one [19] sampled 100 or more LGB people (table 1).
Data syntheses
Suicide attempts and DSH
Only one cohort study [34] reported cumulative incidence
of suicide attempts over two years in 2924 Norwegian
school youths. They reported an odds ratio of 4.69 (95%
CI 2.29, 10.62) for LB girls after adjustment but no signif-
icant differential for BG boys.
Meta-analyses of cross-sectional studies of lifetime suicide
attempts demonstrated increased risk in all groups when
compared to heterosexuals but there was substantial het-
erogeneity when these data were combined for both sexes
and for men only (Figure 2). Attributable risk ranged from
0.03 to 0.25 and was higher in men than women. Studies
in this analysis were limited by small samples
[9,14,18,33] or selection bias [18,23,28,33] (Table 1).
One small study that met all but one quality criteria
showed a high risk of suicide attempts in men (Figure 2)
[9]. Meta-analysis in women demonstrated 1.82 times
increased risk of lifetime suicide attempts in lesbians and
bisexuals compared to controls and showed little hetero-
geneity (Figure 2). However, all the studies failed to meet
several of our quality indicators.
Risk ratios for 12 month prevalence of suicide attempts
ranged from 1.96 to 2.76 (men 2.23 to 2.53; women 1.94
to 2.46), while attributable risk ranged from 0.01 to 0.14
(men 0.01 to 0.03; women 0.01 to 0.07). The pooled esti-
mate for men and women was 2.56 (Figure 2) with similar
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 140 of 153 Pg ID 1179
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 5 of 17
(page number not for citation purposes)
Forest plots for lifetime and 12 month prevalence of suicide attempts Figure 2
Forest plots for lifetime and 12 month prevalence of suicide attempts.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 141 of 153 Pg ID 1180
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 6 of 17
(page number not for citation purposes)
values for LB and GB people and all showed little or no
heterogeneity. The highest quality study [19], however,
showed a non significant risk ratio for all groups.
Only two studies reported lifetime prevalence of DSH
[1,33] (Figure 3) and meta-analyses of these data pro-
duced equivocal results. One further study that met all but
one of our quality criteria reported elevated risk of lifetime
prevalence of DSH and/or suicide attempts [9] in gay
rather than bisexual men (RR: Gay = 3.61, CI 1.86, 7.01;
Bisexual men = 1.95, CI 0.73, 5.19).
Suicidal ideation
Meta-analyses of lifetime prevalence of suicidal ideation
revealed risk ratios of 2.04 for both sexes (range: both
sexes 1.72 to 2.42; men 2.0 to 4.10; women 1.75 to 2.10)
with considerable heterogeneity. Attributable risk ranged
from 0.10 to 0.40 (Figure 4). All studies included in this
analysis were limited by selection bias [23,24] and small
samples [12,17].
The combined meta-analysis of 12 month prevalence of
suicidal ideation contained some heterogeneity in both
sexes and in women, but none in men. The risk ratio in
both sexes was 1.71 (men 1.64; women 2.31) while attrib-
utable risk ranged from 0.02 to 0.21 (men 0.02 to 0.13;
women 0.02 to 0.21). One study that met all four quality
criteria [19] demonstrated over three times the risk in
women but not in men. The other studies were limited by
selection of very young populations [17,28,30,33,26] or
low participation rates [26].
In summary, there were elevated risks for suicide attempts
and ideation in LGB people but quality of studies was lim-
ited. Data from higher quality studies showed higher
cumulative incidence of suicide in LB school girls,
increased lifetime risk of suicide attempts in GB men and
increased 12 months risk of suicidal ideation in LB
women.
Mental disorders depression
Three studies reported lifetime prevalence of depression
[14,18,31]. Increased risk of lifetime depression was
observed in both sexes and men with little heterogeneity
in the analyses (Figure 5). One of the two studies that met
all but one quality criteria demonstrated a risk ratio of 2.2
Forest plots for lifetime prevalence of deliberate self harm Figure 3
Forest plots for lifetime prevalence of deliberate self harm.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 142 of 153 Pg ID 1181
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 7 of 17
(page number not for citation purposes)
Forest plots for lifetime and 12 month prevalence of suicide ideation Figure 4
Forest plots for lifetime and 12 month prevalence of suicide ideation.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 143 of 153 Pg ID 1182
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 8 of 17
(page number not for citation purposes)
Forest plots for lifetime and 12 month prevalence of depression Figure 5
Forest plots for lifetime and 12 month prevalence of depression.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 144 of 153 Pg ID 1183
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 9 of 17
(page number not for citation purposes)
in both sexes; 2.68 in men (Figure 5); and 2.21 (CI 1.57,
3.12) in women [31].
The risk of 12 months prevalence of depression in LGB
people on meta-analysis was at least twice that of hetero-
sexual controls with little heterogeneity (Figure 5). All
studies in this analysis were of good quality based on gen-
eral population samples with high participation rates.
Risk ratios ranged from 1.57 to 3.74 (men 1.57 to 3.74;
women 1.67 to 3.69) and attributable risk from two stud-
ies ranged from 0.04 to 0.20 (men 0.04 to 0.20; women
0.04 to 0.22). The only study that met the highest stand-
ard on the four quality criteria demonstrated significantly
higher risk ratios and attributable risk for women but not
men [19]. Lastly, a study of 45 gay and 37 bisexual men
that recorded depression on a standardised scale and met
all but one of our quality criteria showed a small but pos-
itive effect size indicating more depression in gay or bisex-
ual men (standardised mean difference in depression
score 0.16) [9].
Forest plots for 12 month prevalence of anxiety Figure 6
Forest plots for 12 month prevalence of anxiety.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 145 of 153 Pg ID 1184
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 10 of 17
(page number not for citation purposes)
Mental disorders anxiety
Two studies reported lifetime prevalence of any anxiety
disorder and both met all but one of the quality criteria
[18,31]. Although their data could not be combined in a
meta-analysis, increased risk was reported in both sexes
(RR 2.28 CI 1.25, 4.21) [18] and in men (RR 2.40, CI 1.72,
3.35) [31], but not in women (RR 1.02, CI 0.61, 1.70)
[31]. The meta-analyses of data on 12 month prevalence
of any anxiety disorder (Figure 6) resulted in a pooled RR
of 1.54 for both sexes and 1.88 in men with little hetero-
geneity. Attributable risk ranged from 0.00 to 0.17 (men
0.01 to 0.12; women 0.00 to 0.17). The result in women
was less convincing because of heterogeneity. The only
study of the four in this analysis that met the highest of all
four of our quality criteria demonstrated an elevated risk
of 1.75 in women [19]. All the studies were based on gen-
eral population samples and were of reasonable quality.
Forest plots for 12 month prevalence of alcohol dependence Figure 7
Forest plots for 12 month prevalence of alcohol dependence.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 146 of 153 Pg ID 1185
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 11 of 17
(page number not for citation purposes)
In summary, on the basis of studies of relatively good
quality, there was an elevated risk of lifetime and 12
month prevalence of depression and anxiety disorders in
all LGB groups compared to heterosexual controls.
Alcohol misuse
Data from a single study that met all but one of our high-
est quality criteria showed increased risk of lifetime prev-
alence of alcohol dependence in both sexes (RR 2.59 CI
1.62, 4.15) and women (RR 6.51, CI 2.74, 15.44) but not
in men (RR 1.60, CI 0.91, 2.80) [31]. All the studies in this
analysis met at least three of our four quality criteria. Risk
ratios for alcohol dependence in the previous 12 months
in both sexes ranged from 1.76 to 3.05 and were higher in
women (Figure 8). Attributable risk for alcohol depend-
ence over 12 months was higher in women (Figure 8).
Two studies presented data in accordance with our defini-
tion of alcohol misuse within the previous 12 months.
McCabe et al (2003) [25] reported little difference
between LGB people and controls, but Gruskin et al
(2001) [20] reported higher risk of alcohol misuse (RR
3.52, CI 1.97, 6.26) in LB than heterosexual women, with
an attributable risk of 7%.
Drug misuse or any substance misuse disorder
One study reported higher risks of lifetime prevalence of
drug dependence in both sexes (RR 4.32, CI 2.14, 8.72),
men (RR 2.71, CI 1.01, 7.37) and in women (RR 7.74, CI
Forest plots for 12 month prevalence of drug dependence Figure 8
Forest plots for 12 month prevalence of drug dependence.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 147 of 153 Pg ID 1186
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 12 of 17
(page number not for citation purposes)
2.88, 20.75) [31]. Meta-analyses of data on drug depend-
ence over the previous 12 months showed 2.73 times
greater risk in both sexes, 3.5 times greater in women and
2.41 times greater in men than controls (Figure 9). Attrib-
utable risk for drug dependence in the previous 12
months ranged from 0.002 to 0.05 in both sexes, in men
0.03 to 0.05 and women 0.02 to 0.04 (Figure 9).
One good quality study [31] of lifetime prevalence of any
substance use disorder showed elevated risk in women
(RR 3.61 CI 2.13, 6.11, attributable risk 0.11 to 0.26) but
not men (RR 1.05, CI 0.76, 1.47; attributable risk -0.08 to
0.11). Similar findings arose in the meta-analyses of data
from two good quality studies on 12 months prevalence
of any substance use disorder (figure 9).
Forest plots for lifetime and 12 month prevalence of any substance use disorder Figure 9
Forest plots for lifetime and 12 month prevalence of any substance use disorder.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 148 of 153 Pg ID 1187
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 13 of 17
(page number not for citation purposes)
In summary, there was an increased lifetime and 12
month risk of alcohol and drug dependency in all groups
compared with heterosexuals with markedly higher risk in
lesbian and bisexual women.
Discussion
LGB people are at higher risk of suicidal behaviour, men-
tal disorder and substance misuse and dependence than
heterosexual people. The results of the meta-analyses
demonstrate a two fold excess in risk of suicide attempts
in the preceding year in men and women, and a four fold
excess in risk in gay and bisexual men over a lifetime. Sim-
ilarly, depression, anxiety, alcohol and substance misuse
were at least 1.5 times more common in LGB people.
Findings were similar in men and women but LB women
were at particular risk of substance dependence, while life-
time risk of suicide attempts was especially high in GB
men.
Strengths and limitations of the review
We found 25 studies that met our inclusion criteria for
epidemiological rather than clinical studies. Our search
terms included all possible subcategories of mental disor-
der and substance dependence. We identified a wide range
of study methods but excluded designs that provided
biased or erroneous estimates. We included studies with
consistent definitions of sexual orientation and with con-
temporaneous comparison groups. However, the lower
than expected prevalence of LGB people in several of the
population surveys [27,31,32] indicates that many studies
were unable to recruit a representative sample. Thus, it is
likely that a proportion of LGB people are reluctant to par-
ticipate in research for all sorts of reasons, but most likely
for fear of disclosure. Until it becomes less risky to identify
oneself as LGB for the purposes of research we shall know
little about this hidden population or how it influences
the conclusions we can make here. All studies used well-
described and potentially replicable mental health out-
comes. However, only one study met all four of our qual-
ity criteria, while seven met all but one of our quality
markers. The number of studies in each meta-analysis was
relatively small and thus we were unable to interpret fun-
nel plots to investigate sources of bias or run a meta-
regression analysis to account for the variable quality of
the studies identified in this review.
Given the range of study design and definitions of expo-
sure and outcome, we encountered significant heteroge-
neity in our meta-analyses. However, these estimates did
not deviate markedly from data reported in the better
Table 1: Classification of quality indicators of studies included in the review
Sampling Participation rate Population Sample size
1 = Non-random 1<60% 1 = Selected 1<100
2 = Random 2 t 60% 2 = General 2 t 100
Bagley 1997 [9] 2 2 2 1
Bontempo & D'Augelli 2002 [10] Not known 2 1 2
Case et al. 2004 [11]* 1 2 1 2
Cochran & Mays (2000a) & Mays, Ross (2004) [12,13] 1 2 2 1
Cochran & Mays (2000b) [14] 1 2 2 1
Cochran et al. 2003 & Mays & Cochran (2001) [15,16] 2 2 2 1
Faulkner et al. (1998) [17] Not known 1 1 2
Fergusson et al 1999 [18]* 1 2 1 1
Gilman et al. 2001 [19] 2 2 2 2
Gruskin et al. 2001 [20] 2 1 2 2
Herrell et al. 1999 [21] Not known 2 1 2
Jorm et al. 2002 [22] 2 1 2 2
King et al. 2003 [1] 1 NA 1 2
Mathy 2002 [23] 1 1 1 2
Mathews et al. 2002 [24] 1 1 1 2
McCabe et al. 2003 [25] 2 1 1 2
Mc Cabe et al. 2004 [26] 2 1 1 1
Nawyn et al. 2000 [27] Not known 1 1 1
Remafedi et al. 1998 [28] Not known 2 1 2
Robin et al. 2002 [29] Not known 2 1 2
Russell & Joyner 2001 [30] Not known Not known 1 2
Sandfort et al. 2001 & Sandfort, de Graf, Bijl (2003) [31,32] 2 2 2 1
Skegg et al. 2003 [33]* 1 2 1 1
Wichstrom & Hegna 2003 [34]* 1 2 1 2
Drabble et al. 2005 [35] 2 Not known 2 2
Key: * Longitudinal studies; 2 suggests higher quality and than 1
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 149 of 153 Pg ID 1188
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 14 of 17
(page number not for citation purposes)
quality studies. Although, in some studies reported data
were weighted or shown as percentages, our calculated
risk ratios were similar to unadjusted ratios reported in
these papers making it unlikely that we have extrapolated
beyond the studies' findings. The distinction between sui-
cide attempt and DSH was often unclear. We followed
authors' definitions of the acts and did not judge the life
threatening nature of the behaviour. Finally, uncertainties
inherent in defining and recruiting a representative sam-
ple of LGB people cannot be overcome in a systematic
review. For example, participants may be asked about
their sexuality in ways that are unfamiliar to them or it
may be assumed that sexual orientation is a fixed life-time
characteristic. Despite these reservations about our
review, the consistent direction of our findings suggests
that mental health is poorer in LGB people.
Selection of studies
We had to exclude otherwise well conducted research that
was based in specialised populations or in health services
or that selected LGB people in a particular way. We wish
to highlight three studies that we eventually excluded on
grounds of selection of the LGB population [36-38]; but
whose results were broadly in the direction of our find-
ings. Russell & Keel (2002) [36] reported data on depres-
sion using the Beck Depression Inventory; van Heeringen
& Vincke (2000) [38] reported data on suicide attempts
and ideation and Savin-Williams (2001) [37] reported
data on suicide attempts.
Explanations for our findings
Our study aimed to determine whether there was une-
quivocal evidence for a preponderance of mental health
problems in LGB people relative to heterosexuals. Thus,
circumspection is required when discussing possible
mechanisms which generate them [120]. Although our
evidence does not specify the nature of such mechanisms,
there is no evidence to suggest that homosexuality is itself
a disorder that is thereby subject to a higher co-morbidity
than is found in heterosexuals [120]. This review was
strictly limited to documenting whether or not there was
an excess of mental health problems in LGB people. It will
take other, prospective research to investigate the compo-
nents of this vulnerability. Unfortunately prospective
studies were unusual among the 25 reviewed here and
thus we cannot say much with certainty about the risk fac-
tors for mental disorder in LGB people. Nevertheless, it is
likely that the social hostility, stigma and discrimination
that most LGB people experience is at least part of the rea-
son for the higher rates of psychological morbidity
observed. This may be aggravated by easy access to alcohol
and drugs in gay venues that LGB people frequent both to
find the company of others who will accept them less crit-
ically and to meet potential partners. However, why LB
women are at greater risk of substance misuse than GB
men is not clear as most LGB commercial venues provide
alcohol.
Implications of our findings
It is of considerable concern that sexual minorities such as
LGB people suffer so many disadvantages in terms of
mental health. Our findings need consideration in plan-
ning public health and clinical services, as well as in terms
of international human rights. Although we cannot report
on whether or not LGB people are at greater risk than het-
erosexuals for completed suicide, the elevated risks for all
forms of mental disorder, DSH and substance misuse
would suggest very strongly that this is the case. Thus,
national suicide strategies need to include LGB people as
a high risk group now rather than await more evidence on
suicide. The hidden nature of sexual orientation makes it
very unlikely that we shall be able to show definitely in
post-mortem psychological studies that LGB are over-rep-
resented among suicide victims.
Conclusion and further research
Besides more qualitative and case-control research, we
need prospective studies as these are most likely to reveal
the mechanisms involved. Although, in this review we
identified four cohorts [15,18,33,34] only one collected
prospective data on suicidal risk in lesbian, gay and bisex-
ual people [34]. Prospective studies, however, are difficult
to undertake as many people cannot or will not identify
themselves as LGB until late adolescence or even young
adulthood when the emotional damage may already have
occurred. Nevertheless, a cohort of young LGB people
who are followed through as they complete education and
career training and start relationships and families, would
begin to address this difficult issue. We also need to
address the complexities of defining sexual orientation.
Most modern conceptions of sexual orientation consider
personal identification, sexual behaviour and sexual fan-
tasy [121]. Thus, we chose these parameters as the most
pragmatic and commonly used definitions for this review.
However, we need more detailed study of the develop-
ment of sexuality across the spectrum of partner prefer-
ence, its stability over time and its relationship to other
preferences and behaviour.
Competing interests
The authors declare that they have no competing interests
Authors' contributions
MK, HK, DO, IN and SST obtained funding for the study.
JS and DP conducted the literature search, obtained
papers and extracted data. JS, MK, HK, DO, IN and DP
scanned abstracts and read papers. SST conducted the
meta-analysis with input from IN and MK. MK drafted the
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 150 of 153 Pg ID 1189
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 15 of 17
(page number not for citation purposes)
paper and all authors contributed to the final version. All
authors read and approved the final version.
Additional material
Acknowledgements
The study was funded by a grant from the National Institute for Mental
Health England. The funder had no involvement in the conduct of the
research. We thank Rosalind Lai M Lib, Medical Librarian, for constructing
the search strategy.
References
1. King M, McKeown E, Warner J, Ramsay A, Johnson K, Cort C, Wright
L, Blizard R, Davidson O: Mental health and quality of life of gay
men and lesbians in England and Wales: a controlled, cross-
sectional study. British Journal of Psychiatry 2003, 183:552-558.
2. Meyer IH: Prejudice, social stress and mental health in lesbian,
gay and bisexual populations: conceptual issues and research
evidence. Psychological Bulletin 2003, 129:674-697.
3. Gibson P: Gay male and lesbian youth suicide. US Depart-
ment of Health and Human Services: Report of the Secre-
tary's Task Force on Youth Suicide. Volume 3. Washington DC,
Government Printing Office; 1989:115-142.
4. NHS Centre for Reviews and Dissemination Deliberate Self
Harm. 1989, 4(6):.
5. National Institute for Mental Health in England: National Suicide
Prevention Strategy for England. Annual Report on Progress 2006.
6. Kinsey AC, Pomeroy WB, Martin CE: Sexual behaviour in the
Human Male. Saunders, Philadelphia; 1948.
7. Egger M, Schneider M, Davey-Smith G: Spurious precision? Meta-
analysis of observational studies. British Medical Journal 1998,
316:140-144.
8. Higgins JPT, Thompson SG, Deeks JJ, Altman DG: Measuring incon-
sistency in meta-analyses. British Medical Journal 2003,
327:557-560.
9. Bagley C, Tremblay P: Suicidal behaviors in homosexual and
bisexual males. Crisis 1997, 18(1):24-34.
10. Bontempo DE, D'Augelli AR: Effects of at-school victimization
and sexual orientation on lesbian, gay, or bisexual youths'
health risk behavior. Journal of Adolescent Health 2002,
30(5):364-374.
11. Case P, Bryn Austin S, Hunter DJ, Manson JE, Malspeis S, Willett W,
Speigelman D: Sexual Orientation, Health Risk Factors, and
Physical Functioning in the Nurses' Health Study II. Journal of
Women's Health 2004, 13:1033-1047.
12. Cochran SD, Mays VM: Relation between psychiatric syn-
dromes and behaviorally defined sexual orientation in a sam-
ple of the US population. American Journal of Epidemiology 2000,
151(5):516-523.
13. Cochran SD, Ackerman D, Mays VM, Ross MW: Prevalence of
non-medical drug use and dependence among homosexually
active men and women in the US population. Addiction 2004,
99(8):989-998.
14. Cochran SD, Mays VM: Lifetime prevalence of suicide symp-
toms and affective disorders among men reporting same-sex
sexual partners: Results from NHANES III. American Journal of
Public Health 2000, 90(4):573-578.
15. Cochran SD, Sullivan JG, Mays VM: Prevalence of mental disor-
ders, psychological distress, and mental services use among
lesbian, gay, and bisexual adults in the United States. Journal
of Consulting and Clinical Psychology 2003, 71(1):53-61.
16. Mays VM, Cochran SD: Mental health correlates of perceived
discrimination among lesbian, gay, and bisexual adults in the
United States. American Journal of Public Health 2001,
91(11):1869-1876.
17. Faulkner AH, Cranston K: Correlates of same-sex sexual behav-
ior in a random sample of Massachusetts high school stu-
dents. American Journal of Public Health 1998, 88(2):262-266.
18. Fergusson DM, Horwood LJ, Beautrais AL: Is sexual orientation
related to mental health problems and suicidality in young
people? Archives of General Psychiatry 1999, 56(10):876-880.
19. Gilman SE, Cochran SD, Mays VM, Hughes M, Ostrow D, Kessler RC:
Risk of psychiatric disorders among individuals reporting
same-sex sexual partners in the National Comorbidity Sur-
vey. American Journal of Public Health 2001, 91(6):933-939.
20. Gruskin EP, Hart S, Gordon N, Ackerson L: Patterns of cigarette
smoking and alcohol use among lesbians and bisexual
women enrolled in a large health maintenance organization.
American Journal of Public Health 2001, 91(6):976.
21. Herrell R, Goldberg J, True WR, Ramakrishnan V, Lyons M, Eisen S,
Tsuang MT: Sexual orientation and suicidality: a co-twin con-
trol study in adult men. Archives of General Psychiatry 1999,
56(10):867-874.
22. Jorm AF, Korten AE, Rodgers B, Jacomb PA, Christensen H: Sexual
orientation and mental health: results from a community
survey of young and middle-aged adults. British Journal of Psychi-
atry 2002, 180(5):423-427.
23. Mathy RM: Suicidality and sexual orientation in five conti-
nents: Asia, Australia, Europe, North America, and South
America. International Journal of Sexuality and Gender Studies 2002,
7(23):215-225.
24. Matthews AK, Hughes TL, Johnson T, Razzano LA, Cassidy R: Pre-
diction of depressive distress in a community sample of
women: The role of sexual orientation. American Journal of Public
Health 2002, 92(7):1131-1139.
25. McCabe SE, Boyd C, Hughes TL, D'Arcy H: Sexual identity and
substance use among undergraduate students. Substance
Abuse 2003, 24(2):77-91.
26. McCabe SE, Hughes TL, Boyd CJ: Substance use and misuse: are
bisexual women at greater risk? Journal of Psychoactive Drugs
2004, 36(2):217-225.
27. Nawyn SJ, Richman JA, Rospenda KM, Hughes TL: Sexual identity
and alcohol-related outcomes: contributions of workplace
harassment. Journal of Substance Abuse 2000, 11(3):289-304.
28. Remafedi G, French S, Story M, Resnick MD, Blum R: The relation-
ship between suicide risk and sexual orientation: results of a
population-based study. American Journal of Public Health 1998,
88(1):57-60.
29. Robin L, Brener ND, Donahue SF, Hack T, Hale K, Goodenow C:
Associations between health risk behaviors and opposite-,
same-, and both-sex sexual partners in representative sam-
ples of Vermont and Massachusetts high school students.
Archives of Pediatrics & Adolescent Medicine 2002, 156(4):349-355.
30. Russell ST, Joyner K: Adolescent sexual orientation and suicide
risk: evidence from a national study. American Journal of Public
Health 2001, 91(8):1276-1281.
31. Sandfort TG, de Graaf R, Bijl RV, Schnabel P: Same-sex sexual
behavior and psychiatric disorders: Findings from the Neth-
erlands mental health survey and incidence study (NEME-
SIS). Archives of General Psychiatry 2001, 58(1):85-91.
32. Sandfort TG, De Graaf R, Bijl RV: Same-sex sexuality and quality
of life: findings from the Netherlands Mental Health Survey
and Incidence Study. Archives of Sexual Behaviour 2003,
32(1):15-22.
33. Skegg K, Nada-Raja S, Dickson N, Paul C, Williams S: Sexual orien-
tation and self-harm in men and women. American Journal of Psy-
chiatry 2003, 160(3):541-546.
34. Wichstrom L, Hegna K: Sexual orientation and suicide attempt:
A longitudinal study of the general Norwegian adolescent
population. Journal of Abnormal Psychology 2003, 112(1):144-151.
35. Drabble L, Midanik LT, Trocki K: reports of alcohol consumption
and alcohol-related problems among homosexual, bisexual
and heterosexual respondents: results from the 2000
national alcohol survey. J Stud Alcohol 2005, 66(1):111-120.
36. Russell CJ, Keel PK: Homosexuality as a specific risk factor for
eating disorders in men. International Journal of Eating Disorders
2002, 31(3):300-306.
Additional File 1
Table 1: review studies.
Click here for file
[http://www.biomedcentral.com/content/supplementary/1471-
244X-8-70-S1.doc]
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 151 of 153 Pg ID 1190
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 16 of 17
(page number not for citation purposes)
37. Savin-Williams RC: Suicide attempts among sexual-minority
youths: Population and measurement issues. Journal of Consult-
ing and Clinical Psychology 2001, 69(6):983-991.
38. van Heeringen C, Vincke J: Suicidal acts and ideation in homo-
sexual and bisexual young people: A study of prevalence and
risk factors. Social Psychiatry and Psychiatric Epidemiology 2000,
35(11):494-499.
39. Garofalo R, Wolf RC, Kessel S, Palfrey SJ, DuRant RH: The associa-
tion between health risk behaviors and sexual orientation
among a school-based sample of adolescents. Pediatrics 1998,
101(5):895-902.
40. Garofalo R, Wolf RC, Wissow LS, Woods ER, Goodman E: Sexual
orientation and risk of suicide attempts among a represent-
ative sample of youth. Archives of Pediatrics and Adolescent Medicine
1999, 153(5):487-493.
41. Austin SB, Ziyadeh N, Kahn JA, Camargo CAJ, Colditz GA, Field A:
Sexual orientation, weight concerns, and eating-disordered
behaviors in adolescent girls and boys. Journal of the American
Academy of Child & Adolescent Psychiatry 2004, 43(9):1115-1123.
42. Bernhard LA, Applegate JM: Comparison of stress and stress
management strategies between lesbian and heterosexual
women. Health Care for Women International 1999, 20(4):335-347.
43. Bloomfield K: A comparison of alcohol consumption between
lesbians and heterosexual women in an urban population.
Drug and Alcohol Dependence 1993, 33(3):257-269.
44. Boyd CJ, McCabe SE, D'Arcy H: Ecstasy use among college
undergraduates: Gender, race and sexual identity. Journal of
Substance Abuse Treatment 2003, 24(3):209-215.
45. Burgard SA, Cochran SD, Mays VM: Alcohol and tobacco use pat-
terns among heterosexually and homosexually experienced
California women. Drug and Alcohol Dependence 2005,
77(1):61-70.
46. Conner M, Johnson C, Grogan S: Gender, sexuality, body image
and eating behaviours. Journal of Health Psychology 2004,
9(4):505-515.
47. Diamant AL, Wold C: Sexual orientation and variation in phys-
ical and mental health status among women. Journal of
Women's Health 2003, 12(1):41-49.
48. Duggan SJ, McCreary DR: Body image, eating disorders, and the
drive for muscularity in gay and heterosexual men: the influ-
ence of media images. Journal of Homosexuality 2004, 47(3
4):45-58.
49. Eisenberg M, Wechsler H: Substance use behaviors among col-
lege students with same-sex and opposite -sex experience:
results from a national study. Addictive Behavior 2003,
28(5):899-913.
50. Eisenberg ME, Wechsler H: Social influences on substance-use
behaviors of gay, lesbian, and bisexual college students: find-
ings from a national study. Social Science and Medicine 2003,
57(10):1913-1923.
51. Fendrich M, Wislar JS, Johnson TP, Hubbell A: A contextual profile
of club drug use among adults in Chicago. Addiction 2003,
98(12):1693-1703.
52. French SA, Story M, Remafedi G, Resnick MD, Blum RW: Sexual ori-
entation and prevalence of body dissatisfaction and eating
disordered behaviors: a population-based study of adoles-
cents. International Journal of Eating Disorders 1996, 19(2):119-126.
53. Herzog DB, Newman KL, Warshaw M: Body image dissatisfac-
tion in homosexual and heterosexual males. J Nerv Ment Dis
1991, 179(6):356-359.
54. Herzog DB, Newman KL, Yeh CJ, Warshaw M: Body image satis-
faction in homosexual and heterosexual women. International
Journal of Eating Disorders 1992, 11(4):391-396.
55. Hillier L, De Visser R, Kavanagh AM, McNair RP: The association
between licit and illicit drug use and sexuality in young Aus-
tralian women. Medical Journal of Australia 2003, 179(6):326-327.
56. Lakkis J, Ricciardelli LA, Williams RJ: Role of sexual orientation
and gender-related traits in disordered eating. Sex Roles 1999,
41(12):1-16.
57. Lock J, Steiner H: Gay, lesbian, and bisexual youth risks for
emotional, physical, and social problems: Results from a
community-based survey. Journal of the American Academy of Child
and Adolescent Psychiatry 1999, 38(3):297-304.
58. Matthews AK, Hughes TL: Mental health service use by African
American women: exploration of subpopulation differences.
Cultural Diversity and Ethnic Minority Psychology 2001, 7(1):75-87.
59. Meyer C, Blissett J, Oldfield C: Sexual orientation and eating
psychopathology: the role of masculinity and femininity.
International Journal of Eating Disorders 2001, 29(3):314-318.
60. Moore F, Keel PK: Influence of sexual orientation and age on
disordered eating attitudes and behaviors in women. Interna-
tional Journal of Eating Disorders 2003, 34(3):370-374.
61. Neumark-Sztainer D, Story M, Toporoff E, Cassuto N, Resnick MD,
Blum RW: Psychosocial predictors of binge eating and purging
behaviors among adolescents with and without Diabetes
Mellitus. Journal of Adolescent Health 1996, 19(4):289-296.
62. Neumark Sztainer D, Story M, Resnick MD, Blum RW: Lessons
learned about adolescent nutrition from the Minnesota Ado-
lescent Health Survey. Journal of the American Dietetic Association
1998, 98(12):1449-1456.
63. Oberstone AK, Sukoneck H: Psychological adjustment and life
style of single lesbians and single heterosexual women. Psy-
chology of Women Quarterly 1976, 1(2):172-188.
64. Russell ST, Driscoll AK, Truong N: Adolescent same-sex roman-
tic attractions and relationships: implications for substance
use and abuse. American Journal of Public Health 2002,
92(2):198-202.
65. Scheer S, Peterson I, Page SK, Delgado V, Gleghorn A, Ruiz J, Molitor
F, McFarland W, Klausner J, the Young Women's Survey Team: Sex-
ual and drug use behavior among women who have sex with
both women and men: results of a population-based survey.
American Journal of Public Health 2002, 92(7):1110-1112.
66. Schneider JA, O'Leary A, Jenkins SR: Gender, sexual orientation,
and disordered eating. Psychology and Health 1995,
10(2):113-128.
67. Share TL, Mintz LB: Differences between lesbians and hetero-
sexual women in disordered eating and related attitudes.
Journal of Homosexuality 2002, 42(4):89-106.
68. Siever MD: Sexual orientation and gender as factors in socio-
culturally acquired vulnerability to body dissatisfaction and
eating disorders. Journal of Consulting and Clinical Psychology 1994,
62(2):252-260.
69. Silberstein LR, Mishkind ME, Striegel-Moore RH, Timko C: Men and
their bodies: A comparison of homosexual and heterosexual
men. Psychosomatic Medicine 1989, 51(3):337-346.
70. Smith AM, Lindsay J, Rosenthal DA: Same-sex attraction, drug
injection and binge drinking among Australian adolescents.
Australian and New Zealand Journal of Public Health 1999,
23(6):643-646.
71. Stall R, Wiley J: A comparison of alcohol and drug use patterns
of homosexual and heterosexual men: the San Francisco
Men's Health Study. Drug and Alcohol Dependence 1988, 22(1
2):63-73.
72. Williamson I, Hartley P: British research into the increased vul-
nerability of young gay men to eating disturbance and body
dissatisfaction. European Eating Disorders Review 1998,
6(3):160-170.
73. Woody GE, VanEtten Lee ML, McKirnan D, Donnell D, Metzger D,
Seage G 3rd, Gross M, HIVNET VPS 001 Protocol Team: Substance
use among men who have sex with men: comparison with a
national household survey. J Acquir Immune Defic Syndr 2001,
27(1):86-90.
74. Yelland C, Tiggemann M: Muscularity and the gay ideal: Body
dissatisfaction and disordered eating in homosexual men.
Eating Behaviors 2003, 4(2):107-116.
75. Avery AM, Hellman RE, Sudderth LK: Satisfaction with mental
health services among sexual minorities with major mental
illness. American Journal of Public Health 2001, 91(6):990-991.
76. Kuang MF, Mathy RM, Carol HM, Nojima K: The Effects of Sexual
Orientation, Gender Identity, and Gender Role on the Men-
tal Health of Women in Taiwan's T-Po Lesbian Community.
Journal of Psychology and Human Sexuality 2003, 15(4):163-184.
77. Barney DD: Health risk-factors for gay American Indian and
Alaska Native adolescent males. Journal of Homosexuality 2003,
46(12):137-157.
78. Biernbaum MA, Ruscio M: Differences between matched heter-
osexual and non-heterosexual college students on defense
mechanisms and psychopathological symptoms. Journal of
Homosexuality 2004, 48(1):125-141.
79. Carlat DJ, Camargo CAJ, Herzog DB: Eating disorders in males:
a report on 135 patients. American Journal of Psychiatry 1997,
154(8):1127-1132.
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 152 of 153 Pg ID 1191
BMC Psychiatry 2008, 8:70 http://www.biomedcentral.com/1471-244X/8/70
Page 17 of 17
(page number not for citation purposes)
80. Clark TR: Homosexuality and psychopathology in nonpatient
males. American Journal of Psychoanalysis 1975, 35(2):163-168.
81. Copeland J, Hall W, Didcott P, Biggs V: A comparison of a special-
ist women's alcohol and other drug treatment service with
two traditional mixed-sex services: client characteristics and
treatment outcome. Drug and Alcohol Dependence 1993,
32(1):81-92.
82. Garcia J, Adams J, Friedman L, East P: Links between past abuse,
suicide ideation, and sexual orientation among San Diego
college students. Journal of American College Health 2002,
51(1):9-14.
83. Hellman RE, Sudderth L, Avery AM: Major Mental Illness in a Sex-
ual Minority Psychiatric Sample. Journal of the Gay and Lesbian
Medical Association 2002, 6(34):97-106.
84. Hirsch JK, Ellis JB: Reasons for living in homosexual and heter-
osexual young adults. Archives of Suicide Research 1998,
4(3):243-248.
85. Holleran PR, Novak AH: Support choices and abstinence in gay/
lesbian and heterosexual alcoholics. Alcoholism Treatment Quar-
terly 1989, 6(2):71-83.
86. Hopkins JH: The lesbian personality. British Journal of Psychiatry
1969, 115(529):1433-1436.
87. Hughes TL: Lesbians' Drinking Patterns: Beyond the Data.
Substance Use and Misuse 2003, 38(1113):1739-1758.
88. Kruks G: Gay and lesbian homeless/street youth: Special
issues and concerns. Journal of Adolescent Health 1991,
12(7):515-518.
89. Leslie MB, Stein JA, Rotheram-Borus MJ: Sex-specific predictors of
suicidality among runaway youth. J Clin Child Adolesc Psychol
2002, 31(1):27-40.
90. Lewis CE, Saghir MT, Robins E: Drinking patterns in homosexual
and heterosexual women. Journal of Clinical Psychiatry 1982,
43(7):277-279.
91. Mangweth B, Pope HGJ, Hudson JI, Olivardia R, Kinzl J, Biebl W: Eat-
ing disorders in Austrian men: An intracultural and crosscul-
tural comparison study. Psychother Psychosom 1997,
66(4):214-221.
92. Martin RL, Cloninger CR, Guze SB, Clayton PJ: Mortality in a fol-
low-up of 500 psychiatric outpatients. I. Total mortality.
Archives of General Psychiatry 1985, 42(1):47-54.
93. Mathy RM, Lehmann BA: Public health consequences of the
defense of marriage act for lesbian and bisexual women: Sui-
cidality, behavioral difficulties, and psychiatric treatment.
Feminism and Psychology 2004, 14(1):187-194.
94. Noell JW, Ochs LM: Relationship of sexual orientation to sub-
stance use, suicidal ideation, suicide attempts, and other fac-
tors in a population of homeless adolescents. Journal of
Adolescent Health 2001, 29(1):31-36.
95. Nurius PS: Mental health implications of sexual orientation.
Journal of Sex Research 1983, 19(2):119-136.
96. Paris J, Zweig FH, Guzder J: Psychological factors associated
with homosexuality in males with borderline personality dis-
order. Journal of Personality Disorders 1995, 9(1):56-61.
97. Pillard RC: Sexual orientation and mental disorder. Psychiatric
Annals 1988, 18(1):52-56.
98. Rutter PA, Soucar E: Youth suicide risk and sexual orientation.
Adolescence 2002, 37(146):289-299.
99. Safren SA, Heimberg RG: Depression, hopelessness, suicidality,
and related factors in sexual minority and heterosexual ado-
lescents. Journal of Consulting and Clinical Psychology 1999,
67(6):859-866.
100. Saghir MT, Robins E, Walbran B, Gentry KA: Homosexuality. III.
Psychiatric disorders and disability in the male homosexual.
American Journal of Psychiatry 1970, 126(8):1079-1086.
101. Saghir MT, Robins E, Walbran B, Gentry KA: Homosexuality. IV.
Psychiatric disorders and disability in the female homosex-
ual. American Journal of Psychiatry 1970, 127(2):147-154.
102. Saulnier CF, Miller BA: Drug and alcohol problems: heterosex-
ual compared to lesbian and bisexual women. Canadian Journal
of Human Sexuality 1997, 6(3):221-231.
103. Schmitt JP, Kurdek LA: Correlates of social anxiety in college
students and homosexuals. Journal of Personality Assessment 1984,
48(4):403-409.
104. Siegelman M: Adjustment of male homosexuals and hetero-
sexuals. Archives of Sexual Behavior 1972, 2(1):9-25.
105. Singh D, Vidaurri M, Zambarano RJ, Dabbs JMJ: Lesbian erotic role
identification: Behavioral, morphological, and hormonal cor-
relates. Journal of Personality and Social Psychology 1999,
76(6):1035-1049.
106. Striegel-Moore RH, Tucker N, Hsu J: Body image dissatisfaction
and disordered eating in lesbian college students. International
Journal of Eating Disorders 1990, 9(5):493-500.
107. Strong SM, Williamson DA, Netemeyer RG, Geer JH: Eating disor-
der symptoms and concerns about body differ as a function
of gender and sexual orientation. Journal of Social and Clinical Psy-
chology 2000, 19(2):240-255.
108. Tori CD: Homosexuality and illegal residency status in rela-
tion to substance abuse and personality traits among Mexi-
can nationals. Journal of Clinical Psychology 1989, 45(5):814-821.
109. Tuel BD, Russell RK: Self-esteem and depression in battered
women: A comparison of lesbian and heterosexual survivors.
Violence Against Women 1998, 4(3):344-362.
110. Westefeld JS, Maples MR, Buford B, Taylor S: Gay, lesbian, and
bisexual college students: The relationship between sexual
orientation and depression, loneliness, and suicide. Journal of
College Student Psychotherapy 2001, 15(3):71-82.
111. Whitbeck LB, Chen X, Hoyt DR, Tyler KA, Kurt D: Mental Disor-
der, Subsistence Strategies, and Victimization Among Gay,
Lesbian, and Bisexual Homeless and Runaway Adolescents.
Journal of Sex Research 2004, 41(4):329-342.
112. Yoder KA, Hoyt DR, Whitbeck LB: Suicidal behavior among
homeless and runaway adolescents. Journal of Youth and Adoles-
cence 1998, 27(6):753-771.
113. Zubenko GS, George AW, Soloff PH, Schulz P: Sexual practices
among patients with borderline personality disorder. Ameri-
can Journal of Psychiatry 1987, 144(6):748-752.
114. Balsam KF, Huang B, Fieland KC, Simoni JM, Walters KL: Culture,
trauma, and wellness: a comparison of heterosexual and les-
bian, gay, bisexual, and two-spirit native Americans. Cultural
Diversity Ethnic Minority Psychology 2004, 10(3):287-301.
115. DuRant RH, Krowchuk DP, Sinal SH: Victimization, use of vio-
lence, and drug use at school among male adolescents who
engage in same-sex sexual behavior. Journal of Pediatrics 1998,
133(1):113-118.
116. Mathy RM: Transgender Identity and Suicidality in a Nonclin-
ical Sample: Sexual Orientation, Psychiatric History, and
Compulsive Behaviors. Journal of Psychology and Human Sexuality
2002, 14(4):47-65.
117. Ndimbie OK, Perper JA, Kingsley L, Harty L, Winkelstein A: Sudden
unexpected death in a male homosexual cohort. The American
Journal of Forensic Medicine and Pathology 1994, 15(3):247-250.
118. Rich CL, Fowler RC, Young D, Blenkush M: San Diego suicide
study: Comparison of gay to straight males. Suicide and Life
Threatening Behavior 1986, 16(4):448-457.
119. Shaffer D, Fisher P, Parides M, Gould M: Sexual orientation in ado-
lescents who commit suicide. Suicide and Life Threatening Behavior
1995, 25(Suppl):64-71.
120. Bailey JM: Homosexuality and mental illness. Archives of General
Psychiatry 1999, 56(10):883-884.
121. McWhirter DP, Sanders SA, Reinisch JM: Homosexuality/Heterosexual-
ity New York: Oxford University Press; 1990.
Pre-publication history
The pre-publication history for this paper can be accessed
here:
http://www.biomedcentral.com/1471-244X/8/70/pre
pub
2:12-cv-10285-BAF-MJH Doc # 65-3 Filed 08/12/13 Pg 153 of 153 Pg ID 1192
ATTACHMENT M

2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 1 of 99 Pg ID 1193
Google Custom Search GO
Issues & Research Human Services State Laws Limiting Marriage to Opposite-Sex Couples Go 24379
State Laws Limiting Marriage to Opposite-Sex Couples
Updated June 26, 2013
Following the U.S. Supreme Court decision on June 26, 2013, reinstating the federal distrcit court decision that overturned Proposition 8 in
California, 35 states have defined marriage as between a man and a woman in state law. Most states do so by adopting defense of marriage
language that defines marriage in a way similar to the language in the federal Defense of Marriage Act (DOMA) the word 'marriage' means
only a legal union between one man and one woman as husband and wife. Other states prohibit same sex marriages or marriages between
persons of the same sex or gender.
Twenty-nine states have placed that language in their state constitutions, usually adopted by the states legislature and by a popular vote. (26 of these states also
have statutory provisions adopting this language). Six states have only statutory language that defines marriage as a relationship between a man and a woman.
State Laws Defining Marriage as a Relationship between a Man and a Woman
For more information on defense of marriage acts (DOMA) and same-sex marriage issues, please contact Jack Tweedie in the Denver office at 303.856.1546 or cyf-
info@ncsl.org. For federal marriage issues, contact Sheri Steisel in the D.C. office at 202.624.5400 or fedhumserv-info@ncsl.org.
Denver Office
Tel: 303-364-7700 | Fax: 303-364-7800 | 7700 East First Place |
Denver, CO 80230
Washington Office
Tel: 202-624-5400 | Fax: 202-737-1069 | 444 North Capitol Street, N.W., Suite 515 |
Washington, D.C. 20001
2013 National Conference of State Legislatures. All Rights Reserved.
Page 1 of 1 State Laws Limiting Marriage to Opposite-Sex Couples
8/10/2013 http://www.ncsl.org/issues-research/human-services/state-doma-laws.aspx
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 2 of 99 Pg ID 1194
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 7, 2013
ATTACHMENT N

2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 3 of 99 Pg ID 1195
On This Page
Overview
Marriage on the 2012 Ballot
Statewide Votes on Marriage,
1998Present
NCSL Resources
Same Sex Marriage, Civil Unions
and Domestic Partnerships
Elections and Campaigns
NCSL Contact
Jennie Drage Bowser, NCSL's
Denver office, 303-364-7700.
Google Custom Search GO
Legislatures & Elections Elections & Campaigns Same-Sex Marriage on the Ballot Go 20939
Same-Sex Marriage and Domestic Partnerships on the Ballot
Updated Nov. 7, 2012, 5:10am MST
Overview
It was a big night for same-sex marriage, with voters in four states voting in favor of the
issue.
The majority of previous statewide votes on the issue of marriage has sought to define
marriage as between one man and one woman, effectively prohibiting same-sex marriage.
Between 1998 and 2012, there were 31 votes in 30 states on this issue, and in all but one
case, voters agreed to limit marriage to opposite-sex couples. The single exception was in Arizona, where in 2006 voters rejected
a same-sex marriage ban. However, Arizona voters went on to approve a ban in the 2008 election. In November 2012,
Minnesota was the 31st state to consider a constitutional provision limiting marriage to opposite-sex couples, and they rejected
their proposed ban.
Marriage issues have appeared on the ballot in slightly different forms as well. In 1998, Hawaii voted to give the Legislature the
right to define marriage, and after the passage of the ballot question, the Legislature moved to define marriage as between a
man and a woman in state law. In Maine, voters were asked in 2009 whether they wanted to uphold or reject a law passed by
the Legislature that legalized same-sex marriage; voters rejected that law (they will consider a new proposal to legalize same-
sex marriage in November 2012). And in also 2009, Washington voters were asked to weigh in on a law passed by the Legislature to legalize domestic partnerships.
Washington is the only state where voters have agreed to extend these rights to same-sex couples; until 2012, no state had approved the legalization of same-sex
marriage.
Same-Sex Marriage on the 2012 Ballot
Marriage, a perennial issue on statewide ballots over the past decade, was back before voters again in 2012. It was on the ballot in four states in November 2012,
with several new spins on this old theme this year. Marriage appeared on the primary ballot in North Carolina, where voters approved a constitutional definition of
marriage as between one man and one woman in May 2012. The states that voted on marriage in 2012 were:
Maine: Voters approved an initiative legalizing same-sex marriage. This was the first time a state's voters had been directly asked to legalize same-sex marriage,
rather than prohibit it.
Maryland: Voters approved a new law legalizing same-sex marriage. The legislature had passed this law, but opponents qualified a popular referendum in an
attempt to block its implementation.
Minnesota: Voters rejected a legislatively-referred same-sex marriage ban. This question was similar to those that have appeared on the ballot in 30 other
states since 1998.
North Carolina: Voters approved a same-sex marriage ban in May 2012. The "yes" vote was 61.1%, the lowest affirmative vote ever received by a same-sex
marriage ban in a southern state.
Washington: Like Maryland, Washington had a popular referendum on the ballot that sought to overturn a new law legalizing same-sex marriage. Voters
rejected this move and approved the legislature's bill legalizing same-sex marriage. Vote returns won't be complete in Washington until at least a week after the
election, but the "yes" vote stands at a solid 52% on Wednesday morning.
Petitions dealing with marriage were circulated in at least five other states--California, Colorado, Florida, Nebraska, and Ohio--but failed to gather sufficient
signatures to reach the November 2012 ballot. In a break from the established historical pattern on this issue, all of these petitions sought to either legalize same-sex
marriage or repeal an existing ban on it.
A New Spin on an Old Idea
Just one of this November's crop of marriage issues -- Minnesota's -- followed the pattern established over the past decade of asking voters to insert into the state
constitution a definition of marriage as being between one man and one woman. The other three issues diffeedr considerably.
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
KS
KY
LA
ME
MD
MA
MI
MN
MS
MO
MT
NE NV NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
RI
SC
SD
TN
TX
UT
VT
VA
WA
WV
WI
WY
AS GU MP PR VI
Initiative Map
Legend
States with Initiatives
After Election Day
Failed
Passed
Split
Page 1 of 3 Same-Sex Marriage on the Ballot
8/10/2013 http://www.ncsl.org/legislatures-elections/elections/same-sex-marriage-on-the-ballot.aspx
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 4 of 99 Pg ID 1196
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 7, 2013
In Maryland and Washington, legislatures recently passed laws legalizing same-sex marriage. The questions on the ballot in these two states sought to block
these new laws. They used a device called the popular referendum, available in 23 states, which permits opponents of a new law to veto it through a popular
vote. In both states, the "yes" vote on November 6 had the effect of approving the legislatures' move to legalize same-sex marriage. If voters had voted "no,"
the new laws passed by the legislature would have been effectively vetoed and would not have taken effect.
In Maine, voters faced a question asking them to legalize same-sex marriage in their state, and they said "yes." No state's voters had been asked this question
in quite this way before. It was only three years ago, in November 2009, that Maine voters overturned a law passed by the legislature legalizing same-sex
marriage. The Maine situation in 2009 was identical to what happened in Maryland and Washington this year, although the outcome was different this time in
those two states.
Attitudes Toward Same-Sex Marriage
There was another major change in the issue of same-sex marriage leading into this year's election, and that was voter opinion. Both national and state-specific polls
on same-sex marriage indicated that voter opinion has shifted significantly over the past decade, and NCSL data on voter behavior supported that conclusion. In
other words, the handwriting was on the wall well before November 6, and voters proved pollsters correct on Election Day.
The Pew Forum on Religion and Public Life has polled Americans regularly concerning their attitude toward same-sex marriage since 2001. Back in 2001, Americans
were opposed to same-sex marriage by a margin of 57 percent to 35 percent. Fast-forward to 2012, and those numbers had shifted dramatically: 48 percent
said they favor same-sex marriage, while 44 percent opposed it.
State-specific polls in three of the four states with marriage on the 2012 ballot indicated that a majority of voters in those states supported same-sex marriage in
advance of Election Day:
Maine: A poll conducted in mid-September found that 57 percent support the legalization of same-sex marriage, while 36 percent oppose it.
Maryland: A late-September poll by the Baltimore Sun found support for same-sex marriage at 49 percent, with 39 percent opposed.
Minnesota: A Star-Tribune poll conducted in mid-September found that 49 percent of voters planned to vote "yes" on the same-sex marriage prohibition,
while 47 percent opposed it, results which fall within the poll's 3.5% margine of error.
Washington: A mid-September poll by Survey USA found that 56 percent of voters favor supporting the legislature's law legalizing same-sex marriage, while
38 percent opposite.
Two of these four polls indicated that voters were likely to approve same-sex marriage on November 6. Minnesota's poll was in a statistical tie, while the ten percent
of voters who remained undecided in Maryland decided the fate of same-sex marriage in that state. If any of these four states had approved same-sex marriage on
Election Day, that would have been a first in our nation's history. The fact that all four did is a strong signal that attidudes have changed.
NCSL data also supported the idea that voter attitudes toward same-sex marriage were changing going into Election Day 2012: the strength of the "yes" vote for
banning same-sex marriage peaked in 2005, with a multi-state average of 73.1 percent of voters saying "yes" to a same-sex marriage ban. The "yes" vote has
consistently lost strength since 2005, falling to 63.9 percent in 2006, 56.8 percent in 2008, and 52.9 percent in 2009. Read the full analysis of voter behavior on
same-sex marriage on the Prop 50 Blog.
In short, leading into Election Day, all signs pointed toward a major change in voter attitudes toward same-sex marriage, and those signs played out in four states
approving the issue.
Statewide Votes on Same-Sex Marriage, 1998 - Present
State Year Measure # Topic Area Type
a
CA/S
b
Pass/Fail
Alabama 2006 Amendment 1 Definition of marriage L CA Pass
Alaska 1998 Measure 2 Definition of marriage L CA Pass
Arizona 2006 Prop. 107 Definition of marriage I CA Fail
Arizona 2008 Prop. 102 Definition of marriage L CA Pass
Arkansas 2004 Amendment 3 Definition of marriage I CA Pass
California 2000 Prop. 22 Definition of marriage I S Pass
California 2008 Proposition 8 Definition of marriage I CA Pass
Colorado 2006 Amend. 43 Definition of marriage I CA Pass
Florida 2008 Amendment 2 Definition of marriage I CA Pass
Georgia 2004 Amendment 1 Definition of marriage L CA Pass
Hawaii 1998 Question 2 Give legislature right to define marriage L CA Pass
Idaho 2006 HJR 2 Definition of marriage L CA Pass
Kansas 2005 Amendment Definition of marriage L CA Pass
Kentucky 2004 Amendment Definition of marriage L CA Pass
Louisiana 2004 Amendment 1 Definition of marriage L CA Pass
Page 2 of 3 Same-Sex Marriage on the Ballot
8/10/2013 http://www.ncsl.org/legislatures-elections/elections/same-sex-marriage-on-the-ballot.aspx
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 5 of 99 Pg ID 1197
State Year Measure # Topic Area Type
a
CA/S
b
Pass/Fail
Maine 2009 Question 1 Reject the legalization of same-sex
marriage
PR S Pass
Maine 2012 Question 1 Legalize same-sex marriage I S Pass
Maryland 2012 Question 6 Legalize same-sex marriage PR S Pass
Michigan 2004 Proposal 2 Definition of marriage I CA Pass
Minnesota 2012 Amendment 1 Definition of marriage L CA Fail
Mississippi 2004 Amendment 1 Definition of marriage L CA Pass
Missouri 2004 Amendment 2 Definition of marriage L CA Pass
Montana 2004 CI-96 Definition of marriage I CA Pass
Nebraska 2000 Initiative 416 Definition of marriage I CA Pass
Nevada 2002 Question 2 Definition of marriage I CA Pass
North Carolina 2012 Amendment 1 Definition of marriage L CA Pass
North Dakota 2004 ICM 1 Definition of marriage I CA Pass
Ohio 2004 Issue 1 Definition of marriage I CA Pass
Oklahoma 2004 Question 711 Definition of marriage L CA Pass
Oregon 2004 Measure 36 Definition of marriage I CA Pass
S. Carolina 2006 Amendment 1 Definition of marriage L CA Pass
South Dakota 2006 Amend. C Definition of marriage L CA Pass
Tennessee 2006 Amendment 1 Definition of marriage L CA Pass
Texas 2005 Proposition 2 Definition of marriage L CA Pass
Utah 2004 Amendment 3 Definition of marriage L CA Pass
Virginia 2006 Amendment 1 Definition of marriage L CA Pass
Washington 2009 Referendum Measure
71
Uphold a law passed by the Legislature,
giving rights and responsibilities to same-
sex couples
PR S Pass
Washington 2012 Referendum Measure
74
Legalize same-sex marriage PR S Pass
(Ballots will continue
to trickle in for a
week)
Wisconsin 2006 Question 1 Definition of marriage L CA Pass
a) Type: L = legislative referendum
I = citizen-initiated
PR = popular referendum (a petition-driven effort to overturn a law passed by the legislature)
b) CA = constitutional amendment
S = statutory
Denver Office
Tel: 303-364-7700 | Fax: 303-364-7800 | 7700 East First Place |
Denver, CO 80230
Washington Office
Tel: 202-624-5400 | Fax: 202-737-1069 | 444 North Capitol Street, N.W., Suite 515 |
Washington, D.C. 20001
2013 National Conference of State Legislatures. All Rights Reserved.
Page 3 of 3 Same-Sex Marriage on the Ballot
8/10/2013 http://www.ncsl.org/legislatures-elections/elections/same-sex-marriage-on-the-ballot.aspx
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 6 of 99 Pg ID 1198
ATTACHMENT O

2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 7 of 99 Pg ID 1199
Paul Weyrich
December 3, 2004
The Arlington Group
By Paul Weyrich
In the middle 1990s Mike Valerio, who had been mentoring conservative leaders
for a couple of decades, made the case that we needed to bring leaders of the
religious right together so they could work together and become a more powerful
force. What he said made sense so I agreed to undertake the project. I sent out an
invitation to all of the major leaders of what often is termed the "Religious Right" to attend an
organizing session at the Free Congress Foundation. To my pleasant surprise nearly all of them
came. We had what I thought was an excellent organizing meeting. In fact it went so well that it
seemed to me it had upon it the hand of Divine Providence.
It is a fact of contemporary Washington that if more than three people meet to discuss anything one
of them ends up speaking to the media. Sure enough, soon after this first meeting I received a call
from The New York Times, which had been fairly accurately informed about the discussions in the
meeting. The article that resulted from the interview with me and others was almost positive but it
prompted some in the group to begin to question whether or not I was the correct person to lead the
group. (In point of fact, I offered to step aside after completing the initial organizational activities but
the group insisted that I continue as Chairman). Word was I was out to dictate to other groups how
they should use their resources. Nothing could have been further from the truth, but in politics
perception is greater than reality. So after some additional attempts to keep the group together, which
were unsuccessful, I withdrew.
Fast forward to a couple of years ago: I received an e-mail from the Rev. Don Wildmon, of the
American Family Association (AFA). After having built a force of folks dedicated to saving the family,
Wildmon went on to acquire radio stations, especially in the South and Southwest. On these stations
he beamed Christian programming, including a program on public affairs originating at AFA
headquarters in Tupelo, MS. Wildmon's e-mail suggested that we were facing daunting social
problems. He correctly said if we all went our separate ways we would not amount to much. However,
if we could all sing off the same sheet of music, we could be a significant force. He suggested a
meeting and one of the participants provided meeting facilities in the condo complex where she lived,
which is across the Potomac River from Washington, D.C.
Neither Wildmon nor any of the rest of us had any idea if this effort to get the principals of the
Religious Right together for the purpose of working together would succeed. Some groups are rivals
of each other. Others never had worked together with anyone. Plus, on the right there is a streak of
individualism which causes leaders of groups not to want to cooperate with other leaders.
Whatever the drawbacks, mainly because of the non-threatening leadership of Rev. Wildmon, the first
meeting was a success.
Page 1 of 3 The Arlington Group
8/7/2013 http://www.renewamerica.com/columns/weyrich/041203
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 8 of 99 Pg ID 1200
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 7, 2013
The meeting has grown from there. Of course the effort, known now as the Arlington Group, even
though we now meet in Washington, D.C., has had its ups and downs. It has been mainly up,
however. People of all denominations and backgrounds are now participating. A major development
occurred when the Rev. Bill Owens joined the Executive Committee. Rev. Owens is a Black pastor
who is dedicated to eliminating the differences between Blacks and Whites as they approach public
policy. His most frequently repeated line is, "These are not Black or White issues. These are
Christian issues." He has brought many powerful Black pastors with him. The latest to join the
Arlington Group is Bishop Keith Butler, who presides over Protestant churches all over the U.S.A. and
even abroad. His own parish in Detroit, MI has some 16,000 members.
The level of trust and cooperation among members of the group has been increasing. Early on the
group agreed to work on the marriage issue. Indeed the effort to put marriage on the ballot in eleven
States emanated from the Arlington Group. And the resources to go full-tilt in Ohio were raised from
participants in the group. Heavyweights such as Gary Bauer of the American Values Committee,
Richard Land of the Southern Baptists and Dr. James Dobson are regular participants. Indeed, the
group asked Dr. Dobson to be its National Chairman.
The Arlington Group has adopted the coalition style of operations which was pioneered by the Free
Congress Foundation more than thirty years ago. There is no formal structure. The meeting is by
invitation only. Participants must represent something larger than themselves. The Chairman, with
the assistance of the fulltime staff, sets the agenda. But any member can have a matter considered
by the group. The meetings are not secret but they are off the record. (You can't get 70 people
together and keep it a secret, however, you can ask people to keep to themselves what is said within
the room.)
It works. Shannon Royce, who for many years worked for the Southern Baptists in Washington, is the
very capable Executive Director. The meetings are dynamic. They are filled with up-to-date
information. While the debates on tactical or even strategic questions are often very lively, when a
consensus is reached we move forward. There are no votes other than to see which way the group is
leaning on a tactic. It works because no group seeks to force any other group to spend its resources.
Rather each group uses its resources toward the common objective as it sees fit. There is neither
power play nor effort to undercut the majority by those whose views may not have been adopted.
Participants look forward to, rather then dread, the meetings.
The group has been very encouraged by the eleven victories on the marriage issue from one end of
the country to the other. For now the group intends to keep its focus on the marriage issue. Part of
the effort of the group is educational, part is lobbying. Some groups have PACs. For those legislators
who remain uneducable or un-persuadable there is always the ballot box. Partisan elections (as
opposed to issue elections) are not an effort of the Arlington Group but there are those participants
who have candidate election capabilities and no doubt will use them in due course.
I have the privilege of serving on the Executive Committee of the Arlington Group. I have never
worked with a finer group of people. Each one approaches this effort with a prayerful disposition and
an open mind.
Would that every policy effort in which I engage could have people with the same attitude. Clearly the
participants of the Arlington Group approach life with an attitude of: "How can we contribute to the
common good?"
Only God knows what we will be able to accomplish or how long we will be together. For now, the
Arlington Group is the one bright spot in the body politick. It is a group of men and women, the
leaders of the values voters, who seek to stem the tide of the cultural decline of this once great
Page 2 of 3 The Arlington Group
8/7/2013 http://www.renewamerica.com/columns/weyrich/041203
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 9 of 99 Pg ID 1201
nation. They are reasonable yet they don't believe in compromise when compromise is not absolutely
required. They are tough yet they are all-giving toward the poor and less fortunate. They think in
cosmic terms yet they are not utopian. It is so wonderful to be associated with them. As we say in the
tradition of the Eastern Church: "May God grant them many years!"
Paul Weyrich
The views expressed by RenewAmerica columnists are their own and do not
necessarily reflect the position of RenewAmerica or its affiliates.
(See RenewAmerica's publishing standards.)
Page 3 of 3 The Arlington Group
8/7/2013 http://www.renewamerica.com/columns/weyrich/041203
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 10 of 99 Pg ID 1202
ATTACHMENT P

2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 11 of 99 Pg ID 1203
ARLINGTON GROUP MEMBERS
Dr. James Dobson
Focus on the Family
Paul M. Weyrich
Free Congress Foundation
Rich Bott
Bott Radio Network
Rod Parsley
Center for Moral Clarity
Janet Folger
Faith2Action
Donald E. Wildman
American Family Association
Stuart Epperson
Salem Communications
Corporation
Tony Perkins
Family Research Council
Gary Bauer
American Values
Kenneth Hutchenson
Mayday for Marriage
Bishop Harry R. Jackson,
Chairman
High Impact Leadership
Coalition
Alan Chambers, President
Exodus International
Dick Bott, Sr.
Bott Radio Network
Carl D. Herbster
Advance USA
Dr. Bill Maier
Focus on the Family
Keith Wiebe
American Assoc. of Christian
School
Leo Godzich
Natl Assoc. of Marriage
Enhancement
Ron Crews
MA Coalition for Marriage
Samuel Casey
Christian Legal Society
Colin A. Hanna
Let Freedom Ring, Inc.
Byron Voorheis, III,
Michigan Chairman, Social
Conservatives Bush-Cheney
O4
Gary Glenn
American Family Association
of Michigan
Randy Thomas
Exodus International
Kelly Shackleford
Free Market Foundation
Phil Burress
Citizens for Community
Values
Rev. William Owens,
President
Coalition of African-
American Pastors
Dr. S. Dale Burroughs
Biblical Heritage Institute
Clint Cline
Design 4
Stephen M. Crampton,
Chief Counsel
American Family Association
Center for Law and Policy
Warren Kelley, President
National Center for Freedom
& Renewal
Rev. Derek A. McCoy, Vice
President
High Impact Leadership
Coaliton
Dan Panetti
National Coalition for the
Protection of Children and
Families
Kristian M. Mineau,
President
Massachusetts Family
Institute
John Stemberger, Chairman
Florida Family Policy
Council, Inc.
Al Laws, Jr.
WIN Family Services, Inc.
Diane Gramley
American Family Assoc. of
Pennsylvania
Matthew D. Staver,
President
Liberty Counsel
Mark Benz
Men for Nations
Robert E. Reccord,
President
North American Mission
Board
Page 1 of 2 Jim Dobson Focus on the Family
8/7/2013 http://www.aproundtable.org/untangling/arlington_Group.html
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 12 of 99 Pg ID 1204
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 7, 2013
Rick Scarborough
Vision America
Larry Cirignano
Catholicvote.org
C. Preston Noell
Tradition, Family, Property
Rev. Ted Haggard,
President
National Assoc. of
Evangelicals
Alan E. Sears
Alliance Defense Fund
(for identification purposes
only)
Richard D. Land
Ethics & Religious Liberty
Commission
Frank Wright, Ph.D.,
President
National Religious
Broadcasters
J. Kenneth Blackwell
American Center for Civic
Character
Page 2 of 2 Jim Dobson Focus on the Family
8/7/2013 http://www.aproundtable.org/untangling/arlington_Group.html
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 13 of 99 Pg ID 1205
ATTACHMENT Q

2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 14 of 99 Pg ID 1206
833 NORTH LAST CHANCE GULCH, SECOND FLOOR HELENA, MT 59601
PHONE 406-449-2480 FAX 406-457-2091 E-MAIL institute@statemoney.org
www.followthemoney.org
T H E M O N E Y B E H I N D
T H E 2 0 0 4 M A R R I A G E A M E N D M E N T S
By
S U E O C O N N E L L
J A N . 2 7 , 2 0 0 6
This publication was made possible by grants from:
The JEHT Foundation, Democratizing the Electoral Process
Carnegie Corporation of New York, Strengthening U.S. Democracy Program
Ford Foundation, Program on Governance and Civil Society
Joyce Foundation, Program on Money and Politics
Rockefeller Brothers Fund, Program on Democratic Practice
The statements made and the views expressed are solely the responsibility of the Institute.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 15 of 99 Pg ID 1207
DeBoer v. Snyder, No. 2:12-cv-10285-BAF-MJH, visited August 7, 2013
The Institute on Money in State Politics 2006 2
T A B L E O F C O N T E N T S
Overview ................................................................................................. 3
Methodology ................................................................................ 5
A Rush to Amend..................................................................................... 6
A Network Forms..................................................................................... 8
About the Arlington Group........................................................... 9
The Forces Against ................................................................................ 13
Top Contributors Across the 13 States.................................................... 16
Where the Money Went ......................................................................... 19
Looking down the Road ......................................................................... 21
In Search of New Strategies........................................................ 21
The Arlington Groups Continuing Interests ............................... 22
State-By State Summaries
Arkansas..................................................................................... 28
Georgia....................................................................................... 30
Kentucky.................................................................................... 31
Louisiana.................................................................................... 33
Michigan .................................................................................... 35
Mississippi ................................................................................. 39
Missouri ..................................................................................... 40
Montana ..................................................................................... 42
North Dakota.............................................................................. 43
Ohio ........................................................................................... 44
Oklahoma................................................................................... 47
Oregon ....................................................................................... 49
Utah............................................................................................ 53
Appendix A: Arlington Group Members, February 2005........................ 55
About the Institute.................................................................................. 56
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 16 of 99 Pg ID 1208
The Institute on Money in State Politics 2006 3
O V E R V I E W
The spate of 2004 ballot measures that banned same-sex marriages in fully one-fourth of the states
generated more than $13 million in campaign contributions. Slightly more than half of the money
came from just three groups of contributors: organizations and individuals supporting gay and
lesbian rights; conservative Christian organizations, such as Focus on the Family and the Family
Research Council; and organized religion.
Together, contributors in those groups poured nearly $7.2 million into the marriage debate in 13
different states: Arkansas, Georgia, Kentucky, Louisiana, Michigan, Mississippi, Missouri,
Montana, North Dakota, Ohio, Oklahoma, Oregon and Utah. Four of the states with amendments
on the ballot were considered to be among the 20 or so battleground states in the presidential
contest Arkansas, Michigan, Ohio and Oregon.
1
Supporters of the measures raised slightly more than opponents $6.8 million compared with
$6.6 million. However, the election results were entirely one-sided. The constitutional
amendments passed in every state, some by margins of 3:1.
An analysis of the campaign-finance reports filed by the ballot measure committees shows:
Groups and individuals supporting gay and lesbian rights gave the
largest chunk of cash: slightly more than $3 million. The national
Human Rights Campaign gave about one-third of this total, or nearly
$1.1 million, as it contributed to ballot committees in five states. The
National Gay and Lesbian Task Force gave another $789,360, in six
states. The remainder came primarily from state-based groups or others
supporting gay and lesbian rights.
Contributors affiliated with conservative Christian organizations gave
$2.2 million. Nearly $2 million of this amount, or 89 percent, came
from members of the so-called Arlington Group, a coalition with
close ties to the Bush White House and made up of conservative groups
that have, in some instances, taken credit for the broad sweep of same-
sex marriage measures in 2004. Member organizations of the Arlington
Group or organizations with ties to them were active on numerous
fronts, by:
o forming campaign committees to support the measures in 11
of the 13 states.
o giving money to ballot committees supporting the measures in
11 of the 13 states.
o undertaking advertising campaigns targeting congressional
candidates on the marriage issue in at least six of the states

1
Same Sex Marriage Measures on the 2004 Ballot, National Conference of State Legislatures, Nov. 17, 2004
[on-line]; available from http://www.ncsl.org/programs/legman/statevote/marriage-mea.htm; Internet; accessed
Nov. 21, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 17 of 99 Pg ID 1209
The Institute on Money in State Politics 2006 4
with ballot measures on the issue: Arkansas, Louisiana, North
Dakota, Michigan, Ohio and Oklahoma.
2
Churches including ministers and other employees, as well as
fellowship groups and church-related businesses gave $1.9 million
in nine states.
o Fully $1 million of this amount came from seven Roman
Catholic dioceses in Michigan. Their contributions to a
committee supporting the same-sex marriage ban represented
36 percent of the total contributions raised by the marriage
amendment committees in Michigan.
o Church-related contributors gave 39 percent of the total raised
in Arkansas, but much lower percentages in the other states in
which they gave.
o Slightly less than $12,000 of the nearly $2 million in church-
related contributions went to committees opposed to the
marriage amendments amounting to less than 1 percent of
the giving by churches.
While gay- and lesbian-rights contributors topped the list as a single group, contributions to pro-
amendment committees from churches and conservative Christian groups together totaled more
$4.1 million, or about 35 percent more than the amount given by gay- and lesbian-rights
supporters.
The most costly battleground proved to be Oregon, where Measure 36 drew nearly $5.4 million in
contributions. Opponents of the ban raised just under $3 million, or 55 percent of the total, while
supporters raised $2.4 million.
The vote in Oregon was the closest among all states, with 57 percent of Oregon voters approving
passage and 43 percent opposing the initiative.
Elsewhere, voters passed the constitutional amendments with much more decisive margins of
victory following campaigns marked by heavy rhetoric, calls from the pulpit to rally support, and
a suggestion that the measures were part of a politically motivated effort to turn out conservative
values voters in support of President Bush.
Some of the amendments drew heavy financial support, while ballot battles in other states were
relatively inexpensive, as the table on the following page shows.

2
Focus on the Family Action Takes on Swing-State Senators Over FMA, Focus on the Family Action [on-line];
available from http://www.focusaction.org/actvities/a0000010.cfm; Internet; accessed Dec. 8, 2005, and David
D. Kirkpatrick, The 2004 Campaign: Gays; Marriage Between Gays Becomes Issue in Campaigns, The New
York Times, Oct. 30, 2004, sec. A, p. 16.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 18 of 99 Pg ID 1210
The Institute on Money in State Politics 2006 5
C O N T R I B U T I O N S T O S A M E - S E X M A R R I A G E A M E N D M E N T S B Y S T A T E , 2 0 0 4
C O N T R I B U T I O N S V O T E S
S T A T E F O R A G A I N S T T O T A L % F O R * % A G A I N S T *
Oregon $2,434,454 $2,933,998 $5,368,452 57% 43%
Michigan $1,930,429 $854,212 $2,784,641 59% 41%
Ohio $1,202,761 $942,421 $2,145,182 62% 38%
Utah $506,922 $780,740 $1,287,662 66% 34%
Kentucky $201,132 $522,864 $723,996 75% 25%
Missouri $29,612 $488,189 $517,801 71% 29%
Arkansas $334,731 $2,952 $337,683 75% 25%
Georgia $92,765 $0 $92,765 76% 24%
Louisiana $43,117 $23,547 $66,664 78% 22%
Montana $10,870 $51,498 $62,368 67% 33%
Oklahoma $21,644 $11,616 $33,260 76% 24%
Mississippi $7,215 $0 $7,215 86% 14%
North Dakota $0 $8,974 $8,974 73% 27%
T O T A L $ 6 , 8 1 5 , 6 5 2 $ 6 , 6 2 1 , 0 1 1 $ 1 3 , 4 3 6 , 6 6 3
*Sources: National Gay and Lesbian Task Force and The Marriage Amendment Project
Most of the money came from organizations, rather than the average citizen on the street.
Individual contributors gave about $4.1 million, or about 31 percent of the funds. But some
individuals gave heavily, accounting for a significant portion of the funds. Twenty-one individuals
gave $10,000 or more, for contributions totaling slightly more than $1 million, representing about
one-fourth of the money given by individual contributors.
The ballot committees reported another $1.1 million in unitemized contributions donations in
amounts that fell below a particular states threshold for reporting the names and other identifying
information of the contributors. Many of these contributions came from individuals giving small
amounts or money collected at fund-raising events.
M E T H O D O L O G Y
For this analysis, the Institute collected the campaign-finance reports that ballot measure
committees filed with the state disclosure agency in their respective states. The committees
contributions and expenditures were entered into a database for analysis.
Institute staff use the employer and occupation information provided on disclosure reports to
assign an occupation code to contributors. When that information is not provided, staff members
conduct additional research to determine a contributors economic interest, where possible. The
occupation codes are based on the Standard Industrial Classification system used by the federal
government.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 19 of 99 Pg ID 1211
The Institute on Money in State Politics 2006 6
A R U S H T O A M E N D
Before 2004, only six states had placed a definition of marriage as the union of a man and a
woman in their state constitutions, although 33 states had defined marriage as such in their state
laws.
3
But two pivotal events occurred in 2003 that added fuel to an ongoing debate over the definition of
marriage:
In June, the U.S. Supreme Court struck down a Texas law that
criminalized homosexual sex, citing the right to privacy.
In November, the Massachusetts Supreme Judicial Court struck down
that states law prohibiting same-sex marriages.
Those two court rulings helped revive a flagging effort to amend the U.S. Constitution to include a
definition of marriage. A federal amendment had been introduced in 2002 and again in 2003, but
had languished in Congress.
Congress had already passed the Defense of Marriage Act in 1998, defining marriage in law. But
same-sex marriage opponents had remained concerned that judicial rulings could void that law.
Supporters contended that only a federal constitutional amendment would ensure that no federal or
state court ruling could impose a different standard.
The court rulings in 2003 gave new impetus to the drive to constitutionally define marriage.
President Bush came out in support of a federal amendment in February 2004.
4
The effort gained
even more momentum after a series of highly publicized same-sex marriages in the winter and
spring of 2004, not only in Massachusetts, but also in New York, Oregon, New Mexico and
California.
In July 2004, the latest version of the Federal Marriage Amendment came up for a procedural vote
in the U.S. Senate, to determine whether it should go on to a full vote. However, supporters failed
to obtain the 60 votes needed to move the measure forward. Even had the amendment come to a
vote and secured the required two-thirds approval of each house, it still would have needed the
approval of three-fourths of the state legislatures. Supporters acknowledged that the constitutional
ratification process would be lengthy, and not necessarily successful.
But things move faster at the state level. And in 2004, same-sex marriage opponents turned their
attention to the states, with efforts to amend state constitutions while the federal amendment
remained in limbo. Those efforts helped place the issue on the ballot in 13 states.
In Mississippi, Missouri, Montana and Oregon, the ballot measures simply defined marriage as the
union of a man and woman. Measures in the remaining states Arkansas, Georgia, Kentucky,
Louisiana, Michigan, North Dakota, Ohio, Oklahoma and Utah also prohibited recognition of

3
Same Sex Marriage Measures on the 2004 Ballot, National Conference of State Legislatures, Nov. 17, 2004
[on-line]; available from http://www.ncsl.org/programs/legman/statevote/marriage-mea.htm; Internet; accessed
Nov. 21, 2005.
4
Susan Page and Richard Benedetto, Bush Backs Gay-Marriage Ban, USA Today, Feb. 25, 2004, p. 1.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 20 of 99 Pg ID 1212
The Institute on Money in State Politics 2006 7
civil unions. And the Oklahoma measure made it a misdemeanor crime to issue marriage licenses
to same-sex couples.
5
In some states, lawmakers placed the measures on the ballot via legislation. In others, same-sex
marriage opponents used the initiative process. Whatever the route taken, the debate in all states
was bitter.
Supporters painted the measures both at the federal and state levels as necessary to preserve
moral values and circumvent judges who wanted to legislate from the bench. Opponents decried
them as discriminatory. And many political observers questioned whether the measures were
simply a way for conservative groups to mobilize their voters in what was expected to be a close
presidential election and in states where U.S. Senate and House seats were up for grabs. Four of
the amendments were on the ballot in states considered key to the presidential election: Arkansas,
Michigan, Ohio and Oregon.
6
Democratic Congressman William Jefferson of Louisiana criticized President Bushs call for a
national constitutional amendment in February 2004, contending the president was merely trying
to draw conservative voters to the polls. Elections are all about turnout, he said. This is about
energizing people when you dont have answers on other big issues, like health care and the
economy.
7
And indeed, leaders of conservative Christian groups found the developments around the country
to be the catalyst they needed to not only move forward on the marriage issue, but also to motivate
voters.
James Dobson, head of the evangelical Christian organization Focus on the Family, said the issue
of gay marriage was one of the most influential factors in the outcome of the 2004 election. In a
piece published on the Focus on the Family Action Web site, Dobson wrote: I am among those
who believe the President would not have won re-election if it had not been for the power of this
issue to drive conservative voters to the polls.
8

5
Same Sex Marriage Measures on the 2004 Ballot, National Conference of State Legislatures, Nov. 17, 2004
[on-line]; available from http://www.ncsl.org/programs/legman/statevote/marriage-mea.htm; Internet; accessed
Nov. 21, 2005.
6
Ibid.
7
Bill Walsh, Bush takes hard line on gay marriage; rivals say move is a political stunt, Times Picayune, Feb.
25, 2004, p. 1.
8
Dr. James Dobson, Looking Back, Looking Ahead, Focus on the Family Action [on-line]; available from
http://www.focusaction.org/articles/a0000050.cfm; Internet; accessed Dec. 30, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 21 of 99 Pg ID 1213
The Institute on Money in State Politics 2006 8
A N E T W O R K F O R M S
On the ground in the 13 states, efforts to promote and defeat the measures were led and supported
by a variety of people active in their churches, involved in human rights groups or conservative
causes, or simply impassioned by the topic.
But a few news stories during those months showed another force was at work, as well.
In September 2003, the Boston Globe reported the formation of the Arlington Group, a coalition
of evangelical Christian and other conservative organizations.
9
The group was called together by
the Rev. Donald Wildmon of Mississippi; Wildmon is chairman of the American Family
Association, which runs a network of more than 200 Christian radio stations and affiliate groups.
10
The Globe article said leaders of the groups began meeting in July 2003 to address the threat they
saw in the U.S. Supreme Court ruling and the possibility the Massachusetts high court may
invalidate that states ban on gay marriage. Wildmon said religious conservatives mobilized too
slowly after the 1973 Supreme Court ruling that legalized abortion and needed to act sooner on
same-sex marriages because the danger is now.
Subsequent news articles in publications such as The New York Times, The Washington Post, USA
Today and Time magazine frequently quoted members of the Arlington Group on the issue of
same-sex marriage, but made only passing reference to the existence of the group. Those quoted
were instead usually linked to the organization with which they were directly tied, including James
Dobson of Focus on the Family, Tony Perkins of the Family Research Council, Richard Land of
the Southern Baptist Convention and conservative activist Gary Bauer.
By early to mid-2004, articles in regional newspapers also made mention of the groups existence,
but with little explanation of who was involved:
A Feb. 24 article in The Times Picayune of New Orleans mentioned
that the Arlington Group was pressing its case for a national
amendment with President Bush and his top adviser, Karl Rove.
A Washington Post article reprinted in the Milwaukee Journal-Sentinel
on March 9 said leaders of the Arlington Group had jointly hired or
loaned several full-time staff members to work on the gay-marriage
issue.
The Rev. William Owens, a member of the group, wrote a piece for the
Memphis Commercial Appeal on June 20, saying the executive board
of the Arlington Group had attended a meeting of the Coalition of
African-American Pastors to speak to them about supporting the
Federal Marriage Amendment.
A news brief in the Dayton Daily News on July 12 noted that Ohio
Secretary of State J. Kenneth Blackwell was the only non-senator to
speak at a meeting of the U.S. Senate Republican Conference, where he

9
Mary Leonard, Gay Marriage Stirs Conservatives Again, Boston Globe, Sept. 28, 2003, p. 1.
10
Ibid.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 22 of 99 Pg ID 1214
The Institute on Money in State Politics 2006 9
discussed the need for a federal constitutional amendment defining
marriage. Blackwells name is on lists of Arlington Group members.
11
And on July 14, the Omaha World-Herald reported that at the request
of the Arlington Group, several churches urged their congregations to
call their U.S. senators to support the proposed federal marriage
amendment.
A B O U T T H E A R L I N G T O N G R O U P
The Arlington Group is made up of the leaders of numerous conservative religious and social
groups. Reports from various time periods list anywhere from 20 members (in early 2004)
12
to
more than 60 (in 2005).
13
A list on the Ohio section of the American Policy Roundtable Web site
and a 2005 letter to presidential adviser Karl Rove each contain the same list of 47 names. (See
Appendix A on P. 55.)
An October 2003 press release on the Web site of Americans United to Preserve Marriage, an
organization headed by Gary Bauer, made mention of a group of two dozen conservative and
religious groups that pledged to use their bully pulpits, media outlets and other grass-roots
resources to rouse national and political support for traditional marriage.
14
The news release
quotes seven people whose names appear on lists of Arlington Group members, but never
identifies the coalition by that name.
The Origins of the Arlington Group
The Arlington Groups formation and purpose are described in detail in a December 2004 column
written by Arlington Group member Paul Weyrich of the Free Congress Research and Education
Foundation and published on the Web site of Renew America, a group headed by Reagan
appointee and conservative commentator Alan Keyes.
Weyrichs column says that several months earlier, the Rev. Wildmon of the American Family
Association began contacting leaders of religious groups, suggesting that they begin to work
together on daunting social problems.
15
He correctly said, Weyrich wrote, that if we all went our separate ways we would not amount
to much. However, if we could all sing off the same sheet of music, we could be a significant
force.

11
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005. A Jan. 17,
2006, phone call to the Ohio Secretary of States Office to confirm Blackwells participation in the Arlington
Group was referred to the office for Blackwells current gubernatorial campaign; a campaign staffer said
Blackwell participates in the group and has received phone calls from the Arlington Group.
12
Statement from Arlington Group on Todays Marriage Ruling in Massachusetts, Family Research Council,
Feb. 4, 2004 [on-line]; available from http://www.frc.org/get.cfm?I=PRO4B04; Internet; accessed Dec. 6, 2005.
13
Russell Shorto, Whats Their Real Problem with Gay Marriage? Its the Gay Part, The New York Times,
June 19, 2005, sec. 6, p. 34.
14
Groups Pledge to Protect Marriage, Americans United to Preserve Marriage, Oct. 3, 2003 [on-line]; available
from http://www.americansformarriage.org/press_release_article.php?id=10030301; Internet; accessed Dec. 7,
2005.
15
Paul Weyrich, The Arlington Group, Renew America, Dec. 3, 2004 [on-line]; available from
http://www.renewamerica.us/columns/weyrich/041203; Internet; accessed Nov. 21, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 23 of 99 Pg ID 1215
The Institute on Money in State Politics 2006 10
Weyrich said the group of religious and conservative leaders first met at a condominium in the
Washington, D.C., suburb of Arlington, Va. That location led to the permanent name for the
ongoing coalition the Arlington Group. Its meetings, he said, are not secret but they are off the
record.
Early on, he wrote, the group agreed to work on the marriage issue. Indeed the effort to put
marriage on the ballot in eleven States emanated from the Arlington Group. And the resources to
go full-tilt in Ohio were raised from participants in the group.
In fact, campaign contributions from member groups of the coalition went most heavily to Ohio,
totaling $1.18 million, nearly all of the money given to support Ohios amendment and 59 percent
of the $1.99 million in contributions given by organizations or individuals connected with the
Arlington Group.
And two members of the Arlington Group were key players in the Ohio effort: Phil Burress of the
Ohio-based Citizens for Community Values, a Focus on the Family affiliate,
16
and Ohio Secretary
of State J. Kenneth Blackwell.
17
Not only did Arlington Group member organizations funnel financial resources to Ohio, but they
also gave heavily in two other states considered to be presidential battlegrounds $546,600 in
Michigan and $138,360 in Oregon. However, Arlington Group contributions in these states made
up a much smaller percentage of the total money favoring the amendments, representing 28
percent of the funds in favor in Michigan and 6 percent in Oregon.
Groups Contributions, Efforts Add Up
Members of the Arlington Group backed their beliefs with their money and their organizational
force.
Focus on the Family, a Colorado-based organization headed by
Arlington Group member James Dobson, created ballot measure
committees to raise and spend money in seven of the 13 states:
Arkansas, Georgia, Kentucky, Louisiana, Michigan, Mississippi and
Montana. It also gave $255,600 in either direct or in-kind contributions
to its committees, as well as to other committees in Ohio and Oregon.
In addition, separate state groups related to Focus on the Family created
their own ballot committees in Arkansas, Kentucky, Louisiana and
Michigan. These state groups also contributed to other ballot
committees in Arkansas, Michigan, Montana and Ohio.
The Family Research Council gave $376,400 to committees in
Michigan, including $186,400 to a committee it established there.
Traditional Marriage Crusade ballot committees formed in nine states
and raised $27,600 in eight states. In many of those states, it was the
first ballot committee to organize in support of the measure. On its
statement of organization in Mississippi, the group described itself as a

16
Citizens for Community Values [on-line]; available from http://www.ccv.org; Internet; accessed Dec. 15, 2005.
17
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 24 of 99 Pg ID 1216
The Institute on Money in State Politics 2006 11
special campaign of The Foundation for a Christian Civilization,
which also is the corporate name of the American Society for the
Defense of Tradition, Family and Property (TFP).
18
C. Preston Noell III
is on the TFP board of directors
19
and is editor of Crusade, a TFP
magazine.
20
He also is a member of the Arlington Group.
21
The society
was founded by a group of Catholic Americans in 1973;
22
its Web site
noted that it was working to get marriage amendments on ballots across
the country and working with other organizations by sending postcards
and making calls to friends and supporters urging them to act.
23
The American Family Association and its broadcasting arm, American
Family Radio, gave $6,200 in Kentucky and Michigan. Its Kentucky
affiliate also gave about $29,350 to support the amendment there.
And the Arlington Groups influence wasnt limited to money. News reports noted that group
members held weekly conference calls that included White House staff members.
24
Tables on the following page show how much money individuals or organizations associated with
the Arlington Group gave in each of the states with a marriage-related ballot measure in 2004, as
well as the total amount organizations associated with the group gave.

18
The Idea of a Counter-Revolution: Who We Are, The American Society for the Defense of Tradition, Family
and Property [on-line]; available from http://www.tfp.org/who_we_are/the_counter_rev.html; Internet; accessed
Sept. 9 , 2005.
19
Ibid.
20
About Crusade: A Magazine of the American TFP, The American Society for the Defense of Tradition,
Family and Property [on-line]; available from http://www.tfp.org/magazine/about_htm; Internet; accessed Dec.
12, 2005.
21
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005.
22
The Idea of a Counter-Revolution: Who We Are, The American Society for the Defense of Tradition, Family
and Property [on-line]; available from http://www.tfp.org/who_we_are/the_counter_rev.html; Internet; accessed
Sept. 9 , 2005.
23
What Are You Doing to Stop Same-Sex Marriage?, The American Society for the Defense of Tradition,
Family and Property [on-line]; available from http://www.tfp.org/tfc/what_are_you_doing.htm; Internet; accessed
Dec. 8, 2005.
24
Alan Cooperman, Evangelical Groups Plan Aggressive Drive for Nominee, Washington Post, July 3, 2005,
sec. Business, and Americas Religious Right: You Aint Seen Nothing Yet, The Economist, June 25, 2005,
Issue 950.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 25 of 99 Pg ID 1217
The Institute on Money in State Politics 2006 12
A R L I N G T O N G R O U P M E M B E R C O N T R I B U T I O N S B Y S T A T E , 2 0 0 4
S T A T E A M O U N T
% O F T O T A L R A I S E D
I N F A V O R
Ohio $1,183,485 98%
Michigan $546,599 28%
Oregon $138,364 6%
Kentucky $67,543 33%
Arkansas $19,330 6%
Georgia $17,650 19%
Montana $8,959 82%
Mississippi $5,266 73%
Oklahoma $1,295 6%
Utah $643 0.1%
Louisiana $411 1%
T O T A L $ 1 , 9 8 9 , 5 4 5 2 9 %
C O N T R I B U T I O N S F R O M A R L I N G T O N G R O U P A N D R E L A T E D O R G A N I Z A T I O N S , 2 0 0 4
C O N T R I B U T O R T O T A L
Citizens for Community Values Action $1,182,139
Family Research Council $376,397
Focus on the Family $255,604
Michigan Family Forum $68,386
American Family Association of Kentucky $29,344
The Family Foundation of Kentucky Inc. $19,664
Public Interest Forum $19,500
Family Trust Foundation of Kentucky Inc. $14,395
Montana Family Foundation $6,765
The Foundation for a Christian Civilization Inc. $5,951
American Family Association $5,000
American Family Radio* $1,200
Arkansas Family Council $950
T O T A L $ 1 , 9 8 5 , 2 9 4
* American Family Radio is a division of the American Family Association.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 26 of 99 Pg ID 1218
The Institute on Money in State Politics 2006 13
T H E F O R C E S A G A I N S T
While conservative groups banded together to support the marriage amendments, national gay-
and lesbian-rights groups also were active. However, their efforts appeared less cohesive, and
leaders of national groups acknowledged that at times, they were out-organized by the supporters
of the amendments and had fewer resources to put into the states.
25
A few groups spent heavily in targeted states, in an effort to ward off limits on the definition of
marriage or outright bans on civil unions. But most of the money to fight the amendments was
generated by groups and individuals within the affected states.
Significant contributions came in from the following national groups:
The Human Rights Campaign, which works to advance equality based
on sexual orientation and gender expression and identity.
26
This group
put nearly $1.1 million into the ballot battles in five states: Michigan,
Missouri, Ohio, Oregon and Utah.
The National Gay and Lesbian Task Force, which describes itself as
the nations first national lesbian, gay, bisexual and transgender civil
rights and advocacy organization.
27
It gave almost $790,000 in six
states: Kentucky, Michigan, Missouri, Montana, Oregon and Utah.
The Log Cabin Republicans, which supports gay and lesbian rights and
describes itself as the nations leading voice for fairness, inclusion and
tolerance in the GOP.
28
The group gave $40,000 in Oregon.
Funds from national groups made up nearly 30 percent to 40 percent of the total raised to fight the
amendments in four of the seven states involved, falling below that level in Kentucky, Montana
and Utah. But little other gay-rights giving crossed state lines. Instead, most groups concentrated
their efforts on the states in which they were located, with the heaviest giving in Oregon and Utah.
The national groups appeared to give most heavily in states considered to be battlegrounds, giving
much less to committees in states likely to vote Republican, such as Utah and Montana.
The table on the following page shows where national gay- and lesbian-rights groups put their
funds.

25
Monica Davey, Sharp Reactions to Missouris Decisive Vote Against Gay Marriage, The New York Times,
Aug. 5, 2004, sec. A, p. 17, and Sandeep Kaushik, Gay Marriage Backers Focus on Ore. Battle, Boston
Globe, Sept. 27, 2004, sec. A, p. 3.
26
About the Human Rights Campaign, Human Rights Campaign [on-line]; available from http://
www.hrc.org/Template.cfm?Section=About_HRC; Internet; accessed Jan. 10, 2006.
27
What We Do, National Gay and Lesbian Task Force [on-line]; available from
http://www.thetaskforce.org/aboutus/whatwedo.cfm; Internet; accessed Dec. 5, 2005.
28
About Log Cabin, Log Cabin Republicans [on-line]; available from http://online.logcabin.org/about/; Internet:
accessed Jan. 13, 2006.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 27 of 99 Pg ID 1219
The Institute on Money in State Politics 2006 14
N A T I O N A L G A Y - A N D L E S B I A N - R I G H T S G R O U P G I V I N G B Y S T A T E , 2 0 0 4
S T A T E A M O U N T
% O F T O T A L R A I S E D
I N O P P O S I T I O N
Oregon $1,015,636 35%
Ohio $384,145 41%
Michigan $244,081 29%
Missouri $133,250 27%
Kentucky $73,350 14%
Utah $65,000 8%
Montana $10,000 19%
T O T A L $ 1 , 9 2 5 , 4 6 2 2 9 %
Interestingly, the national gay- and lesbian-rights groups gave 29 percent of the total money raised
to fight the measures in all 13 states, nearly identical to the percentage the Arlington Group
members gave of the total dollars given in support of the amendments. And in all states where
supporters of gay and lesbian rights contributed, the money whether from individuals or from
national, state or local groups made up a sizable share of the money raised in opposition.
G A Y - A N D L E S B I A N - R I G H T S G I V I N G B Y S T A T E , 2 0 0 4
S T A T E A M O U N T % O F T O T A L A G A I N S T
Oregon $1,400,679 48%
Ohio $547,076 58%
Utah $478,550 61%
Michigan $286,625 34%
Kentucky $157,681 30%
Missouri $147,294 30%
Montana $26,814 52%
Oklahoma $8,816 76%
North Dakota $2,000 22%
T O T A L $ 3 , 0 5 3 , 5 3 5 4 6 %
The table below shows the top contributors among all groups supporting gay- and lesbian-rights.
T O P 1 0 N O N - I N D I V I D U A L G A Y - A N D L E S B I A N - R I G H T S C O N T R I B U T O R S , 2 0 0 4
C O N T R I B U T O R L O C A T I O N T O T A L
Human Rights Campaign Washington, DC $1,089,754
National Gay & Lesbian Task Force Washington, DC $789,358
Bruce W. Bastian Foundation Orem, UT $239,000
Basic Rights Oregon Portland, OR $184,243
Log Cabin Republicans Washington, DC $40,000
Pride Source Media Group Farmington, MI $24,995
Ohioans for Growth & Equality Columbus, OH $20,000
Equality Utah Salt Lake City, UT $17,500
Fairness Campaign Louisville, KY $17,000
Pride Inc. Helena, MT $15,067
T O T A L $ 2 , 4 3 2 , 9 1 7
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 28 of 99 Pg ID 1220
The Institute on Money in State Politics 2006 15
Some individual contributors also gave heavily but primarily in only one state. The biggest
individual contributors were:
Bruce Bastian, the openly gay founder of WordPerfect software.
29
Bastian gave $178,000 in Utah, Oregon and Ohio. He gave most
heavily in his home state of Utah, contributing $125,500 to the Dont
Amend Alliance, the group fighting Amendment 3 there. He also gave
$27,500 in Oregon and $25,000 in Ohio.
Tim Gill, who co-founded the Quark software company and promotes
fair treatment of gays and lesbians through his Gill Foundation,
30
ranked second among individual contributors, giving $150,000 to
oppose the Oregon ballot measure.
David Maltz, who is involved with the Stonewall Democrats, a pro-gay
rights group of Democrats. He gave $101,383 in Ohio.

29
Robert Gehrke, Donors on Record Pace, Salt Lake Tribune, Aug. 23, 2004, sec. A.
30
Meet Tim Gill, Gill Foundation [on-line]; available from
http://www.gillfoundation.org/about_show.htm?doc_id=75988; accessed Oct. 18, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 29 of 99 Pg ID 1221
The Institute on Money in State Politics 2006 16
T O P C O N T R I B U T O R S A C R O S S T H E 1 3 S T A T E S
While the same-sex marriage debates stirred strong emotions in all 13 states, that emotion seemed
to translate more readily into votes than into money. The cash to run the campaigns for and against
the amendments came largely from big-dollar contributors, both individually and through
organizations.
In fact, the top 20 individual and top 20 non-individual givers contributed $7.2 million of the
approximately $13.4 million given to the ballot committees, or 54 percent of the total.
Citizens for Community Values Action led all contributors, pouring nearly $1.2 million into
Ohios Issue 1 in 2004. The group is an offshoot of Citizens for Community Values,
31
an
Arlington Group member founded in 1983 by a group of Cincinnati-area ministers and now
designed to promote Judeo-Christian moral values.
32
In addition to being listed as an Arlington
Group member in its own right, Citizens for Community Values is also affiliated with Arlington
Group member Focus on the Family.
33
The Human Rights Campaign put nearly $1.1 million into the ballot-measure battles in Michigan,
Missouri, Ohio, Oregon and Utah. The National Gay & Lesbian Task Force ranked third in
contributions, giving $789,360 to fight the amendments in Kentucky, Michigan, Missouri,
Montana, Oregon and Utah.
Only one other contributor among the top non-individual givers spread funds to more than one
state. Focus on the Family, the Arlington Group member based in Colorado Springs, Colo., gave
$255,600 to committees backing the amendments in Arkansas, Georgia, Michigan, Mississippi,
Montana, Ohio and Oregon. The organization describes its mission as disseminating the Gospel
of Jesus Christ to as many people as possible and, specifically, to accomplish that objective by
helping to preserve traditional values and the institution of the family.
34
C O N T R I B U T I O N S B Y O R G A N I Z A T I O N S
The top 20 non-individual contributors gave $6.1 million. Among these top givers, supporters of
the proposals to limit marriage to a man and a woman gave more $3.8 million, or 62.5 percent
of the $6.1 million. Those organizations opposed to the amendments gave nearly $2.3 million. The
top contributors favoring the amendments gave most heavily in Michigan, Ohio and Oregon;
nearly 90 percent of their contributions went to those three states. Those opposing the amendments
gave most heavily in Oregon, channeling 51 percent of their dollars into that state, with Ohio and
Utah receiving the next largest amounts of money.

31
April Yee, Paid Recruits Fight Gay Marriage, Cincinnati Post, July 24, 2004 [newspaper on-line]; available
from http://www.cincypost.com/2004/07/24/pet072404.html; accessed Oct. 18, 2005.
32
Mission and Vision: Who Is CCV?, Citizens for Community Values [on-line]; available from
http://www.ccv.org/About_CCV.htm; accessed Oct. 18, 2005.
33
Citizens for Community Values [on-line]; available from http://www.ccv.org; Internet; accessed on Dec. 15,
2005.
34
Our Mission, Focus on the Family [on-line]; available from
http://www.family.org/welcome/aboutfof/a0005554.cfm; accessed Sept. 9, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 30 of 99 Pg ID 1222
The Institute on Money in State Politics 2006 17
T O P 2 0 N O N - I N D I V I D U A L C O N T R I B U T O R S T O M A R R I A G E A M E N D M E N T S , 2 0 0 4
C O N T R I B U T O R L O C A T I O N P O S I T I O N T O T A L
Citizens for Community Values Action* Cincinnati, OH For $1,182,139
Human Rights Campaign** Washington, DC Against $1,089,754
National Gay and Lesbian Task Force** Washington, DC Against $789,358
Archdiocese of Detroit Detroit, MI For $538,100
Christian Copyright Licensing Inc. Portland, OR For $410,000
Family Research Council* Washington, DC For $376,397
Focus on the Family* Colorado Springs, CO For $255,604
Bruce W. Bastian Foundation Orem, UT Against $239,000
Basic Rights Oregon Portland, OR Against $184,243
A.K. Holding Co. Provo, UT For $175,000
Marriage Education Initiatives Salt Lake City, UT For $171,000
Diocese of Lansing Lansing, MI For $133,350
Gateway Communications Portland, OR For $120,439
Diocese of Grand Rapids Grand Rapids, MI For $106,100
Diocese of Saginaw Saginaw, MI For $87,500
Michigan Family Forum* Lansing, MI For $68,386
Christian Values Fund Muscatine, IA For $50,000
Diocese of Gaylord Gaylord, MI For $49,250
Diocese of Kalamazoo Kalamazoo, MI For $47,450
Rolling Hills Community Church Tualatin, OR For $46,200
T O T A L T O P 2 0 $ 6 , 1 0 6 , 2 7 0
*Arlington Group members or affiliates of Arlington Group members. Contributions totaled $1.88 million.
** National gay- and lesbian rights group. Contributions totaled $1.88 million.
C O N T R I B U T I O N S B Y I N D I V I D U A L S
The top 20 individual contributors gave $1.1 million, or about 8 percent of the total contributions
reported by the marriage amendment committees. Amendment opponents gave two-thirds of that
total, about $753,000. In fact, four of the top five individual contributors gave to committees
opposing the amendments. Supporters gave about $363,770.
Top-contributing individuals who opposed the amendments gave most heavily in Oregon, which
received about 40 percent of their contributions. Another 26 percent of their funds went to Utah,
while 22 percent went to Ohio.
Top-contributing individuals who supported the amendments put 82 percent of their money into
Michigan and Oregon, splitting it fairly evenly between the two states $150,500 to Michigan
and $148,000 to Oregon.
The table on the following page lists the individuals who gave $20,000 or more to ballot
committees.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 31 of 99 Pg ID 1223
The Institute on Money in State Politics 2006 18
T O P 2 0 I N D I V I D U A L C O N T R I B U T O R S T O M A R R I A G E A M E N D M E N T S , 2 0 0 4
C O N T R I B U T O R H O M E T O W N I N D U S T R Y P O S I T I
O N
T O T A L
Bastian, Bruce W. Orem, UT Gay & Lesbian Rights Against $178,000
Gill, Tim Denver, CO Gay & Lesbian Rights Against $150,000
Maltz, David Beachwood, OH Gay & Lesbian Rights Against $101,383
Nedelisky, Neil West Linn, OR Real Estate For $101,000
Wilson, Robert W. Brooklyn, NY Finance Against $100,000
Broekhuizen, Elsa Prince Holland, MI Securities & Investment For $75,000
Marquardt, Jane A. Salt Lake City, UT Lawyers & Lobbyists Against $47,670
Wallace, Carla Louisville, KY Gay & Lesbian Rights Against $44,004
Lee, William Saginaw, MI Computer Equipment & Services For $35,500
Gaby, Richard D. Duluth, GA Lodging & Tourism For $25,000
Lewis, Jonathan Coral Gables, FL Real Estate Against $25,000
Gilmour, Allan Birmingham, MI Automotive Against $25,000
Templeton, John Bryn Mawr, PA Christian Conservative For $25,000
Bisenius, James Sherwood, OR Securities & Investment For $22,000
Marquardt, Robert Ogden, UT Miscellaneous Business Against $22,000
Buttars, D. Chris West Jordan, UT Republican Officials/Candidates For $20,269
DeVos Sr., Richard Grand Rapids, MI Retail Sales For $20,000
Dewan, Michael Putnam, MI Retired For $20,000
Heiner, Hal Louisville, KY Real Estate For $20,000
Springer, Gerald N. Chicago, IL TV Production Against $20,000
Stryker, Jon Kalamazoo, MI Construction Services Against $20,000
Wexner, Abigail S. Hudson, OH Retail Sales Against $20,000
T O T A L T O P 2 0 $ 1 , 1 1 6 , 8 2 6
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 32 of 99 Pg ID 1224
The Institute on Money in State Politics 2006 19
W H E R E T H E M O N E Y W E N T
The ballot committees in the 13 states reported spending nearly $12.2 million on their activities.
Not surprisingly with such an emotionally charged issue, proponents and opponents turned to
broadcast advertising to make their arguments and sway the voters.
Committees reported spending $5.34 million on broadcast advertising. Those opposing the
amendments spent $3.34 million in this category, or 62.5 percent of the broadcast advertising
total. Committees supporting the amendments spent $2 million. Committees spent most heavily on
broadcast advertising in Oregon, Ohio, Utah and Michigan.
The committees reported spending another $1.7 million on consultants, about $1 million on
salaries, $1 million on direct mail expenses, and nearly $902,000 on get-out-the-vote efforts.
Committees in Michigan reported spending nearly $1.1 million of the $1.7 million spent on
consultants, with pro-amendment committee Citizens for the Protection of Marriage spending all
but $10,000 of the money paid to consultants in Michigan. The committee paid the Sterling Corp.,
a political consulting firm that works primarily with Republicans, nearly $985,000 for its services.
It also paid $136,300 to National Petition Management Inc., which is a full-service petition
management company that helps organizations collect signatures to qualify measures for the
ballot, through paid signature-gathering efforts or by managing volunteer efforts.
35
Direct mail expenses were far and away the highest in Oregon, where committees reported
spending $637,200 on costs related to mailings. Arkansas committees trailed at $72,850.
Some companies did business with amendment committees in more than one state:
Four committees fighting the amendments paid a combined $177,500
for polling and research services from Decision Research, which
describes itself as a Democratic national public opinion research
firm.
36
Its client list includes the Human Rights Campaign, the top
contributor to anti-amendment efforts. No on Constitutional
Amendment 36, the group opposing the Oregon amendment, reported
payments of $88,341 to the company. Other committees that did
business with this firm were the Dont Amend Alliance in Utah,
$37,585; Kentucky Families for Fairness, $31,920; and the Constitution
Defense League in Missouri, $19,620.
Anti-amendment committees in three states hired Laguens Hamburger
Stone for media and political advice, paying a combined total of nearly
$89,700. The companys client list includes numerous Democratic
candidates, as well as labor, environmental and progressive groups. It
also includes the Human Right Campaign and Basic Rights Oregon,
37

35
About NPM, National Petition Management [on-line]; available from http://www.aboutnpm.com/index.htm;
Internet; accessed Jan. 17, 2006.
36
Introducing Decision Research, Decision Research [on-line]; available from
http://www.decisionr.com/intro.htm; Internet; accessed Jan. 6, 2006.
37
Past and Present Clients, Laguens Hamburger Kully Klose [on-line]; available from
http://www.lhkkmedia.com/clients.html; Internet; accessed Jan. 6, 2006. Web links to Laguens Hamburger
Stone now go to the Web site for Laguens Hamburger Kully Klose, which is at the same Washington, D.C.,
address.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 33 of 99 Pg ID 1225
The Institute on Money in State Politics 2006 20
which contributed heavily to the anti-amendment effort in Oregon. No
on Constitutional Amendment 36 in Oregon paid the firm $76,634 for
political consulting and ad preparation, while the Constitution Defense
League in Missouri paid $6,700 for production of television ads and
Kentucky Families for Fairness paid $6,350 for advertising.
CC Advertising Inc., a Virginia firm, received $70,200 from three
committees supporting the amendments. The Yes! Marriage
Amendment Alliance in Georgia paid $36,621 for telephone surveys
and canvassing, while the Ohio Campaign to Protect Marriage paid
$600 for an expense it described as a phone blitz to churches. The
Defense of Marriage Coalition in Oregon paid the company $33,000 for
surveys and polls.
David A. Smith Printing Inc. of Pennsylvania printed fliers and direct
mail pieces for pro-amendment committees formed by the Traditional
Marriage Crusade in six states: Arkansas, Kentucky, Louisiana,
Mississippi, Ohio and Utah. The company received payments totaling
about $6,270.
The Ohio Campaign to Protect Marriage also paid Design 4 Advertising $600,000 for statewide
TV advertising. Arlington Group member lists include an individual named Clint Cline who is
listed as being associated with a company called Design 4.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 34 of 99 Pg ID 1226
The Institute on Money in State Politics 2006 21
L O O K I N G D O W N T H E R O A D
The state-level ballot measures to constitutionally define marriage as the union of a man and a
woman were wildly successful in 2004, leading to some introspection among gay-rights groups
and plans for how to change the direction of the debate in the future.
Meanwhile, supporters of the marriage amendments, particularly members of the Arlington Group,
indicated they would not merely rest on their laurels.
I N S E A R C H O F N E W S T R A T E G I E S
Where conservative groups appeared more unified after their push for the amendments, the groups
opposing them appeared to suffer effects that went beyond the polls. Following the decisive
defeats in November 2004, some activists began questioning the effectiveness of the Human
Rights Campaign and the support it had given to state groups.
38
The campaigns executive
director, Cheryl Jacques, resigned after holding the post for less than a year.
39
The battering that gay- and lesbian-rights advocates took at the polls also left key national groups
looking for new ways to fight future attempts to further define marriage at the state level.
In a November 2005 speech, National Gay and Lesbian Task Force Executive Director Matt
Foreman called on supporters to go on the offensive in the ballot-measure battle.
First, lets start proclaiming our moral values personal liberty and equality for all not only
for those who are white, or rich, or who subscribe to a particular kind of Christian dogma, he
said, adding: We must say over and over and over again, simply, directly and unambiguously that
anti-gay, anti-lesbian, anti-bisexual and anti-transgender discrimination in all its forms is
immoral.
40
Foreman suggested a plan that included having non-gay people speak out with the same
vehemence as they would if it was another minority under attack; taking issue with putting the
rights of a minority up for a popular vote; and including the religious community in the efforts.
Now, more than ever, we need LGBT people of faith and their allies to speak to other religious
peopleand demanding not pleading for help, he said.
The Human Rights Campaign, meanwhile, has outlined its Marriage Project on its Web site.
Strategies include developing language to counteract fears about gay marriage and cultivate
support for marriage equality; presenting the stories of gay and lesbian couples through

38
Sarah Wildman, Tough Times at HRC, The Advocate, March 29, 2005, p. 30.
39
Evelyn Nieves, Largest Gay Rights Group Gets New Chief, Washington Post, March 10, 2005 [newspaper
on-line]; available from http://www.washingtonpost.com/wp-dyn/articles/A21703-2005Mar9.html; Internet;
accessed Sept. 9, 2005.
40
Matt Foreman, Reclaiming Moral Values: A Lesbian, Gay, Bisexual and Transgender Agenda for 2006,
keynote address at the 18
th
Annual Creating Change Conference, National Gay and Lesbian Task Force [on-
line]; available from http://www.thetaskforce.org/downloads/ReclaimingMoralValues.pdf; Internet; accessed
Dec. 29, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 35 of 99 Pg ID 1227
The Institute on Money in State Politics 2006 22
advertising, legislative testimony, and media appearances; developing state-by-state strategies; and
building alliances with other gay- and lesbian-rights groups.
41
Another prominent gay-rights advocate, Tim Gill, has created the Gill Action Fund to, among
other things, fight future constitutional amendment attempts at the state level.
42
Gill, who founded
software company Quark Inc. and profited substantially from the sale of his share of the firm,
established the Gill Foundation in 1994 to support gay and lesbian rights. He gave $150,000 of his
own money to oppose the Oregon initiative in 2004.
His new political nonprofit organization will be funded solely by Gill and will work at the national
level. Rodger McFarlane, executive director of the Gill Foundation, said the Gill Action Fund
wasnt a reaction to the 2004 elections, saying instead: This is the evolution of Tim Gill. This
doesnt reflect anything more than his increasing influence and his own sense of responsibility as a
citizen and a very privileged citizen.
43
T H E A R L I N G T O N G R O U P S C O N T I N U I N G I N T E R E S T S
In his December 2004 column on the Renew America Web site, Paul Weyrich noted that the
Arlington Groups activities were part educational and part lobbying, and could involve turning
recalcitrant lawmakers out of office through the election process.
Only God knows what we will be able to accomplish or how long we will be together, Weyrich
wrote. For now, the Arlington Group is the one bright spot in the body politick. It is the group of
men and women, the leaders of the values voters, who seek to stem the tide of the culture decline
of this once great nation.
44
He said the group planned to continue working on the marriage issue, and subsequent events show
that it has, on many fronts.
For example, group members signed a letter to presidential adviser Karl Rove in January 2005,
urging President Bushs unequivocal support on the Federal Marriage Amendment. They indicated
they would have trouble encouraging their members to support Bushs controversial Social
Security privatization plan if Bush was not willing to be more vocal in his support of the marriage
amendment.
We couldnt help but notice the contrast between how the President is approaching the difficult
issue of Social Security privatization where public opinion is deeply divided and the marriage
issue where public opinion is overwhelmingly on his side. Is he prepared to spend significant
political capital on privatization but reluctant to devote the same energy to preserving traditional
marriage? the letter asked. If so, it would create outrage with countless voters who stood with

41
HRC Marriage Project, Human Rights Campaign [on-line]; available from
http://www.hrc.org/Template.cfm?Section=Center&CONTENTID=29316&TEMPLATE=/ContentManagement/Co
ntentDisplay.cfm; Internet; accessed Dec. 29, 2005.
42
Eric Gorski, Benefactors Group to Fight Effort to Ban Gay Marriage, Denver Post, Dec. 6, 2005, sec. B, p.
1.
43
Ibid.
44
Paul Weyrich, The Arlington Group, Renew America, Dec. 3, 2004 [on-line]; available from
http://www.renewamerica.us/columns/weyrich/041203; Internet; accessed Nov. 21, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 36 of 99 Pg ID 1228
The Institute on Money in State Politics 2006 23
him just a few weeks ago, including an unprecedented number of African Americans, Latinos and
Catholics who broke with tradition and supported the president solely because of this issue.
45
When the Administration adopts a defeatist attitude on an issue that is at the top of our agenda,
the letter added, it becomes impossible for us to unite our movement on an issue such as Social
Security privatization where there are already deep misgivings.
Arlington Group activity also was apparent in Kansas and Texas, where voters approved marriage
amendments in 2005.
A March 2005 article in the Kansas City Star announced an upcoming
rally planned by area clergy members and the Coalition of African-
American Pastors, to support the proposed Kansas constitutional
amendment banning same-sex marriage. The article noted that the
national leader for the effort was the Rev. William Owens, founder of
the Coalition of African-American Pastors and co-chairman of the
Arlington Group.
46
The Kansas Legislature ended up putting the amendment on the 2005
ballot, and it passed with 70 percent support. In 2004, Kansas
legislators had defeated a similar proposal for a referendum. But the
2005 Legislature approved the referendum with the help of legislators
elected in November 2004.
47
During the Kansas marriage campaign,
Focus on the Family gave at least $23,000 to the effort in support of the
amendment.
48
Texans approved a constitutional amendment defining marriage in
November 2005. Kelly Shackelford of the Plano-based Free Market
Foundation helped write the amendment and led the campaign in favor
of it.
49
Shackelford is also a member of the Arlington Group,
50
and the
Free Market Foundation is affiliated with Arlington Group member
Focus on the Family.
51
Texans for Marriage, a group promoting the amendment, published on
its Web site a variety of print ads that could be run in local newspapers.
The contact person for information about ad prices was Clint Cline of

45
Letter to Karl Rove, Marriage Amendment Project, Jan. 18, 2005 [on-line]; available from
http://www.nationalcoalition.org/Legal/Karl_Rove.pdf; Internet; accessed Nov. 21, 2005.
46
Clergy, Coalition Plan Rally Against Same-Sex Marriage, Kansas City Star, March 26, 2005, sec. E, p.12.
47
Diane Carroll, Kansans Back Gay-Marriage Ban, Kansas City Star, April 6, 2005, p.1.
48
Ibid.
49
Robert B. Garrett, Texas Votes for State Constitutional Ban on Gay Marriage, The Dallas Morning News,
Nov. 9, 2005.
50
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005.
51
About Free Market Foundation, Free Market Foundation [on-line]; available from
http://www.freemarket.org/portal/index.php?option=displaypage&Itemid=47&op=page&SubMenu=; Internet;
accessed Dec. 15, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 37 of 99 Pg ID 1229
The Institute on Money in State Politics 2006 24
Design 4;
52
Arlington Group member lists contain the name of a Clint
Cline who is associated with a company named Design 4.
53
And the effort to amend state constitutions is continuing in numerous states in 2006. Arlington
Group influence can be seen in many of these states, primarily from Focus on the Family:
In Arizona, conservative social groups began a petition drive in May
2005 to place an amendment on the November 2006 ballot. The
coalition backing the measure includes the Arizona Catholic
Conference and the Center for Arizona Policy. The center is a family
policy council listed on the Focus on the Family Web site;
54
the
centers Web site notes that these councils are independent but also
says it has been selected and endorsed by Dr. Dobson and Focus on
the Family to be the Family Policy Council for Arizona. CAP is deeply
grateful for Focus on the Familys support through the provision of
research, promotion, materials, prayers and guidance.
55
At the end of
2005, the centers director, Len Munsil, stepped down to pursue a bid
for governor in 2006.
In California, two groups launched initiative drives to put marriage
amendments on the ballot. ProtectMarriage.com was promoting an
initiative to limit marriage to a man and a woman, while
VoteYesMarriage.coms initiative would ban gay marriages, as well as
civil unions.
ProtectMarriage.com announced in December 2005 that it was
dropping its effort, having failed to obtain the needed signatures.
ProtectMarriage.com was a project of California Renewal,
56
a political
nonprofit affiliate of the California Family Council.
57
The California
Family Council serves as the statewide family policy council affiliated
with Focus on the Family.
58

52
Print Ads, Texans for Marriage [on-line]; available from www.texansformarriage.org/print_ads.htm; Internet;
accessed Nov. 21, 2005.
53
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005.
54
State Family Policy Councils, Focus on the Family [on-line]; available from http://www.family.org/cforum/fpc/;
Internet; accessed Dec. 14, 2005.
55
What is CAP?, Center for Arizona Policy [on-line]; available from http://www.azpolicy.org/html/aboutus.html;
Internet; accessed Jan. 1, 2006.
56
ProtectMarriage.com [on-line]; available from http://www.protectmarriage.com; Internet; accessed Dec. 28,
2005.
57
2005 Annual Report, California Family Council [on-line]; available from
http://www.californiafamily.org/Site/current_detail.asp?IssueID=277; Internet; accessed Jan. 1, 2006.
58
About Us, California Family Council [on-line]; available from
http://www.californiafamily.org/Site/cfc_about.asp; Internet; accessed Jan. 2, 2006.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 38 of 99 Pg ID 1230
The Institute on Money in State Politics 2006 25
VoteYesMarriage.com, meanwhile, plans to forge ahead with its
petition drive. It is currently raising money to hire professional
signature gatherers.
59
In Colorado, Focus on the Family spokesman Tom Minnery said the
group would be involved in an effort to collect signatures to place an
amendment on the Colorado ballot in 2006.
60
Minnery was listed as an
officer on all of Focus on the Familys state marriage amendment
committees in 2004.
In Florida, John Stemberger head of Florida Family Action
created a committee to place an amendment on the states ballot in
2006. Florida Family Action is the political action committee of the
Florida Family Council, an affiliate of Focus on the Family.
61
Stemberger also is listed as a member of the Arlington Group.
62
In Massachusetts, amendment supporters have been gathering
signatures to put the issue on the November 2008 ballot. The group
spearheading the drive is VoteOnMarriage.org, whose spokesman is
Kris Mineau, president of the Massachusetts Family Institute. Mineau
also is a member of the Arlington Group,
63
and the Massachusetts
Family Institute is an affiliate of Focus on the Family.
64
Larry
Cirignano of Catholicvote.org also has been active in organizing the
petition drive among Catholic Churches in Massachusetts.
65
Cirignano
is also listed as an Arlington Group member.
66
In Minnesota, the Minnesota Family Council has been backing a
marriage amendment. It also organized a November 2005 gathering of
pastors at which a Focus on the Family vice president encouraged the
ministers to have their congregations join the fight.
67
The Minnesota
Family Council is the parent organization of the Minnesota Family
Institute, a state policy council listed on the Focus on the Family Web
site.
68

59
Group Drops Bid to Ban Same-Sex Marriage, New York Times, Dec. 29, 2005, sec. A, p. 24.
60
Eric Gorski, Gay-Marriage Fight Looms, Denver Post, Feb. 11, 2005, sec. A, p. 1.
61
Who Are We?, Florida Family Policy Council [on-line]; available from
http://www.flfamily.org/welcome_letter.php?aboutid=3; Internet; accessed Jan. 1, 2006.
62
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005.
63
Ibid.
64
State Family Policy Councils, Focus on the Family [on-line]; available from http://www.family.org/cforum/fpc/;
Internet; accessed Dec. 14, 2005.
65
Michael Levenson, Petition Bid to Ban Gay Marriage Said to Gain, Boston Globe, Oct. 3, 2005, sec. A, p. 1.
66
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005.
67
Patrick Condon, Pastors Meet, Push for Gay Marriage Ban, Associated Press, Nov. 11, 2005.
68
State Family Policy Councils, Focus on the Family [on-line]; available from http://www.family.org/cforum/fpc/;
Internet; accessed Dec. 14, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 39 of 99 Pg ID 1231
The Institute on Money in State Politics 2006 26
In North Carolina, Arlington Group member Tony Perkins of the
Family Research Council and Focus on the Family Vice President Bill
Maier spoke at a May 2005 rally organized by the North Carolina
Family Policy Council and the group Called2Action, to pressure
lawmakers to put a referendum on the ballot.
69
The North Carolina
Family Policy Council is a state policy center listed on the Focus on the
Family Web site;
70
Called2Action was later asked to join the Arlington
Group.
71
In Wisconsin, the Family Research Institute of Wisconsin supported a
proposal to place a referendum on the 2006 ballot. The institute is a
Focus on the Family state policy council and, while independent,
partners with other groups, including Focus on the Family, the Family
Research Council and the Alliance Defense Fund.
72
Tony Perkins of the
Family Research Council and Alan Sears of the Alliance Defense Fund
are both Arlington Group members.
And Arlington Group members are not limiting themselves to the push on marriage.
When U.S. Supreme Court Justice Sandra Day OConnor announced in July 2005 that she would
be leaving the court, the Washington Post reported that evangelical Christian groups planned to
rouse support for a thoroughly conservative replacement by using essentially the same game
plan they used to win referendums against same-sex marriage.
73
At a nationally televised August 2005 event known as Justice Sunday IIGod Save the United
States and this Honorable Court, James Dobson of Focus on the Family urged viewers to defend
Bushs first Supreme Court nominee, John Roberts, from U.S. Sens. Edward Kennedy and Patrick
Leahy, as well as all the other minions on the left.
74
The event focused on the direction of the nations high court and was sponsored by both Focus on
the Family Action, the political arm of Focus on the Family, and the Family Research Council.
75
Tony Perkins of the Family Research Council also spoke at the event, as did Arlington Group
member Bishop Harry Jackson of Maryland, affiliated with the High Impact Leadership Coalition.
When Bush nominated longtime friend and current White House Counsel Harriet Miers to a
second vacancy on the Supreme Court, numerous conservative groups opposed the nomination.

69
Yonat Shimron and Jim Nesbitt, Rally Seeks Marriage Law Amendment, The Raleigh News & Observer,
May 11, 2005, sec. B, p. 1.
70
State Family Policy Councils, Focus on the Family [on-line]; available from http://www.family.org/cforum/fpc/;
Internet; accessed Dec. 14, 2005.
71
Yonat Shimron, A Grass-Roots Star Rises on the Right, The Raleigh News & Observer, July 10, 2005, sec.
A., p. 1.
72
About FRI, Family Research Institute of Wisconsin [on-line]; available from http://www.fri-wi.org/about.html;
Internet; accessed Jan. 1, 2006.
73
Alan Cooperman, Evangelical Groups Plan Aggressive Drive for Nominee, Washington Post, July 3, 2005,
sec. Business.
74
Jeannine F. Hunter, Justice Sunday Message: People Hold the Power, The Tennessean, Aug. 5, 2005, p.
1.
75
Ibid.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 40 of 99 Pg ID 1232
The Institute on Money in State Politics 2006 27
After she withdrew, Bushs subsequent nominee Samuel Alito drew praise from the same
groups, including those involved with the Arlington Group.
Everybody is totally on board, Weyrich said in a Nov. 1 San Francisco Chronicle article, which
also reported that the Arlington Group had held a conference call to discuss the new nominee.
76
Many of the Arlington Groups activities in 2005 involved what Focus on the Family head James
Dobson described as the battles that lie ahead: passing the Federal Marriage Amendment;
ensuring the right outcome on judicial appointments; making known the ideological beliefs of
judges who are up for election; and passing state-level marriage amendments.
77
But he also wrote in a piece on the Focus on the Family Action Web site that success on those
issues is not enough: As I continue to say, no matter how many ballot measures we pass, no
matter how many constitutional amendments we support, no matter how many God-fearing and
God-honoring women and men are elected and appointed to public office, until the hearts of the
people change, we will not turn around this culture and restore our Biblical foundations. May we
continue to collectively pray for this spirit of revival throughout America.

76
Joe Garofoli, Conservatives Delighted with Selection, San Francisco Chronicle, Nov. 1, 2005.
77
Dr. James Dobson, Looking Back, Looking Ahead, Focus on the Family Action [on-line]; available from
http://www.focusaction.org/articles/a0000050.cfm; Internet; accessed Dec. 30, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 41 of 99 Pg ID 1233
The Institute on Money in State Politics 2006 28
A R K A N S A S
Amendment 3 gained a spot on the Arkansas 2004 ballot following an initiative drive spearheaded
by the Arkansas Marriage Amendment Committee and supported by Families First, the Arkansas
Committee for Ethics Policy and Eagle Forum of Arkansas.
78
The state already had a law banning
same-sex marriages. But initiative supporters pushed for a constitutional amendment, which was
endorsed by Gov. Mike Huckabee.
Seven ballot committees in Arkansas raised nearly $338,000 for the marriage amendment
campaign, but just two committees raised the bulk of the money: the Arkansas Marriage
Amendment Committee and Families First Action Committee. Both favored defining marriage in
the state constitution. Only one group formed in opposition to Amendment 3, and it raised less
than $3,000.
A R K A N S A S C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Arkansas Marriage Amendment Committee Pro $226,051
Families First Action Committee Pro $73,374
Focus on the Family Arkansas Marriage Amendment Committee Pro $17,380
Arkansas Committee for Ethics Policy (ACEP) Pro $13,392
Traditional Marriage Crusade Pro $3,529
Arkansans for Human Rights Con $2,952
Churches in Support of Amendment 3 Pro $1,005
T O T A L $ 3 3 7 , 6 8 3
Families First Action Committee received its funds largely from Church of Christ congregations,
which gave $65,734, and some individuals. The Families First Foundation, its parent organization,
serves Church of Christ leaders and members in Arkansas as they attempt to address moral
problems that plague the family.
79
The Arkansas Committee for Ethics Policy drew two-thirds of its money from Baptist churches.
All but $300 of the money reported by Arkansans for Human Rights, the sole committee opposing
the amendment, came from contributions under the threshold amount for reporting the names of
contributors.
Arlington Group Involvement
The Arkansas Marriage Amendment Committee operated out of the same address as the Arkansas
Family Council, a group associated with Focus on the Family.
80
The committee received nearly
one-fourth of its identified funds about $55,100 from churches, including a number of
Baptist churches. It reported $56,700 as small contributions under the threshold for reporting the

78
Associated Press, Signatures Readied for Marriage Amendment, The (Memphis) Commercial Appeal, June
29, 2004, sec. B, p. 6.
79
Ministry Statement, Families First Foundation [on-line]; available from
http://www.arfamiliesfirst.org/ministry.shtml; Internet; accessed Dec. 12, 2005.
80
A Letter from Arkansas Physicians Resource Council Board Chairman, Dr. Tad Pruitt, Arkansas Family
Council [on-line]; available from http://www.familycouncil.org/aprcmission.html; Internet; accessed Oct. 11,
2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 42 of 99 Pg ID 1234
The Institute on Money in State Politics 2006 29
names of contributors. The committee spent most of its money on salaries and mailings. Three of
the committees paid staff members are also staffers for the Arkansas Family Council: Jerry Cox,
the councils executive director; Martha Adcock, the councils staff attorney; and John Thomas,
the director of the councils Arkansas Physicians Resource Council.
81
Thomas formerly served as
a marriage and family policy analyst with Focus on the Family.
82
Focus on the Family also created its own committee in Arkansas. Focus on the Family was the
only contributor to its committee, making in-kind donations of goods and services for a mailing
and air time for radio broadcasts on its affiliate radio stations in Arkansas.
Another Arlington Group member, Traditional Marriage Crusade, reported raising about $3,500,
including $1,960 it reported receiving without listing any source of contributions. It reported
spending about $1,650, including printing 10,000 fliers to encourage a favorable vote on the
amendment.
T O P C O N T R I B U T O R S I N A R K A N S A S , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Westside Church of Christ Russellville, AR Clergy Pro $20,000
Focus on the Family Colorado Springs, CO Christian Conservative Pro $17,380
Fellowship Bible Church Little Rock, AR Clergy Pro $10,000
Ligon Jr., Ed & Judy Little Rock, AR Steel Pro $10,000
Missouri Street Church of Christ West Memphis, AR Clergy Pro $9,066
Burklyn Co. Warm Springs, AR Education Pro $6,500
Fellowship Bible Church Lowell, AR Clergy Pro $6,000
Borbon, Laura C. San Antonio, TX Unknown Pro $5,000
First Baptist Church of Springdale Springdale, AR Clergy Pro $5,000
Soderquist, Don & Jo Ann Rogers, AR Commercial Banks Pro $5,000
T O T A L $ 9 3 , 9 4 6

81
Our Staff, Arkansas Family Council [on-line]; available from http://www.familycouncil.org/fcstaff.html;
Internet; accessed Oct. 11, 2005.
82
A Letter from Arkansas Physicians Resource Council Board Chairman, Dr. Tad Pruitt, Arkansas Family
Council [on-line]; available from http://www.familycouncil.org/aprcmission.html; Internet; accessed Oct. 11,
2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 43 of 99 Pg ID 1235
The Institute on Money in State Politics 2006 30
G E O R G I A
Only two ballot committees raised money in Georgia, and both supported Amendment 1, which
the Georgia Legislature placed on the November ballot as a referendum. Other groups were active
in the Georgia election,
83
but did not file campaign-finance reports. The state Christian Coalition
published its usual voter guide, while the Georgia Baptist Convention aired television ads
encouraging a vote for the amendment. Two groups opposing the amendment Georgians
Against Discrimination and Straights in Solidarity with Lesbian and Gay Civil Rights
conducted grass-roots efforts or rallies.
G E O R G I A C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Yes! Marriage Amendment Alliance Inc. Pro $75,115
Focus on the Family Georgia Marriage Amendment Committee Pro $17,650
T O T A L $ 9 2 , 7 6 5
The Yes! Marriage Amendment Alliance Inc. received nearly all its money from four major
contributors. Top individual contributor Richard Gaby operates a resort on a Caribbean island that
is privately owned by the Van Andel family, co-founders of Amway. Gaby is married to Barbara
Van Andel, daughter of Amway founder Jay Van Andel, who had traditionally given to
Republican Party committees and conservative groups before his death in late 2004.
84
Van Andel
founded Amway with Richard DeVos Sr., who along with other DeVos family members
contributed heavily to a committee supporting the same-sex marriage ban in Michigan.
Arlington Group Involvement
Arlington Group member Focus on the Family established a Georgia committee and gave it the
entire $17,650 it raised, all through in-kind contributions of goods and services, including the
costs of copying and sending a direct-mail piece.
Traditional Marriage Crusade also registered a committee with the Secretary of States Office
the first ballot committee formed on the measure but did not file any disclosure reports.
T O P C O N T R I B U T O R S I N G E O R G I A , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Capital Research Advisors Sugar Hill, GA Finance Pro $25,000
Gaby, Richard D. Duluth, GA Lodging & Tourism Pro $25,000
Focus on the Family Colorado Springs, CO Christian Conservative Pro $17,650
Reagan, Robert W. Atlanta, GA Insurance Pro $12,500
Stipe, Kevin M. Alpharetta, GA Insurance Pro $12,500
T O T A L $ 9 2 , 6 5 0

83
Sonji Jacobs, New Ads Encourage Voters to Ban Same-Sex Marriages, The Atlanta Journal-Constitution,
Oct. 28, 2004, sec. C, p. 1.
84
Denise Roth Barber, Declining Fortunes: State Party Finances, 2004, Institute on Money in State Politics,
September 2005, p. 11.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 44 of 99 Pg ID 1236
The Institute on Money in State Politics 2006 31
K E N T U C K Y
After weeks of divisive debate, the Kentucky Legislature passed a referendum putting the
amendment question on the ballot in November 2004. Seven committees formed in the subsequent
campaign on Amendment 1. Six committees worked to support the measure, while one formed in
opposition. The single committee opposing the measure, Kentucky Families for Fairness, raised
more than all the other committees combined, but the amendment still passed resoundingly.
K E N T U C K Y C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Kentucky Families for Fairness Con $522,864
Vote Yes for Marriage Committee Pro $135,493
Yes for Traditional Marriage Pro $41,308
Laurel County Citizens for KY Constitutional Amendment Pro $13,191
Focus on the Family Kentucky Marriage Amendment Committee Pro $7,449
Committee for the Defense of Traditional Marriage Pro $1,950
Traditional Marriage Crusade Pro $1,740
T O T A L $ 7 2 3 , 9 9 5
Kentucky Families for Fairness reported nearly $523,000 in contributions more than twice the
$201,130 that committees promoting the measure reported raising. Nearly one-half its money, or
about $157,700, came from organizations and individuals supporting gay and lesbian rights. About
half of the funds from gay- and lesbian-rights advocates came from out of state, while half came
from contributors within the state. Key Kentucky contributors were the Fairness Campaign, a gay-
and lesbian-rights group that helped organize Kentucky Families for Fairness, and its founder,
Carla Wallace. Wallace, whose father was heir to a pharmaceutical fortune,
85
gave $43,754, while
the Fairness Campaign gave $17,000.
Other contributors to Families for Fairness had ties to the gay and lesbian community. Carla
Wallaces family members gave a combined total of at least $38,175. And the Stinson-Lewis-
Stinson Pride Foundation, a nonprofit that supports the arts and humanities,
86
gave $40,000; the
foundation is run by Ed Lewis and George Stinson, who operate a club for gay men.
The top individual contributor favoring the amendment, Hal Heiner, is a real estate developer and
a Republican member of the Louisville Metro Council. He gave $20,000 to the Vote Yes for
Marriage Committee.
National Gay- and Lesbian-Rights Giving
National organizations, or individuals with ties to them, gave slightly less than $77,000 to the
Kentucky amendment fight. Most of the money came from the National Gay and Lesbian Task
Force, which gave $73,000, and its employees or board members, who gave an additional $2,600.

85
Henry Wallace: (Part 2), Louisville Magazine [on-line]: cached version available from
http://72.14.207.104/search?q=cache:iF70sJGvBmQJ:www.louisville.com/loumag/nov/henry2.htm+%22Henry+
Wallace%22+smith+beecham+kline&hl=en&ie=UTF-8; Internet; accessed Jan. 13, 2006.
86
Tamara Ikenberg, Cross-Dress for Success, The Courier-Journal, July 29, 2005 [newspaper on-line];
available from http://www.courier-
journal.com/apps/pbcs.dll/article?Date=20050729&Category=FEATURES&ArtNo=507290306&SectionCat=&Te
mplate=printart; Internet; accessed Dec. 28, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 45 of 99 Pg ID 1237
The Institute on Money in State Politics 2006 32
Arlington Group Involvement
Arlington Group members were active in a variety of ways, supporting the legislation that placed
the measure on the ballot, organizing rallies at the Capitol during key points in legislative
debates,
87
forming committees and contributing substantially to the effort to pass Amendment 1.
Kent Ostrander, executive director of the Family Foundation of Kentucky, not only organized
much of the support for the legislation placing Amendment 1 on the ballot, but also was an officer
of the Vote Yes for Marriage Committee. The Family Foundation of Kentucky, listed as a state
policy council on the Focus on the Family Web site,
88
gave $19,660 in in-kind contributions to the
Vote Yes for Marriage Committee. Its parent organization, The Family Trust Foundation of
Kentucky, gave another $14,395, also as in-kind donations of goods or services. And three Family
Foundation employees gave a combined $1,200.
Focus on the Family established a Kentucky committee and reported raising $7,449 in in-kind
contributions; it did not report any expenditures.
The Yes for Traditional Marriage Committee was associated with the American Family
Association of Kentucky,
89
an affiliate of the American Family Association,
90
an Arlington Group
member. The American Family Association of Kentucky gave by far the largest amount of
itemized contributions to this committee about $29,350 of the $41,300 it raised. The committee
reported only $2,800 in itemized contributions from other sources.
In addition, American Family Radio gave $1,200 to the Vote Yes for Marriage Committee; the
radio network is a division of the American Family Association.
T O P C O N T R I B U T O R S I N K E N T U C K Y , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
National Gay & Lesbian Task Force Washington, DC Gay & Lesbian Rights Con $73,000
Wallace, Carla Louisville, KY Gay & Lesbian Rights Con $43,754
Stinson-Lewis-Stinson Pride Foundation Louisville, KY Nonprofit Institutions Con $40,000
American Family Association of Kentucky Louisville, KY Christian Conservative Pro $29,344
Kentucky Campaigns Louisville, KY Business Services Pro $25,000
Heiner, Hal Louisville, KY Republican Officials Pro $20,000
The Family Foundation of Kentucky Lexington, KY Christian Conservative Pro $19,664
Fairness Campaign Louisville, KY Gay & Lesbian Rights Con $17,000
Family Trust Foundation of Kentucky Lexington, KY Christian Conservative Pro $14,395
DeVries, Sonja Prospect, KY TV & Movie Production Con $10,000
Southland Christian Church Lexington, KY Clergy Pro $10,000
Wallace, Henry Prospect, KY Agriculture Con $10,000
T O T A L $ 3 1 2 , 1 5 7

87
Bruce Schreiner, Foundation a Force in Push for Gay Marriage Ban, Lexington Herald-Leader, April 11,
2004, sec. B, p. 1.
88
State Family Policy Councils, Focus on the Family [on-line]; available from http://www.family.org/cforum/fpc/;
Internet; accessed Dec. 14, 2005.
89
Sarah Vos, Marriage Amendment Donations Listed, Lexington Herald-Leader, Oct. 12, 2004, sec. B, p. 1.
90
AFA State Affiliates: State Directors, American Family Association [on-line]; available from
http://www.afa.net/affiliates/kentucky.asp; Internet; accessed Dec. 30, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 46 of 99 Pg ID 1238
The Institute on Money in State Politics 2006 33
L O U I S I A N A
Louisianas Amendment 1 was placed on the ballot by the state Legislature. It drew support from
four ballot committees, three of which reported raising money. A fifth committee, Forum for
Equality, was the only group opposing the amendment. It raised $23,500, or about 35 percent of
the money that all committees reported raising.
L O U I S I A N A C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Forum for Equality Con $23,547
Louisiana Citizens for the Defense of Marriage Inc. Pro $22,750
Louisiana Family Forum Pro $14,824
Traditional Marriage Crusade Pro $5,542
Focus on the Family Louisiana Marriage Amendment Committee Pro $0
T O T A L $ 6 6 , 6 6 3
About one third-of the Forum for Equalitys funds came from lawyers or law firms, while another
$5,000 came from Club New Orleans, a club for gay men.
Louisiana Citizens for the Defense of Marriage received nearly half of its contributions from New
Orleans developer Joseph Canizaro and his wife, Sue Ellen. Republican state Rep. Steve Scalise,
who sponsored the legislation placing the referendum on the ballot, served as treasurer of this
committee.
Top contributor Craig Hubbard gave $8,000 to the Louisiana Family Forum. Hubbard is chief
financial officer of SPC Pool Corp., a wholesale distributor for the pool and spa industry.
Arlington Group Involvement
Arlington Group member Focus on the Family established a committee but reported no
contributions. It did report spending $3,910: about $2, 900 for copying and postage for a mailing
and slightly more than $1,000 on radio broadcasts for its affiliate radio stations in Louisiana.
The Louisiana Family Forum was the only ballot committee to report money from churches,
raising nearly $4,500 of its $14,824 from churches. According to the Family Forums Web site, it
maintains a close working relationship with Focus on the Family and the Family Research
Council,
91
also an Arlington Group member. Almost 81 percent of the Family Forums
expenditures went to its political action committee to buy ads. The group spent another $5,614 on
yard signs.
Traditional Marriage Crusade also formed a committee in Louisiana; most of its money came from
out-of-state donors and was used to print letters, as well as 15,000 fliers and 25,000 inserts
supporting the amendment.

91
Louisiana Family Forum & Its Associations, Louisiana Family Forum [on-line]; available from
http://www.lafamilyforum.org/; Internet; accessed Dec. 4, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 47 of 99 Pg ID 1239
The Institute on Money in State Politics 2006 34
T O P C O N T R I B U T O R S I N L O U I S I A N A , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Hubbard, Craig Folsom, LA Wholesale Trade Pro $8,000
Canizaro, Joseph C. New Orleans, LA Real Estate Pro $5,000
Canizaro, Sue Ellen New Orleans, LA Real Estate Pro $5,000
Club New Orleans New Orleans, LA Business Services Con $5,000
Evans & Clesi New Orleans, LA Lawyers & Lobbyists Con $3,750
Best & Koeppel New Orleans, LA Lawyers & Lobbyists Con $2,500
Benedon, Debora Manalapan, NJ Unknown Pro $2,000
Friends of Steve Scalise Elmwood, LA Candidate Committee Pro $2,000
Walk, Frank H. New Orleans, LA Construction Services Pro $2,000
Gillis, Charles W. New Orleans, LA Business Services Con $1,200
T O T A L $ 3 6 , 4 5 0

2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 48 of 99 Pg ID 1240
The Institute on Money in State Politics 2006 35
M I C H I G A N
Proposal 2 was placed on Michigans ballot by citizen petition after the Michigan Legislature
failed to approve a referendum. The heated battle over Proposal 2 in this presidential battleground
state drew $2.8 million into eight ballot committees, only one of which opposed the amendment.
Several contributors were members of the Arlington Group, and some of the biggest payments
went to businesses with strong GOP ties.
M I C H I G A N C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Citizens for the Protection of Marriage Pro $1,626,582
Coalition for a Fair Michigan Con $854,212
Family Research Council Inc. Pro $186,397
Focus on the Family Michigan Marriage Amendment Committee Pro $73,649
Oakland Citizens to Protect Marriage Pro $27,397
Michigan Citizens Voting Yes for Marriage Pro $7,000
Traditional Marriage Crusade Pro $4,906
Marriage in the Public Interest Committee Pro $4,500
T O T A L $ 2 , 7 8 4 , 6 4 3
Citizens for the Protection of Marriage raised the most among all committees, nearly $1.63 million
or 58 percent of the money raised by all committees. The group was heavily financed by the
Catholic Church. Seven Catholic dioceses gave an even $1 million, or 61 percent of the
committees total. The church coordinated an effort in support of Proposal 2 through the Michigan
Catholic Conference, the public policy arm of the states seven dioceses; Cardinal Adam Maida
urged the states Catholics to vote in favor of the amendment in an eight-minute videotape that
was distributed to Michigan parishes, along with suggestions for points to make in sermons and
other materials on issues related to the amendment.
92
The top individual contributor was Elsa Prince Broekhuizen, who gave $75,000 to Citizens for the
Protection of Marriage. Broekuizen is the mother of Betsy Devos, who was serving as chairman of
the Michigan Republican Party in 2004. Betsy DeVos is married to Dick DeVos, currently a
Republican candidate for governor of Michigan. Dick DeVos father is Amway co-founder
Richard DeVos Sr., who gave $20,000 to the committee. Two other DeVos family members gave
a combined $30,000.
In addition, Elsa Prince Broekhuizen was a member of the board of directors of the
Family Research Council.
93
In fact, her late husband, Edgar Prince, was a co-founder of
the group.
94

92
Robert Delaney, Cd. Maida: Vote Yes for Prop. 2, The Michigan Catholic, Oct. 7, 2004 [on-line]; available
from http://www.aodonline.org/AODOnline/Archives+177/Michigan+Catholic+-+More+News+10-08-2004.htm;
Internet; accessed Nov. 10, 2005.
93
List of Officers, Directors, Trustees and Key Employees, IRS Form 990, Evangelical Council for Financial
Accountability [on-line]; available from http://files.ecfa.org/assoc/00000083.pdf; Internet; accessed Jan. 3, 2006.
The form covered the tax year beginning Oct. 1, 2003, and ending Sept. 30, 2004.
94
Allison Connolly, Blackwaters Best-Kept Secret: Its Founder, Virginian Pilot-Ledger, May 3, 2004, sec. A, p.
1.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 49 of 99 Pg ID 1241
The Institute on Money in State Politics 2006 36
Citizens for the Protection of Marriage paid the Sterling Corp. slightly more than $1 million. This
company provides campaign consulting services, primarily to Republican clients. Former Sterling
Vice President Jeff Timmer left the company in February 2005 to become executive director of the
Michigan Republican Party.
95
The committee also paid about $110,000 to Public Opinion Strategies, which bills itself as a
Republican polling firm.
96
Its Web site notes that it polled for both Citizens for the Protection of
Marriage and the Ohio Republican Party on the marriage amendment. Marlene Elwell, who
headed the committee, received nearly $69,000, while a firm at the same address, Elwell
Consulting, received another $66,200. Elwell also is founder of Catholics in the Public Square,
which describes itself as a group of Catholics who want to share the beauty and richness of this
Faith in the public arena through all venues available to us.
97
The sole committee opposing the amendment, Coalition for a Fair Michigan, raised $854,200, or
30 percent of the funds raised for the ballot fight. The largest segment of its itemized funds came
from individuals and organizations supporting gay and lesbian rights $286,625.
However, much of the committees money remains unitemized, exemplifying a problem typical of
ballot measure committees. The coalition did not file detailed information about contributors on its
required periodic reports.
98
The state has notified the committee that it needs to file amended
reports; a spokeswoman at the state office said those letters were returned as undeliverable. Phone
numbers for the committee have been disconnected, as is often the case with short-lived political
committees formed for one specific purpose.
National Gay- and Lesbian-Rights Giving
By far the largest portion of the itemized contributions reported by the Coalition for a Fair
Michigan came from the national Human Rights Campaign. The Washington, D.C.-based
organization gave $231,081, or 42 percent of the $543,950 of contributions for which the
committee provided the names of contributors. The National Gay and Lesbian Task Force gave
another $13,000.
Arlington Group Involvement
Five Arlington Group members were active in the Michigan effort:
The Family Research Council gave Citizens for the Protection of
Marriage $190,000. The council is headed by Tony Perkins, a key
leader of the Arlington Group. The Family Research Council also
established its own ballot committee in Michigan, and gave it $186,397
all the money the committee reported raising. Nearly all of this

95
Timmer Heads to Michigan Republican Party, The Sterling Corporation , Feb. 25, 2005 [on-line]; available
from http://www.sterlingcorporation.com/news/default.aspx?cid=18; Internet; accessed Dec. 7, 2005.
96
Research: Political Campaigns, Public Opinion Strategies [on-line]; available from
http://www.pos.org/research/political.cfm; Internet; accessed Sept. 14, 2005.
97
CPS Overview, Catholics in the Public Square [on-line]; available from
http://www.catholicsinthepublicsquare.org/aboutus_history.html; accessed Jan. 4, 2006.
98
The Institute was able to obtain some of the missing information from the 24-hour reports the committee was
required to file when it raised contributions of $200 or more from a single contributor in the two-week period
before the election; however, the committee reported raising another $310,262 but provided no detailed
information on the contributors.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 50 of 99 Pg ID 1242
The Institute on Money in State Politics 2006 37
money was reported as going to the Citizens for Protection of Marriage
to support the amendment.
Because the amount raised by the Family Research Council committee
and the amount the Citizens for the Protection of Marriage reported
receiving from the Family Research Council are so similar, it is
possible that the disclosure reports involve the same pool of money.
Also, as noted earlier, top contributor Elsa Prince Broekhuizen also was
listed as a member of the Family Research Council board of directors
for the tax year ending Sept. 30, 2004.
Focus on the Family was active in two different ways. It established its
own committee in Michigan, giving through in-kind contributions all of
the $73,650 the committee raised. In addition, the Michigan Family
Forum, a state policy center listed on the Focus on the Family Web
site,
99
gave $63,386 to Citizens for the Protection of Marriage. And the
Public Interest Forum, an offshoot of the Michigan Family Forum, gave
$19,500 $15,000 to Citizens for the Protection of Marriage and
$4,500 to the Marriage in the Public Interest Committee. This latter
committee shares the same address as the Michigan Family Forum and
the Public Interest Forum, and its treasurer was Brad Snavely,
executive director of the Michigan Family Forum.
100
The American Family Association, headed by Arlington Group
member the Rev. Don Wildmon, provided nearly all of the money for
Michigan Citizens Voting Yes for Marriage $5,000 of $7,000. In
addition, Gary Glenn of the American Family Association of Michigan,
an Arlington Group member himself,
101
co-authored the amendment.
102
Byron Voorheis III, a real estate developer, loaned Citizens for the
Protection of Marriage $20,000 a few weeks after it formed in March
2004 and contributed another $2,000 in November. The committee
repaid him $20,000 in July 2004. Voorheis name is on Arlington
Group member lists, which identify him as Michigan chairman of
Social Conservatives Bush-Cheney 04.
103
Traditional Marriage Crusade established a committee in Michigan and
reported raising slightly less than $5,000, with most of it coming from

99
State Family Policy Councils, Focus on the Family [on-line]; available from http://www.family.org/cforum/fpc/;
Internet; accessed Dec. 14, 2005.
100
Committee Statement of Organization, Department of State [on-line]; available from
http://miboecfr.nicusa.com/cgi-bin/cfr/com_det.cgi?com_id=512395; Internet; accessed Dec. 28, 2005.
101
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005.
102
AFAMI News, American Family Association of Michigan [on-line]; available from
http://www.afamichigan.org/category/marriage/: Internet: accessed Jan. 16, 2006.
103
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 51 of 99 Pg ID 1243
The Institute on Money in State Politics 2006 38
out-of-state contributors. It paid approximately $2,300 for a newspaper
advertisement and gave its parent organization, The Foundation for a
Christian Civilization, $849 in leftover funds.
T O P N O N - I N D I V I D U A L C O N T R I B U T O R S I N M I C H I G A N , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Archdiocese of Detroit Detroit, MI Clergy Pro $538,100
Family Research Council Washington, DC Christian Conservative Pro $376,397
Human Rights Campaign Washington, DC Gay & Lesbian Rights Con $231,081
Diocese of Lansing Lansing, MI Clergy Pro $133,350
Diocese of Grand Rapids Grand Rapids, MI Clergy Pro $106,100
Diocese of Saginaw Saginaw, MI Clergy Pro $87,500
Focus on the Family Colorado Springs, CO Christian Conservative Pro $73,649
Michigan Family Forum Lansing, MI Christian Conservative Pro $68,386
Diocese of Gaylord Gaylord, MI Clergy Pro $49,250
Diocese of Kalamazoo Kalamazoo, MI Clergy Pro $47,450
T O T A L $ 1 , 7 1 1 , 2 6 3
T O P I N D I V I D U A L C O N T R I B U T O R S I N M I C H I G A N , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Broekhuizen, Elsa Prince Holland, MI Securities & Investment Pro $75,000
Lee, William Saginaw, MI Computer Services Pro $35,500
Gilmour, Allan Birmingham, MI Automotive Con $25,000
DeVos Sr., Richard M. Grand Rapids, MI Amway/Alticor Pro $20,000
Dewan, Michael Putnam, MI Retired Pro $20,000
Stryker, Jon Kalamazoo, MI Construction Services Con $20,000
DeVos, Douglas L. Grand Rapids, MI Amway/Alticor Pro $15,000
DeVos, Maria P. Grand Rapids, MI Amway/Alticor Pro $15,000
Katz, Nancy Plymouth, MI Laywers & Lobbyists Con $15,000
Blumenstein, Richard Bloomfield Hills, MI Real Estate Con $11,000
T O T A L $ 2 5 1 , 5 0 0
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 52 of 99 Pg ID 1244
The Institute on Money in State Politics 2006 39
M I S S I S S I P P I
Amendment 1 in Mississippi placed on the ballot by the Legislature drew little money. Only
two committees formed, both created by groups with headquarters outside of the state and
affiliated with the Arlington Group. They reported contributions of only $7,200.
M I S S I S S I P P I C O N T R I B U T I O N S B Y B A L L O T C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Focus on the Family Mississippi Marriage Amendment Committee Pro $5,266
Traditional Marriage Crusade Pro $1,949
T O T A L $ 7 , 2 1 5
Arlington Group Involvement
Focus on the Family created a Mississippi committee, providing all of the committees funds
through in-kind contributions of goods and services. The committee did not report any
expenditures.
Traditional Marriage Crusade reported contributions of $1,949. More than half $1,000 came
from Anthony Lomangino of Hobe Sound, Florida, owner of Southern Waste Systems and
Recycling. The committee also reported $749 in small contributions, made in amounts below the
threshold for reporting the names of contributors. It spent $550 on printing fliers and envelopes,
and spent another $615 on unitemized expenses.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 53 of 99 Pg ID 1245
The Institute on Money in State Politics 2006 40
M I S S O U R I
Missouris Amendment 2 won resoundingly at the polls, with 71 percent of the vote despite the
fact that supporters raised a mere fraction of the amount the opponents raised. Supporters of the
amendment raised just $29,600, compared with the approximately $488,000 opponents raised.
Although a handful of other states had enacted constitutional amendments defining marriage
before 2004, Missouri was the first state to vote on the issue after the Massachusetts Supreme
Judicial Court decision allowing same-sex marriages. The Legislature placed the measure on the
Aug. 3 ballot, in what was widely viewed as a nationwide test of the issue.
M I S S O U R I C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Constitution Defense League Con $488,189
Coalition to Protect Marriage in Missouri Pro $21,499
Missourians for Marriage Pro $8,113
T O T A L $ 5 1 7 , 8 0 1
The committee formed to oppose the amendment, the Constitution Defense League, raised 94
percent of the funds reported by ballot committees, as national gay- and lesbian-rights groups
poured money into this first ballot-measure fight. Doug Gray, one of the top contributors to the
committee, also served as its campaign manager, with $7,500 of his nearly $9,300 in contributions
reported as in-kind donations of services or goods.
The Coalition to Protect Marriage in Missouri received the largest amount of its money from
churches. And within that category, Baptist churches gave the most: $3,610 of the $6,785 in
church funds.
Opponents used their campaign dollars to mount an advertising blitz, spending $293,500 on
television and print advertising. Supporters of the amendments turned to churches to get the word
out, using phone lists developed from church rosters, offering downloadable inserts for church
bulletins on a Web site, and urging ministers to preach in support of the amendment.
104
National Gay- and Lesbian-Rights Giving
National groups supporting gay and lesbian rights gave $133,250 of the funds raised by the
Constitution Defense League, or 27 percent of the committees total. The Human Rights
Campaign alone put in $111,750. The National Gay and Lesbian Task Force added $20,500 to the
campaign, while the National Center for Lesbian Rights gave $1,000.
The table on the following page shows the top contributors in Missouri.

104
Matthew Franck, Grass-Roots Battle Heats Up, St. Louis Post-Dispatch, July 28, 2004, sec. B, p. 1.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 54 of 99 Pg ID 1246
The Institute on Money in State Politics 2006 41
T O P C O N T R I B U T O R S I N M I S S O U R I , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Human Rights Campaign Washington, DC Gay & Lesbian Rights Con $111,750
National Gay & Lesbian Task Force Washington, DC Gay & Lesbian Rights Con $20,500
ACLU of Eastern Missouri St. Louis, MO Ideology/Single Issue Con $11,500
Simon, Ray M. St. Louis, MO Construction Services Con $10,000
Gray, Doug Kansas City, MO Business Services Con $9,289
Committee for Fairness Kansas City, MO Gay & Lesbian Rights Con $8,414
Tivoli Building LLC St. Louis, MO Real Estate Con $8,400
Pilkenton, Jill St. Louis, MO Retail Sales Con $7,026
Fischer, M. Peter St. Louis, MO Lawyers & Lobbyists Con $5,000
Wells, Doug Kansas City, MO Business Services Con $5,000
T O T A L $ 1 9 6 , 8 7 9
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 55 of 99 Pg ID 1247
The Institute on Money in State Politics 2006 42
M O N T A N A
Opponents to Montanas Constitutional Initiative 96, placed on the ballot by citizen petition,
outraised supporters but lost at the ballot box. Montanans for Families and Fairness raised
$51,500, while two committees supporting the measure raised less than one-fourth of that amount.
M O N T A N A C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Montanans for Families and Fairness/Against CI-96 Con $51,498
Montanans for Marriage/For CI-96 Pro $8,676
Focus on the Family Montana Marriage Amendment Committee Pro $2,194
T O T A L $ 6 2 , 3 6 8
National Gay- and Lesbian-Rights Giving
The National Gay & Lesbian Task Force gave $10,000 to Montanans for Families and Fairness, or
37 percent of the contributions the committee received from individuals and organizations
supporting gay rights and 19 percent of its total contributions. The Seattle-based Pride Foundation,
which supports the gay and lesbian community in the Pacific Northwest, gave $1,000.
Arlington Group Involvement
Arlington Group member Focus on the Family established a committee in Montana and gave it
$2,194 through in-kind contributions. It reported no expenditures.
Montanans for Marriage received 78 percent of its funds $6,765 as in-kind contributions
from the Montana Family Foundation, which is associated with Focus on the Family.
105
The
foundations president, Republican state Rep. Jeff Laszloffy, authored the ballot petition and acted
as a spokesman.
106
He also served as treasurer for the Focus on the Family Montana Marriage
Amendment Committee. In addition, a Voter Information Pamphlet statement from proponents
directed readers to the Family Foundations Web site for more information.
107
T O P C O N T R I B U T O R S I N M O N T A N A , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Pride Inc. Helena, MT Gay & Lesbian Rights Con $15,067
National Gay & Lesbian Task Force Washington, DC Gay & Lesbian Rights Con $10,000
Montana Family Foundation Laurel, MT Christian Conservative Pro $6,765
Montana Human Rights Network Helena, MT Human Rights Con $3,959
Stranahan, Mary Arlee, MT Health Professionals Con $3,000
Focus on the Family Colorado Springs, CO Christian Conservative Pro $2,194
Milton, Maxwell Helena, MT Investor Con $1,000
The Pride Foundation Seattle, WA Gay & Lesbian Rights Con $1,000
T O T A L $ 4 2 , 9 8 5

105
Montana Family Foundation [on-line]; available from http://www.montanafamily.org; Internet; accessed Dec. 4, 2005.
106
Success! CI-96 Qualifies, Montana Family Action [on-line]; available from
www.mtfamilyaction.com/index.asp?file=form; Internet; accessed Dec. 8, 2005.
107
Proponents Rebuttal of Argument Against CI-96, 2004 Voter Information Pamphlet, Montana Secretary of
States Office, October 2004, p. 28.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 56 of 99 Pg ID 1248
The Institute on Money in State Politics 2006 43
N O R T H D A K O T A
North Dakotas Measure 1 was placed on the ballot through the initiative process. It drew
relatively little in the way of campaign contributions, but passed with 73 percent of the vote.
The group opposing Measure 1, Equality North Dakota, raised $8,974. The North Dakota Human
Rights Coalition gave almost half of the committees $4,150 in itemized contributions, at $2,000;
the remainder of itemized contributions came from a handful of individuals. In addition, the
committee raised another $4,824 in contributions that, individually, fell below the $100 threshold
for reporting the names of contributors and the specific amounts they gave.
N O R T H D A K O T A C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Equality North Dakota Con $8,974
Traditional Marriage Crusade Pro $0
T O T A L $ 8 , 9 7 4
Arlington Group Involvement
Traditional Marriage Crusade established a North Dakota committee, but reported no
contributions. It reported only one $35 unitemized expense.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 57 of 99 Pg ID 1249
The Institute on Money in State Politics 2006 44
O H I O
The pitched battle over Issue 1 in a battleground presidential state involved not only large amounts
of out-of-state money, but also a paid signature-gathering drive, court challenges, a split among
state officials on the amendment, and a complaint over disclosure of the proponents finances.
Groups supporting the amendment raised about $1.2 million, outpacing the one committee that
opposed the measure. Ohioans Protecting the Constitution/Ohians for Fairness, the committee
opposing Issue 1, raised about $942,500, with 58 percent of the money coming from supporters of
gay and lesbian rights. Two other big contributors to the anti-amendment effort were Abigail
Wexner, whose husband owns The Limited clothing chain, and Nationwide Insurance Co. These
Ohio-based companies had opposed the amendment, along with Ohioans for Growth & Equality, a
statewide group that promotes business growth in Ohio by advocating for equality under the law
for all of its citizens.
108
And it appears that the Ohio Republican Party did some work on the marriage issue, although it
did not make any direct contributions to any of the ballot committees. Public Opinion Strategies, a
Republican polling firm, listed the Ohio Republican Party as a client for which it did polling work
in favor of the Ohio marriage question.
109
The party reported paying Public Opinion Strategies
$221,500 for polling and another $18,750 for consulting work in 2004, but did not have to specify
the candidates or issues that the work covered.
O H I O C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Ohio Campaign to Protect Marriage Pro $1,194,808
Ohioans Protecting the Constitution/Ohians for Fairness Con $942,421
Traditional Marriage Crusade Pro $7,953
T O T A L $ 2 , 1 4 5 , 1 8 2
National Gay- and Lesbian-Rights Giving
The Human Rights Campaign was the only national gay- and lesbian-rights group to contribute to
Ohioans Protecting the Constitution. It gave $384,000, representing about 70 percent of the
$547,100 given by gay-rights contributors. In addition, Bruce Bastian of Utah contributed $25,000
to the committee, while James Hormel of San Francisco gave $5,000. Hormel, whose grandfather
founded the Hormel Meat Co., was the first openly gay person to be appointed U.S. ambassador to
a foreign country, Luxembourg.
Arlington Group Involvement
Two Arlington Group members had high-profile roles in the Ohio amendment, while another
formed a committee in support and a fourth contributed funds.

108
Frequently Asked Questions, Ohioans for Growth & Equality [on-line]; available from
http://www.ohioansforgrowth.org/; Internet; accessed Oct. 5, 2005.
109
In the News: Initiatives & Referendums, Public Opinion Strategies [on-line]; available from
http://www.pos.org/research/init_record.cfm; Internet; accessed Sept. 14, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 58 of 99 Pg ID 1250
The Institute on Money in State Politics 2006 45
Phil Burress of Citizens for Community Values led the push to gather
signatures and also served as chairman of the Ohio Campaign to Protect
Marriage, the primary committee supporting the amendment.
Ohio Secretary of State J. Kenneth Blackwell an honorary co-
chairman of President Bushs Ohio re-election campaign
110
came out
in support and did radio ads in favor of the amendment. Blackwell also
sent a letter to 1,500 state GOP members in August 2004 saying that
gay marriage would be important in determining where Ohios
electoral votes will go.
111
The Traditional Marriage Crusade formed a ballot committee, raising
slightly less than $8,000.
Focus on the Family contributed slightly more than $1,000 in radio air
time to the Ohio Campaign to Protect Marriage.
Burress heads up Citizens for Community Values, a state organization officially associated with
Arlington Group member Focus on the Family;
112
Burress also is listed in his own right as being
an Arlington Group member.
113
His groups political action arm, Citizens for Community Values
Action, was the largest contributor to the Ohio Campaign to Protect Marriage, giving $1.18
million of the $1.19 million that the pro-amendment group reported raising. Because Citizens for
Community Values Action is a political action committee and was not formed specifically for the
ballot campaign, it did not have to report its contributors. Thus the sources of the funds it gave to
the Ohio Campaign to Protect Marriage are unknown. Two Cincinnati lawyers and others filed a
complaint in October 2005 against Citizens for Community Values, contending it concealed the
source of the funds its PAC gave to the ballot committee.
114
The commission is expected to hear
the complaint in early 2006.
Citizens for Community Values Action also paid to have professional signature-gatherers collect
signatures for the ballot petitions;
115
again, these expenses were not reported because they were not
paid by committees formed specifically to campaign on the ballot measure.
The Ohio Campaign to Protect Marriage received only $11,520 that did not come from either
Citizens for Community Values Action, Focus on the Family or Phil Burress. The remainder came
from individuals giving amounts generally ranging anywhere from $5 to $350, with only three
contributors giving more than that amount and none giving more than $2,000.
Blackwells role in the pro-amendment campaign was well documented, although his participation
in the Arlington Group appeared far less well known. Blackwells name appears on lists of

110
William Hershey, Blackwells Tenure May Be Last of Kind, Dayton Daily News, Nov. 1, 2005, sec. B, p. 1.
111
Gregory Korte, Marriage Question Seen as Boon to Bush, Cincinnati Enquirer, Sept. 14, 2004, p. 1.
112
Citizens for Community Values [on-line]; available from http://www.ccv.org; Internet; accessed on Dec. 15,
2005.
113
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005.
114
Jon Craig and Gregory Korte, CCV, Others Hid Funding, Complaint Says, Cincinnati Enquirer, Oct. 27,
2005, P. 2
115
April Yee, Paid Recruits Fight Gay Marriage, Cincinnati Post, July 24, 2004 [newspaper on-line]; available
from http://www.cincypost.com/2004/07/24/pet072404.html; accessed Oct. 18, 2005
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 59 of 99 Pg ID 1251
The Institute on Money in State Politics 2006 46
Arlington Group members, as affiliated with the American Center for Civic Character.
116
That
centers Web site promotes its trademarked UncommonSense materials, described as a
conscience-affirming character ethics framework designed by and for leading adults to
contemplate, apply in their lives, adopt within their work teams and easily commend to those
around them.
117
Blackwells name is not found on the centers Web site, but a link to the trademarked
UncommonSense materials went to Blackwells Secretary of State Web site. The link no longer
works, but does give an error message showing Blackwells state site. And the Secretary of States
Web site does contain the UncommonSense material, under a section named Ohio Center for Civic
Character, described as a collaborative, statewide project for leaders of all types to build character.
An Ohio newspaper described the Ohio center as a project that elicits pledges of moral character
from candidates for public office.
118
The Traditional Marriage Crusade brought less than $8,000 into the costly battle, with half of that
amount $4,000 reported in a lump sum with no indication of the source of the funds. Most
of the rest of the money came from outside of Ohio. The committee spent $4,000 on unitemized
expenses, as well as additional funds on printing. It gave about $480 in excess funds to its parent
group, The Foundation for a Christian Civilization.
T O P C O N T R I B U T O R S I N O H I O , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Citizens for Community Values Action Cincinnati, OH Christian Conservative Pro $1,182,139
Human Rights Campaign Washington, DC Gay & Lesbian Rights Con $384,145
Maltz, David Beachwood, OH Gay & Lesbian Rights Con $101,383
Bastian, Bruce W. Orem, UT Gay & Lesbian Rights Con $25,000
Nationwide Mutual Insurance Columbus, OH Insurance Con $20,000
Ohioans For Growth & Equality Columbus, OH Gay & Lesbian Rights Con $20,000
Springer, Gerald N. Chicago, IL TV & Movie Production Con $20,000
Wexner, Abigail S. Hudson, OH Retail Sales Con $20,000
Forest City Enterprises Inc. Cleveland, OH Real Estate Con $15,000
Wolfe Enterprises Inc. Columbus, OH Printing & Publishing Con $15,000
T O T A L $ 1 , 8 0 2 , 6 6 7

116
Arlington Group Members, American Policy Roundtable [on-line]; available from
http://www.ohioroundtable.org/untangling/arlington_Group.html; Internet; accessed Nov. 21, 2005.
117
Our Uncommon Message, The American Center for Civic Character [on-line]; available from
http://centralohiobbb-counties.org/characterusa/about.php; Internet; accessed Nov. 30, 2005.
118
Julie Carr Smyth, Ken Blackwell Ohios Man at the Center of the National Election Storm, Cleveland Plain
Dealer, Oct. 24, 2004, sec. A, p. 1.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 60 of 99 Pg ID 1252
The Institute on Money in State Politics 2006 47
O K L A H O M A
Oklahomas campaign on Question 711 was low cost, with opponents of the amendment raising
slightly more than half the amount the proponents did.
O K L A H O M A C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Oklahomans for the Protection of Marriage Pro $20,293
Protecting Oklahoma Families Fund Con $11,616
Traditional Marriage Crusade Pro $1,350
T O T A L $ 3 3 , 2 5 9
Oklahomans for the Protection of Marriage, headed by Republican state Sen. James Williamson,
reported raising $20,293. Of that, $19,000 came as contributions from a committee of the same
name and $600 came from Williamson, who had sponsored the legislation that placed Question
711 on the ballot. The groups Web site included a sample sermon and a list of individuals who
had given their support to the amendment.
119
The Web site did not indicate, however, whether the
individuals had contributed financially to the committee.
The Protecting Oklahoma Families Fund received three-quarters of its money $8,816 from
Cimarron Equality Oklahoma and its chairman, Terry Gatewood. Cimarron advocates for gay and
lesbian rights.
The amendment passed with 76 percent of the vote and also played out in the Oklahoma U.S.
Senate race, where Democratic U.S. Rep. Brad Carson challenged Republican Tom Coburn, a
former congressman. Carson was one of eight Democrats considered to be in highly competitive
Senate campaigns.
120
Coburn received assistance in his campaign from Arlington Group members. He also was listed as
a member of the board of directors of the Family Research Council, an Arlington Group
member.
121
Arlington Group Involvement
The Traditional Marriage Crusade established a committee in Oklahoma, and a group headed by
another Arlington Group member conservative activist Gary Bauer ran ads against Carson.
The Traditional Marriage Crusade received nearly all of its money from its parent organization,
The Foundation for a Christian Civilization. It spent its funds on printing and distributing fliers
and a direct mail piece.
Well into the campaign, Bauers Americans United to Preserve Marriage ran ads against Carson
and several other Democratic Senate candidates. The ad against Carson suggested he might

119
Oklahomans to Protect Marriage [on-line]: available from http://www.okprotectmarriage.govreach.com;
Internet; accessed Oct. 17, 2005.
120
Andrea Stone, Democrats Know Battle for Senate is on GOP Turf, USA Today, Aug. 26, 2004.
121
List of Officers, Directors, Trustees and Key Employees, IRS Form 990, Evangelical Council for Financial
Accountability [on-line]; available from http://files.ecfa.org/assoc/00000083.pdf; Internet; accessed Jan. 3, 2006.
The form covered the tax year beginning Oct. 1, 2003, and ending Sept. 30, 2004.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 61 of 99 Pg ID 1253
The Institute on Money in State Politics 2006 48
someday be open to gay rights arguments.
122
Carson, however, had publicly supported the
proposed Federal Marriage Amendment, and then-Human Rights Campaign Executive Director
Cheryl Jacques said Carson did not have a record of supporting gay rights.
123
Meanwhile, the Americans United to Preserve Marriage Web site singled Carson out among
Senate candidates, with a home page section entitled Brad Carson: A Risk to Your Values
124
that
displayed a video questioning Carsons commitment to faith-based groups and suggesting he
supported gay partnerships. The Carson section was below two others on the Web sites home
page: one was entitled John Kerry: Too Liberal for America and another encouraged viewers to
Help Protect Marriage Re-Elect George W. Bush.
T O P C O N T R I B U T O R S I N O K L A H O M A , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Oklahomans for the Protection of Marriage Tulsa, OK Christian Conservative Pro $19,000
Cimarron Equality Oklahoma Oklahoma City, OK Gay & Lesbian Rights Con $6,300
Gatewood, Terry L. Oklahoma City, OK Gay & Lesbian Rights Con $2,516
Foundation for a Christian Civilization Spring Grove, PA Christian Conservative Pro $1,295
Prater, Larry Oklahoma City, OK Health Professionals Con $1,000
T O T A L $ 3 0 , 1 1 1

122
David D. Kirkpatrick, The 2004 Campaign: Gays; Marriage Between Gays Becomes Issue in Campaigns,
The New York Times, Oct. 30, 2004, sec. A, p. 16.
123
Ibid.
124
Americans United to Preserve Marriage [on-line]; available from http://www.americansformarriage.org/;
Internet; accessed Nov. 29, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 62 of 99 Pg ID 1254
The Institute on Money in State Politics 2006 49
O R E G O N
Measure 36 was placed on the ballot following a successful initiative drive generally attributed to
four Oregon ministers.
125
It spurred high emotions and heavy giving from not only Oregonians, but
groups and individuals around the country. Four committees raised slightly less than $5.4 million,
with the bulk of the money going to the No on Constitutional Amendment 36 committee and the
Defense of Marriage Coalition PAC.
Although Oregon was seen by many as the state most likely to reject the marriage amendment, 57
percent of the voters supported it. However, that margin of victory was the smallest for any of the
13 amendments that came to a public vote in 2004.
O R E G O N C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
No on Constitutional Amendment 36 Con $2,928,380
Defense of Marriage Coalition PAC Pro $2,414,438
Oregon Right to Life Issues PAC Pro $20,015
Religious Response Network Con $5,618
T O T A L $ 5 , 3 6 8 , 4 5 1
The primary committee opposing the measure, No on Constitutional Amendment 36, raised nearly
$3 million, garnering strong financial support from national and state gay- and lesbian-rights
groups. Forty-eight percent of its funds, or about $1.4 million, came from organizations and
individuals supporting gay and lesbian rights. It raised another quarter of a million dollars from
contributions that were below the limit for reporting the names of contributors.
The main committee supporting the amendment, the Defense of Marriage Coalition, was an
offshoot of the Oregon Family Council and reported the largest segment of its contributions as
coming from small donations under the threshold for reporting the names and occupations of the
contributors nearly $530,000. Christian Copyright Licensing, which collects use fees for the
owners of copyrighted church music and videos, gave $410,000. Gateway Communications, an
advertising firm whose head Tim Nashif served as political director of the Defense of
Marriage Coalition, gave another $120,400, but also received $130,684 in payments from the
coalition.
Church-related contributors to the Defense of Marriage Coalition outside of Christian
Copyright Licensing gave $276,800, led by Rolling Hills Community Church at $46,200,
Mount Olivet Baptist Church at $20,000, and the City Bible Church at $16,105.
Many contributors to the committee had ties in one way or another to the City Bible Church,
which operates two campuses in the Portland area:
The churchs senior pastor, Frank Damazio, was one of the leaders of
the petition effort,
126
along with Tim Nashif. Nashif, who is listed as a

125
Steve Law, Pastors Step from Pulpit into Public Fight over Gay Marriage, Statesman-Journal, April 16,
2004 [newspaper on-line]; available from http://news.statesmanjournal.com/article.cfm?i=78740; Internet;
accessed Dec. 29, 2005.
126
Ibid.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 63 of 99 Pg ID 1255
The Institute on Money in State Politics 2006 50
district pastor on the churchs Web site, is also a co-founder and
political director of the Oregon Family Council. The Defense of
Marriage Coalition was a business name of the Family Council.
127
The committees largest contributor, Christian Copyright Licensing, is
owned by Howard Rachinski, who is listed as an executive pastor on
the Churchs Web site. The business gave $200,000 on Aug. 5, another
$200,000 on Sept. 22 and $10,000 on Oct. 2. Rachinski contributed
another $5,000 of his own money on Oct. 13.
Several contributors with the same names as ministers listed on the
City Bible Church Web site gave a total of about $32,000, including the
$5,000 from Rachinski and $1,000 from Nashif. Both gave on Oct. 13;
in fact, $11,725 of the $32,025 from these contributors came in to the
committee on either Oct. 12 or Oct. 13.
City Bible Church sponsors a ministry it calls Business with a Purpose,
which encourages Christian business owners, professionals &
managers to use their talents, success and influence in the marketplace
as their ministry for the kingdom of God.
128
Individuals and businesses
listed on the Web site as participants in Business with a Purpose gave
an additional $17,500 to support the amendment.
The Defense of Marriage Coalition paid the City Bible Church $332 for
an expense listed as reimbursement of employee health.
Focus on the Family founder James Dobson, a key Arlington Group
member, met with Nashif and Damazio when he spoke to pastors in
Portland.
129
The two also were among a small group of people Dobson
singled out for praise after the November election.
130
All told, the committee raised $475,653, or nearly 20 percent of its total funds, from individuals
and businesses with apparent ties to City Bible Church.
National Gay- and Lesbian-Rights Giving
No on Constitutional Amendment 36 received about one-third of its contributions from three
national gay- and lesbian-rights groups. The National Gay and Lesbian Task Force contributed
nearly $663,000, while the Human Rights Campaign gave about $313,000. The Log Cabin
Republicans gave $40,000, making Oregon the only state in which it contributed to a ballot-
measure fight in 2004.

127
Ibid.
128
Our Vision, Business With a Purpose [on-line]; available from
http://www.businesswithapurpose.org/_vision.html; Internet; accessed Nov. 4, 2005.
129
Dr. James Dobson, Marriage Under Fire, excerpt, Focus on the Family [on-line]; available from
http://www.family.org/docstudy/bookshelf/a0032438.cfm; Internet; accessed Dec. 30, 2005.
130
Dr. James Dobson, Looking Back, Looking Ahead, Focus on the Family Action [on-line]; available from
http://www.focusaction.org/articles/a0000050.cfm; Internet; accessed Dec. 30, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 64 of 99 Pg ID 1256
The Institute on Money in State Politics 2006 51
In addition, the Horizons Foundation of San Francisco gave $10,000. The foundation supports
programs and services for the gay and lesbian community, as well as efforts to advance their
rights.
131
The committee also received $150,000 from Tim Gill of Colorado. Gill founded the
software company Quark, and his Gill Foundation supports gay and lesbian rights. WordPerfect
co-founder Bruce Bastian of Utah gave $27,500 to fight the Oregon amendment, and gay-rights
activist James Hormel of San Francisco gave $5,000.
Arlington Group Involvement
Focus on the Family contributed to the Defense of Marriage Coalition, despite initially saying it
saw no need to become involved in the effort on Amendment 36.
132
The organization gave
$138,364 to the Oregon committee, ranking as its second-largest contributor; $110,000 was given
in direct contributions, while the remainder was given as in-kind services or goods.
As noted above, Focus on the Family founder James Dobson also spoke to Oregon ministers in
April 2004.
Focus on the Family also organized an Oregon Marriage Amendment Committee, filing its
statement of organization with the Secretary of States office on Aug. 30. However, the group
discontinued its activity on Oct. 15 and filed no reports.
133
T O P N O N - I N D I V I D U A L C O N T R I B U T O R S I N O R E G O N , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
National Gay & Lesbian Task Force Washington, DC Gay & Lesbian Rights Con $662,858
Christian Copyright Licensing Inc. Portland, OR Clergy Pro $410,000
Human Rights Campaign Washington, DC Gay & Lesbian Rights Con $312,778
Basic Rights Oregon Portland, OR Gay & Lesbian Rights Con $184,243
Focus on the Family Colorado Springs, CO Christian Conservative Pro $138,364
Gateway Communications Portland, OR Business Services Pro $120,439
Christian Values Fund Muscatine, IA Unknown Pro $50,000
Rolling Hills Community Church Tualatin, OR Clergy Pro $46,200
Planned Parenthood Portland, OR Health Services Con $43,000
Log Cabin Republicans Washington, DC Gay & Lesbian Rights Con $40,000
T O T A L $ 2 , 0 0 7 , 8 2 2

131
About Us, Horizons Foundation [on-line]; available from http://www.horizonsfoundation.org/page/aboutus;
Internet; accessed Dec. 29, 2005
132
Bill Graves, National Gay Rights Groups Fight Measure, The Oregonian, Sept. 1, 2004, sec. C, p. 10.
133
Campaign Finance Activity, Focus on the Family Marriage Amendment Committee, Oregon Secretary of
State [on-line]; available from
http://egov.sos.state.or.us/elec/!pkg_el_web_ce_cmitee_query.p_ce_reports_query; Internet: accessed Dec.
30, 2005.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 65 of 99 Pg ID 1257
The Institute on Money in State Politics 2006 52
T O P I N D I V I D U A L C O N T R I B U T O R S I N O R E G O N , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Gill, Tim Denver, CO Gay & Lesbian Rights Con $150,000
Nedelisky, Neil West Linn, OR Real Estate Pro $101,000
Wilson, Robert W. Brooklyn, NY Investor Con $100,000
Bastian, Bruce W. Orem, UT Gay & Lesbian Rights Con $27,500
Lewis, Jonathan Coral Gables. FL Real Etate Con $25,000
Templeton, John Bryn Mawr, PA Christian Conservative Pro $25,000
Bisenius, James Sherwood, OR Securities & Investment Pro $22,000
Bobosky, Robert S. (Bob) Portland, OR Investor Pro $15,000
Zidell, Jason E. Portland, OR Real Estate Con $11,500
Scheidler, Steve Portland, OR Electronics Manufacturing/ Services Pro $11,000
T O T A L $ 4 8 8 , 0 0 0
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 66 of 99 Pg ID 1258
The Institute on Money in State Politics 2006 53
U T A H
Amendment 3 in conservative, Republican-dominated Utah won, but with a smaller margin of
victory than in many other states. Sixty-six percent of the voters supported the ban, which was
placed on the ballot by the Utah Legislature.
The measure drew a surprising amount of money, considering many political observers believed
its passage was a given. Ballot committees here raised $1.3 million, ranking Utah fourth among
the 13 states. The four committees supporting the amendment raised slightly less than $507,000,
or about two-thirds of the nearly $781,000 that the opponents raised
U T A H C O N T R I B U T I O N S B Y C O M M I T T E E , 2 0 0 4
B A L L O T C O M M I T T E E P R O / C O N T O T A L
Dont Amend Alliance Con $773,186
Utahns for a Better Tommorrow Pro $354,113
The Constitutional Defense of Marriage Alliance Pro $131,354
Yes for Marriage Pro $20,813
Utah Lawyers for Sound Constitutional Amendments Con $7,554
Traditional Marriage Crusade Pro $643
T O T A L $ 1 , 2 8 7 , 6 6 3
The main committee opposing the ban, the Dont Amend Alliance, raised 62 percent of its funds
from contributors supporting gay- and lesbian-rights. Most of the money came from Bruce Bastian
and his Bruce W. Bastian Foundation. Bastian, a Utah resident and gay-rights activist, co-founded
WordPerfect software. He gave $125,500 to the Dont Amend Alliance, while his foundation gave
$239,000.
More than one-third of the $131,350 raised by one committee in favor, the Constitutional Defense
of Marriage Committee, came from several developers who gave a combined $50,000. Two
Republican state legislators who served as co-chairmen of the committee gave another $23,300;
Sen. Chris Buttars contributed about $20,250, while Rep. F. Lavar Christensen gave $3,000.
Buttars had sponsored legislation to define marriage in the law and declare same-sex unions
performed in other states void in Utah. Christensen had sponsored the resolution that placed the
constitutional amendment on the ballot.
Another committee supporting the marriage amendment, Utahns for a Better Tomorrow, received
about half of its $354,000 from a group called Marriage Education Initiatives. The source of those
funds has remained under question; Marriage Education Initiatives formed as a nonprofit
corporation on Oct. 18, the same day it gave a $50,000 contribution to the ballot committee.
134
Scott McCoy, campaign manager of the Dont Amend committee, filed a complaint with the Utah
Attorney Generals office alleging that Marriage Education Initiatives was formed to circumvent
state campaign-finance laws and hide the donors to Utahns for a Better Tomorrow. The complaint
is under review.

134
Rebecca Walsh, Mystery Donor Backing Yes on 3, Salt Lake Tribune, Oct. 29, 2004, sec. B.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 67 of 99 Pg ID 1259
The Institute on Money in State Politics 2006 54
National Gay- and Lesbian-Rights Giving
Three national groups gave a combined total of $65,000 in Utah. The national Human Rights
Campaign kicked in $50,0000, while the National Gay and Lesbian Task Force gave $10,000 and
the National Center for Lesbian Rights gave $5,000.
The contributions represented less than 10 percent of the total funds that the Dont Amend
Alliance raised and about 14 percent of the total it received from organizations and individuals
supporting gay- and lesbian-rights.
Arlington Group Involvement
The Traditional Marriage Crusade created a Utah ballot committee. All of its contributions came
from its parent organization, The Foundation for a Christian Civilization, as in-kind contributions
to cover printing and postage expenses.
T O P N O N - I N D I V I D U A L C O N T R I B U T O R S I N U T A H , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Bruce W. Bastian Foundation Orem, UT Gay & Lesbian Rights Con $239,000
AK Holding Co. Provo, UT Finance/Insurance/Real Estate Pro $175,000
Marriage Education Initiatives Salt Lake City, UT Ideology/Single Issue Pro $171,000
Human Rights Campaign Washington, DC Gay & Lesbian Rights Con $50,000
Equality Utah Salt Lake City, UT Gay & Lesbian Rights Con $17,500
National Gay & Lesbian Task Force Washington, DC Gay & Lesbian Rights Con $10,000
SJ Fox Ridge LLC Lehi, UT Real Estate Pro $10,000
VS Fox Ridge LLC Lehi, UT Real Estate Pro $10,000
Willow Cove Apartments South Jordan, UT Real Estate Pro $10,000
Jackie Biskupski Campaign Salt Lake City, UT Candidate Committee Con $9,000
T O T A L $ 7 1 6 , 6 0 0
T O P I N D I V I D U A L C O N T R I B U T O R S I N U T A H , 2 0 0 4
C O N T R I B U T O R L O C A T I O N I N D U S T R Y P R O / C O N T O T A L
Bastian, Bruce W. Orem, UT Gay & Lesbian Rights Con $125,500
Marquardt, Jane A. Salt Lake City, UT Lawyers & Lobbyists Con $47,670
Marquardt, Robert Ogden, UT General Business Con $22,000
Buttars, D. Chris West Jordan, UT Republican Official Pro $20,269
Matheson, Frank Salt Lake City, UT Gay & Lesbian Rights Con $12,440
Heap, Ted Lehi, UT Real Estate Pro $10,000
Jaffa, Scott Park City, UT Construction Services Con $10,000
Sandlin, Julie L. Draper, UT Real Estate Pro $10,000
Solomon, Elizabeth Park City, UT Gay & Lesbian Rights Con $10,000
Roylance, Susan Salt Lake City, UT Christian Conservative Pro $6,750
T O T A L $ 2 7 4 , 6 2 9
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 68 of 99 Pg ID 1260
The Institute on Money in State Politics 2006 55
A P P E N D I X A
A R L I N G T O N G R O U P M E M B E R S
The following people were listed as Arlington Group members on the Ohio Roundtable Web site
and on a Jan. 18, 2005, letter to presidential adviser Karl Rove that was attributed to the group.
N A M E O R G A N I Z A T I O N
Dr. James Dobson Focus on the Family
Paul M. Weyrich Free Congress Foundation
Rich Bott Bott Radio Network
Rod Parsley Center for Moral Clarity
Janet Folger Faith2Action
Donald E. Wildmon American Family Association
Stuart Epperson Salem Communications Corporation
Tony Perkins Family Research Council
Gary Bauer American Values
Kenneth Hutchenson Mayday for Marriage
Bishop Harry R. Jackson High Impact Leadership Coalition
Alan Chambers Exodus International
Dick Bott Sr. Bott Radio Network
Carl D. Herbster Advance USA
Dr. Bill Maier Focus on the Family
Rick Scarborough Vision America
Keith Wiebe American Association of Christian Schools
Leo Godzich National Association of Marriage Enhancement
Ron Crews Massachusetts Coalition for Marriage
Samuel Casey Christian Legal Society
Colin A. Hanna Let Freedom Ring Inc.
Byron Voorheis III Michigan Chairman, Social Conservatives Bush-Cheney '04
Gary Glenn* American Family Association of Michigan
Randy Thomas Exodus International
Kelly Shackleford* Free Market Foundation
Rev. William Owens Coalition of African-American Pastors
Phil Burress* Citizens for Community Values
Dr. S. Dale Burroughs Biblical Heritage Institute
Clint Cline Design 4
Larry Cirignano* Catholicvote.org
C. Preston Noell Tradition, Family, Property
Rev. Ted Haggard National Association of Christian Evangelicals
Stephen M. Crampton American Family Association Center for Law and Policy
Warren Kelley National Center for Freedom & Renewal
Rev. Derek A. McCoy High Impact Leadership Coalition
Dan Panetti National Coalition for the Protection of Children and Families
Kristian M. Mineau* Massachusetts Family Institute
John Stemberger* Florida Family Policy Council Inc.
Al Laws Jr. WIN Family Services Inc.
Diane Gramley American Family Association of Pennsylvania
Matthew D. Staver Liberty Counsel
Mark Benz Men for Nations
Robert E. Reccord North American Mission Board
Alan E. Sears Alliance Defense Fund (for identification purposes only)
Richard D. Land Ethics & Religious Liberty Commission
Frank Wright National Religious Broadcasters
J. Kenneth Blackwell** American Center for Civic Character
* Involved in state-level amendment efforts
**Also serves as Ohios secretary of state
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 69 of 99 Pg ID 1261
The Institute on Money in State Politics 2006 56
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 70 of 99 Pg ID 1262
ATTACHMENT R

2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 71 of 99 Pg ID 1263








Working Paper No. 32


Turning On and Turning Out: Assessing
the Individual-Level Effects of Ballot
Measures


By
Todd Donovan and Daniel A. Smith







USC Law School
and
California I nstitute of Technology
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 72 of 99 Pg ID 1264
Turning On and Turning Out:
Assessing the Individual-Level Effects of Ballot Measures
Todd Donovan
Western Washington University
donovan@cc.wwu.edu
Daniel A. Smith
University of Florida
dasmith@polisci.ufl.edu
Abstract:
Studies have demonstrated that state ballot initiatives are associated with higher voter
turnout, however existing research has not examined which voters are mobilized by
initiatives. We test whether, 1) initiatives mobilize people who do not fit the profile of
regular voters, and 2) whether initiatives activate people who resemble regular voters.
We use individual-level survey data from three states to test hypotheses related to these
propositions. Partisan identifiers, strong partisans, ideologues, older voters, and the well
educated were more likely to say that their turnout was motivated by a ballot measure. In
contrast, we find no evidence that initiatives motivated young voters, independents, or
ideological moderates to turnout. Our findings illustrate how initiatives may alter the
composition of an electorate, and illustrate the potential effects of partisan efforts to
shape the composition of a states electorate.
Prepared for Delivery at the 4th Annual State Politics and Policy Conference,
April 30-May 1, 2004, Kent State University, OH.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 73 of 99 Pg ID 1265
1
Turning On and Turning Out:
Assessing the Individual-Level Effects of Ballot Measures
Introduction
Following the dramatic rise in the number of citizen initiatives appearing on
statewide ballots in the 1990s, scholars began to assess the possible educative effects of
citizen lawmaking (Smith and Tolbert 2004). Indeed, a number of recent studies show
that there might be some merit to the idea that the process of direct democracy itself has
indirect behavioral and attitudinal effects that increase the likelihood of citizens
becoming more engaged with politics (Mendelsohn and Cutler 2000; Bowler and
Donovan 2002).
On the behavioral side, comparisons of citizens living in states that use initiatives
frequently and those that do not demonstrate that initiatives are associated with increased
voter turnout, particularly in off-year elections. Smith (2001) and Tolbert, Grummel and
Smith (2001) both use aggregate level data to establish that state ballot initiatives have a
positive effect on voter turnout, controlling for a range of other factors. Merging
National Election Studies (NES) survey data with state-level figures of the number of
initiatives on the statewide ballot in a given election, Tolbert, McNeal and Smith (2003)
further find that ballot initiatives are mildly effective in stimulating turnout in midterm
elections and in non-competitive, low-interest presidential elections. The crudeness of
the NES survey data, however, does not allow them to test hypotheses about what types
of initiatives might mobilize which voters. As for attitudinal effects, the presence of
highly visible initiatives on a state ballot is associated with higher levels of general
knowledge about politics (Smith 2002; Tolbert, McNeal, and Smith 2003). Additional
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 74 of 99 Pg ID 1266
2
research has found that citizens in states with frequent initiative use feel more competent
when participating in politics, are more likely to think that they have a say, and are
more likely to think that officials care about what they think (Mendelsohn and Cutler
2000; Bowler and Donovan 2002; Hero and Tolbert 2003; Benz and Stutzer 2004).
Given the modest substantive effects on turnout estimated by models using both
aggregate and survey data, we do not expect to find that a majority of people are
motivated to vote in an election due to the presence of ballot measures, even highly
salient ones. These studies do suggest, though, that initiatives can increase turnout in an
election by several percent. Unfortunately, at the micro-level, political scientists have yet
to address the possible effects of ballot initiatives on an individuals propensity to turn
out to vote. Which citizens are mobilized by what types of initiatives? In this paper we
seek to answer this question, as well as to establish if voters who are mobilized by
initiatives tend to come to vote in support or opposition of the measures. Using data from
recent surveys conducted in three high-use initiative states that were designed specifically
to answer these questions, we offer a preliminary assessment of the effect of initiatives on
voter turnout at the micro-level.
Answers to these questions have important political ramifications. With the soft
money spigot closed for the national and some state parties, party officials are
increasingly viewing initiative campaigns as a possible indirect means to increase the
turnout for their candidates (Garrett 2004; Garrett and Smith 2003). For example, in
Oklahoma in 2002, a successful ballot initiative that banned cockfighting mobilized rural
citizens who were opposed the measure; those same voters simultaneously opposed the
Republican gubernatorial candidate (which ran contrary to their conservative
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 75 of 99 Pg ID 1267
3
inclinations) because he endorsed the cockfighting ban, calling cockfighting a barbaric
practice (Cobb 2004). Similarly, in anticipation of the 2004 general election, the
Democratic National Committee and several 527 political organizations and nonprofit
organizations have started to subvent an effort in Florida by ACORN, a liberal nonprofit
grassroots organization, to place a constitutional amendment initiative on the November
ballot to increase the minimum wage. Their collective aim is twofold: to turn out less
educated, working class, liberals, who are typically non-voters, in support of the
minimum wage measure on its substantive merits, and to have these infrequent voters
simultaneously cast ballots for Democratic candidates (Erickson 2003).
Theorizing about why Initiatives may Affect Turnout
Who is likely to be mobilized to vote by the presence of state ballot initiatives?
We expect that effects on turnout of having initiatives on a states ballot should depend
on the individual, and on the ballot issue. We offer two, rival theoretical perspectives.
First, we might expect that initiatives generally mobilize people who are not
regular voters. There are several reasons to expect this. First, the dealignment literature
(e.g., Wattenberg 1996; Wattenberg 2002; Patterson 2002) suggests that over the last two
decades a block of floating voters has emerged that lacks an attachment to the two
major political parties. These independent-leaning voters are more likely to be mobilized
episodically by third party candidacies (Bowler, Donovan, Karp and Lanoue 2004).
Indeed, much of the decline in turnout in recent decades may be attributed to the failure
of political parties to mobilize these citizens (Rosenstone and Hansen 1993; Abramson,
Aldrich, and Rohde 1998; Jackson, Brown, and Wright 1998), especially younger, less
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 76 of 99 Pg ID 1268
4
educated ones. The same logic, perhaps, applies to ballot measures. It may be no
coincidence that previous studies examining the impact of ballot initiatives on turnout in
the 1960s and 1970s (Everson 1981; Magleby 1984) failed to find a positive relationship.
At that time, the initiative was not used nearly as frequently as it is today (Tolbert 2003;
Waters 2003; Tolbert, Lowenstein, and Donovan 1998), and a larger proportion of voters
were engaged with parties, and thus, more regularly mobilized.
Related to the dealignment thesis, the literature on post-materialist values
(Inglehart 1977; Dalton 2003) suggests that there may be a class of educated citizens who
lack established partisan loyalties, and are less regularly mobilized by candidate
elections. These voters concerns about policy issues rather than candidates may lead
them to vote more often when there are important issues on a states ballot. This
literature stresses that young, well-educated citizens are most likely to place a high value
on direct participation in policy-making via direct democracy (Dalton, Buklin and
Drummond 2001; but see Craig, Kreppel, and Kane 2002). While the information costs
associated with voting on initiatives are likely higher for these potential voters than for
those with stronger partisan attachments, recent studies suggest that the presence of easily
available cues and information short-cuts allow minimally informed voters to initially
become aware of ballot propositions (Magleby 1984; Bowler and Donovan 1994;
Nicholson 2003), and then have the capacity to use cues to make reasonable decisions on
measures that sometimes deal with complex policy choices (Magleby 1984; Lupia 1994;
Gerber and Lupia 1995; Banducci 1998; Karp 1998; Bowler and Donovan 1998).
There is a second, rival perspective about who might likely be mobilized by ballot
initiatives. The substance of many state ballot questions may reflect hard issue voting,
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 77 of 99 Pg ID 1269
5
where it may be difficult for people to calculate the policy benefits of alternative choices
(Downs 1957; Carmines and Stimson 1980). If we assume that voting on initiatives is
analogous to hard issue voting, and that it requires a certain pre-existing level of political
engagement, we might expect that initiatives tend to mobilize people who resemble
regular voters (rather than activate citizens resembling episodic voters). Following the
Michigan model of voting (e.g., Converse, et al. 1960; Flannigan and Zingale 2003;
Green, Palmquist and Schickler 2002), partisan identifiers are expected to have more
interest in political issues than people who fail to identify with parties. Well-educated
people, and people who view politics through ideological perspectives, can be expected
to vote more on the basis of their reasoning about issues (Sniderman, et al. 1991).
Moreover, there is mounting evidence that political parties are becoming engaged in
crafting initiatives not for their substantive merits, but because they expect the measures
will touch a nerve with their supporters, or conversely, drive a wedge into the base of a
rival political party (Smith and Tolbert 2001). Some parties work from the assumption
that they can strategically utilize initiatives to shape an electorate to their advantage
(Chavez 1998; Schrag 1998; Hasen 2000). Indeed, there is the possibility of considerable
electoral payoff for parties when they become involved in ballot campaigns, as party
identification is a major factor in a voters support or opposition of ballot measures
(Donovan and Snipp 1994; Bowler and Donovan 1998; Smith and Tolbert 2001; Branton
2003). Finally, there is evidence that during initiative campaigns for measures targeting
minorities, shifts in affect toward a targeted group is limited to voters who identify with
the party that sponsors the initiative (Wenzel, Donovan and Bowler 1998).
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 78 of 99 Pg ID 1270
6
Alternative Hypotheses
If the partisan activation thesis is correct, and initiatives largely mobilize citizens
who resemble regular, partisan voters, then the independent effects of having more
education and being more ideological should be positively associated with respondents
saying that ballot measures were the main reason they turned out to vote. In contrast, if
the dealignment/post-materialism thesis is correct, and initiatives largely mobilize
episodic voters, respondents who are politically independent should be more likely than
partisans to say they turned out to vote because of ballot initiatives. More precisely,
younger, less-educated citizens who lack partisan ties should have a greater propensity to
say they turned out because propositions were on the ballot.
Descriptive Data
Of course, at the micro-level, scholars have not yet established that ballot
initiatives actually motivate citizens to turn out to vote. Fortunately, in order to test the
possible impact of ballot initiatives on voter turnout, we were able to obtain individual
level survey data from three state-level surveys that were designed in part to answer this
question.
1
We analyze post-election data from two surveys conducted immediately
following the 2002 general electionone poll conducted in Colorado by Lake Snell
Perry and Associates, and the other conducted in Oregon by Penn, Schoen & Berland and
Associates. We also analyze data from a statewide survey conducted in Arizona in May
2003 by Lake Snell Perry and Associates. These three statesArizona, Colorado, and

1
The three surveys were commissioned by the Ballot Initiative Strategy Center (BISC), a nonprofit
organization based in Washington, DC. Smith assisted in conceiving and designing the relevant ballot
initiative/motivation questions asked on the surveys. We thank Kristina Wilfore, Executive Director of
BISC, for both providing and permitting us to analyze data from the three surveys.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 79 of 99 Pg ID 1271
7
Oregonrank among the top five in terms of their historical use of the initiative since the
Progressive Era (Tolbert, Lowenstein, and Donovan 1998; Waters 2003; Tolbert 2003).
The Colorado and Oregon surveys were designed to ascertain whether voters support or
opposition to specific ballot measures this election motivated them to turn out. The
Arizona survey was not conducted in sync with a state election, but instead asked
respondents to think retrospectively whether there had ever been a proposition on the
ballot that was so important that, it alone got you out to the polls.
The electoral context of each state presents citizens with a different mix of ballot
issues and different campaign dynamics. In Colorado in 2002, there was a hotly
contested US Senate race as well as 10 questions on the general election ballot (five
initiatives and five referendums). The ballot questions included a high-profile anti-
bilingual education initiative sponsored by an out-of-state millionaire, four additional
initiatives related to the conduct of elections, and five arcane obscure legislative
referrals.
2
In Oregon in November 2002, voters reelected Republican US Senator Gordon
Smith, elected Democrat Ted Kulongoski to the governors mansion, and voted on a
dozen statewide ballot measures. The twelve questions included five legislative

2
The anti-bilingual education measure (Amendment 31) was by far the highest profile and the most
expensive campaign. The author of the proposed constitutional amendment, California businessman Ron
Unz, self-financed the measure with loans and contributions exceeding half a million dollars. In their
successful efforts to defeat the initiative, opponents spent more than $3.3 million ($3.1 of which came from
the contributions of a single individual, heiress Pat Stryker) to defeat the initiative. Another millionaire,
Coloradoan Jared Polis, single-handedly financed Amendment 30, an unsuccessful initiative calling for
election-day registration. Featuring ads of Colorado Broncos star running back, Terrell Davis, Polis spent
over $1 million to advance his measure; opponents spent less than a tenth that amount to help defeat the
measure. Geophysicist Rutt Bridges, yet another local millionaire, contributed more than 99% of the $1.5
million raised to promote Amendments 28 (vote by mail) and 29 (eliminate the party caucus system).
Opponents spent less than $100,000 to defeat the two measures. Interestingly, the amount spent and the
attendant media attention that focused on Colorado Common Causes campaign finance initiative
(Amendment 27)the only initiative of the five to passwas significantly less than the other four
initiatives; proponents spent roughly $200,000, about 10 times more than their opponents spent (Smith
2003; FCPA 2002).
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 80 of 99 Pg ID 1272
8
referendums and seven initiatives, which ranged in subject matter from a judicial
accountability act to easing the regulation of denturists. Most of the initiatives and
referendums had minimal campaign spending activity, with the big money concentrated
on three initiatives: establishing a universal health care system (Measure 23), raising the
minimum wage in the state (Measure 25), and requiring labels on genetically modified
(GMO) foods (Measure 27). In all three campaigns, the opponents spent considerably
more than the proponents of the measures.
3
With respect to the Arizona retrospective survey, the immediate electoral context
was not as relevant to the survey, as it was conducted in May 2003. When asked an
open-ended question about ballot measures they could recall that were extremely
important, few respondents could offer a specific proposition number, and a plurality
could not recall a specific policy issue. Topics from the most recent Arizona general
election (November 2002) conducted prior to the survey were the most frequently cited,
including gaming (18%) and education, broadly defined (11%). A few respondents
recalled older matters such as medical marijuana (4%), the Cardinals football stadium
issue (3%), and an English-only initiative (1%). Less than 3% of Arizona respondents
mentioned anything having to do with taxes in their retrospective evaluations of
initiatives that in the past had mobilized them to vote.
[Table 1 about here]

3
In the minimum wage campaign, which narrowly passed, the backers of the measure were outspent 2-1 by
a coalition of grocery chains, restaurants, and yard care industries that spent more than $546,000 against the
proposal. Agribusinesses (Cargill, ADM, and especially Monsanto), grocery chains, and the bio-tech
industry spent more than $5.5 million to defeat the GMO proposal, swamping the proponents $92,000.
And on the universal healthcare measure, which also went down to a resounding defeat, proponents and
opponents spent more than $1.4 million combined (BISC 2002; Orr 2004).
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 81 of 99 Pg ID 1273
9
Results in Table 1 demonstrate that in each state, a sizable proportion of voters
indicated that their reason to vote (or for having voted in the past) was very or even
exclusively motivated by the presence of ballot measures on their states ballot. Over a
quarter (28.4%) of Arizona respondents indicated a ballot measure was the singular
reason they had voted in a past election. A similar proportion of Colorado respondents
(24.9%) indicated measures on the 2002 ballot were extremely or very motivating
that they alone got them to vote. In Oregon, slightly under a third of the respondents said
that measures on the 2002 ballot were very motivating, providing them with enough
incentive to vote in the November election.
Do Initiatives Mobilize Opponents or Supporters?
In Table 2 we separate the samples of the three surveys into two subgroups:
respondents who reported that initiatives mobilized them to turn out to vote; and
respondents who reported that they were not motivated to vote by ballot initiatives. This
division allows us to determine whether specific initiatives (in Colorado and Oregon) and
initiatives in the abstract (in Arizona) mobilize supporters or opponents of propositions.
If initiatives generally mobilize those who support the measures, groups attempting to use
initiatives to shape strategically an electorate may face little risk. If, however, ballot
initiatives are likely to mobilize those who are opposed to the measures, there are
substantial risks for the proponents (and the parties and candidates who support them) if
their (indirect) purpose is to custom tailor the electorate.
[Table 2 about here]
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 82 of 99 Pg ID 1274
10
Table 2 illustrates that propositions on the ballot may at times help shape the
composition of a states electorate by mobilizing voters who are sympathetic to the
issues. In Colorado, for instance, respondents who claimed that ballot initiatives in 2002
brought them to the polls were more likely to vote for the measures, compared to voters
who said they were not mobilized to turn out by initiatives. Overall, among Colorado
respondents who said they were mobilized by initiatives, there is considerable net support
for the three initiatives included in the survey (campaign finance, anti-bilingual
education, and same-day registration). Notably, the net margin of support across the
three issues is greater among those respondents who said they were extremely or very
mobilized to vote by the measure, than those respondents who said they were not
impelled to turn out because of the initiatives. These findings suggest that in this election,
the particular mix of initiatives motivated a sizeable proportion of citizens to turn out and
cast ballots because they were sympathetic to these issues.
However, we also find some general evidence that ballot measure may actually
mobilize citizens to vote who are hostile to the goals of initiative proponents. In Arizona,
respondents were asked to recall a recent ballot measure they felt was extremely
important. While all Arizona respondents (those who said they were mobilized to vote
because of an initiative on the ballot and those who said they were not mobilized) were
more likely to say they supported than opposed the measure, those who claimed to be
mobilized by an initiative were much less likely than other Arizonans to say they voted in
favor of the measure.
There is also evidence that the mobilizing effects of ballot initiatives may be
contingent on the content of the issue, as well as on the campaign publicity that it
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 83 of 99 Pg ID 1275
11
generates. In Oregon, the proponents of three progressive measures on the November
ballot (increasing the minimum wage, regulating GMO foods, and guaranteeing universal
health care) had little money to advertise their campaign messages. In contrast, their
opponents on the three initiatives spent heavily on broadcast ads and direct mail and were
able to defeat the GMO and health care measures. Correspondingly, citizens in Oregon
who claimed they were very motivated to vote because of initiatives on the ballot were
more likely to say they voted against each of the three initiatives than were those who
said they were not mobilized to turn out by measures on the ballot. Indeed, all three
initiatives garnered negative net support from those respondents who said they were
strongly impelled to vote by the measures. The initiative to increase the minimum wage
was the only measure to receive marginal net supportbut it was only from respondents
who said they were not mobilized to vote because of measures on the ballot. The slight
net support the measure received from non-episodic voters was likely due to the fact that
the state Democratic party took a very public stance in favor of the measure, sending a
strong signal to the base voters who were already likely to turn out.
4
Specification of the Models
We test our hypotheses with logistic regression models that estimate if people
reported that ballot measures played a major role in their decision to participate in a state
election. Responses to the survey items we use to measure this are in Table 1. Models
were estimated separately for each state given differences in question wording and
response categories across our three state samples. For Arizona, respondents were coded

4
The measure was officially sponsored by two Democratic state representatives, Diane Rosenbaum and
Dan Gardner. The chairman of the group opposing the measure was the communications director of
Republican House leader, Karen Minnis (Orr 2004: 8).
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 84 of 99 Pg ID 1276
12
1 if they replied that ballot measures alone ever got you out to vote, and were code 0
for other responses. For Colorado, respondents were coded 1 if they replied that support
or opposition to ballot measure were extremely or very motivating in getting them to
vote, and were coded as 0 for other responses. For Oregon, respondents were coded 1 if
they replied that ballot measure were very motivating, with other replies coded as 0.
We hypothesize that episodic voters, specifically those with weak attachments to
parties, might be mobilized by initiatives (the dealignment / post-materialism thesis). We
also offered rival hypotheses based on the theory that initiatives activate partisan voters.
We test these several ways.
Age and education (both categorical measures) are used to test if younger voters
and less educated voters were more likely to report being mobilized by initiatives.
Finding that the young are more likely to report turning out due to initiatives would be
consistent with the idea that initiatives mobilize dealigned, floating voters. Expectations
about education are less clear. Education is often used as a surrogate for post-materialist
voters not anchored to established parties. A positive effect of education could thus
reflect support for the idea that initiatives mobilize such voters. More realistically,
education is also a marker for people who are more efficacious and participate fairly
regularly. Thus, we assume that a positive effect for education would reflect the
activation of regular voters, rather than the mobilization of new ones.
We also include measures of weak attachments to parties. One dichotomous
measure (independent) represents whether the respondent failed to identify him or herself
as a Democrat or Republican when asked the 3 category party identification question. In
two of our state samples (Arizona and Colorado), respondents were given a follow-up
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 85 of 99 Pg ID 1277
13
question asking strength of partisanship. For those states, our models also include a
dichotomous variable distinguishing strong partisans from other respondents.
Expectations about these variables are fairly straight forward. The dealignment /
mobilization thesis would be supported by a positive effect for the independent variable,
and a negative effect for the strong party identifier variable. Conversely, the activation
thesis would be supported by a positive effect for strong party identifier variable and a
negative effect for the independent variable.
Given this use of dichotomous variables, we are only able to include a measure
representing identifiers of one political party. We thus use a dummy variable where
Democrats are coded as 1, and all other respondents were coded as 0. Regardless of
which partisans are placed in the reference category, we assume that a positive effect for
party identifiers supports the activation thesis. (It is worth noting here that our substantive
findings remained the same when Republicans were represented by a dummy variable
that placed Democrats with others in the reference category.) We also include a dummy
variable that distinguishes relatively ideological voters from others. Coding of these
varied by state and depended on response categories offered in each survey. In Colorado
very liberal and very conservative respondents were distinguished from somewhat
liberal, moderate, and somewhat conservative respondents. In Arizona, liberal
and conservative respondents were distinguished from moderate liberal, moderate,
and moderate conservative respondents. In Oregon, self-identified liberals and
conservatives were distinguished from moderates.
We include two additional variables, gender and race/ethnicity, as controls.
Given the fact that some initiatives in these states have included such matters as Official
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 86 of 99 Pg ID 1278
14
English, English Only language instruction, and have given national attention to
affirmative action and immigration measures on state ballots, it is important to control for
race/ethnicity (Tolbert and Hero 1996). We do this with a dichotomous variable that
distinguishes whites from non whites (substantive results remained the same when a
variable representing Latinos was included). As for gender, Branton (2003) notes that
while men and women tend to vote similarly to one another on most economic and
financial matters, and governance issues, they differ on many other social and moral
issues. By extension, the mobilizing effects of ballot issues may thus differ across
gender.
Results
Overall, across the three states, we find that the post-materialist/dealignment
thesis has little support. In contrast, we find that initiatives appear to mobilize party
identifiers, ideologues, older voters, and the well educated to go to the polls more than
other citizens.
[Table 3 about here]
As the logit models in Table 3 show, in two states a respondents party
identification has a clear effect on being mobilized by initiatives on the ballot.
Democrats in Colorado and Arizona were more likely than Republicans to say they are
mobilized to vote because of initiatives on the ballot.
5
In Colorado, but not in the other
two states, strong partisans were also much more likely to be mobilized by ballot
initiatives in 2002 than those weakly attached to the parties. On top of the party

5
In Colorado, the positive effect of Democrat is nearly identical to that in Arizona when race/ethnicity is
removed from the model.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 87 of 99 Pg ID 1279
15
identification effect in Colorado, the strength of partisanship also predicts a respondent
being mobilized by initiatives. Clearly, then, party identifiers were mobilized, or
activated, more than other people. In contrast, we find no evidence that independents
were more likely to say that initiatives brought them out to the polls.
There is also a subtle gender gap in two states, with women saying that they were
much more likely than men to turn out to vote because of measures on the ballot.
Although this could possibly reflect gender differences in survey responses, it could also
reflect the substance of the measures on the ballot in Colorado and Arizona, or measures
the respondents recalled being on the ballot in Arizona. In two states, women,
controlling for other factors, were more easily mobilized to vote by ballot measures than
men.
6
Older voters in Colorado and Oregon were also more likely to say that ballot
measures brought them out to the polls in 2002.
7
Despite the anti-bilingual education
measure on the ballot in Colorado, states race/ethnicity (non-white) is not significant
variable when it is limited to Hispanics. Race/ethnicity (non-white) is, however, a
significant predictor of turnout in Arizona, perhaps reflecting minorities memories of a
recent English-only measure. The respondents education level is significant only in
Colorado, as is the effect of being very ideological, both in a positive direction.
8
[Table 4 about here]

6
The estimates we report were generated with StataSE 8.0. When these same models are estimated using
the same datasets with SPSS, all the effects reported here are identical, except the effect of gender in
Colorado is not significant.
7
When an interaction term (youth * well-educated) is added to the model (not show here), age is again not a
significant predictor.
8
The measure for very ideological in Arizona and Oregon is not too precise, reflecting more accurately
non-moderates.
When we add surge voters or non-voters dummies to the AZ model and OR, nothing happens. There
is no vote history variable for CO.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 88 of 99 Pg ID 1280
16
Table 4 translates the estimated logit coefficients (from Table 3) into predicted
probabilities. This gives us a sense of the substantive magnitude of the independent
effect that each statistically significant independent variable has on the probability that a
respondent will say she was motivated to turnout due to a state ballot initiative. The
values in table 4 reflect the predicted effect of a shift from the lowest to highest value of
an independent variable, with all other variables held at their median values. Our
partisan, ideological, racial, and gender indicators are all dichotomous, making the
interpretations of these probabilities straightforward. Thus, we find that Democrats in
Arizona were 8% more likely to say an initiative motivated them to vote, compared to
non-Democrats. The independent effects of party identification, strong party loyalties,
and being very liberal or conservative in Colorado each translate to about a 10% increase
in the likelihood that a respondents said they were motivated to vote by a particular ballot
measure. The largest substantive effects we identified were race/ethnicity in Arizona,
where non whites were 17% more likely than whites to say initiatives mobilized them,
and age in Oregon. Older (over 50) Oregonians were 15% more likely to say initiatives
motivated them to turnout. Conversely, the smallest effect we found is age in Colorado,
where the oldest voters were only 4% more likely to say this than young voters.
Discussion
Recent advances in social science have established that electoral institutions
structure aggregate levels of voter turnout (e.g., Blais and Carty 1990). When electoral
institutions are changed, the size of the participating electorate can change. Indeed, the
effects of relatively modest changes in electoral rules may alter the size of the electorate
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 89 of 99 Pg ID 1281
17
and the composition who participates. Voting by mail, as opposed to at precinct
locations, may increase turnout while also changing the mix of who participates
(Southwell and Burchett 2000; Karp and Banducci 2000). Modifications of how votes are
cast in at-large local elections can change how candidates contact voters, and increase
participation in local elections (Bowler, Donovan, and Brockington 2003). Subtle
changes in how electoral district lines are drawn can also increase or decrease turnout of
specific voters. For example, the probability that a Latino will vote increases with the
number of majority Latino districts (congressional, state assembly, state senate) in which
a Latino voter lives (Barretto, Segura, and Woods 2004).
Little is known, however, about how such changes in electoral context play out at
the level of the individual citizen, and researchers are only beginning to answer questions
about who, exactly, is mobilized to vote when institutions change. It seems clear,
however, that effects of changes in electoral rules that affect turnout are not always
neutral. Different groups of people may be mobilized (or demobilized) when new rules
alter the electoral context.
Previous studies have established that more initiatives on the ballot leads to higher
turnout, but we know little about the composition of the higher turnout electorate. We
suggest that the mix of initiatives on a states ballot is a contextual effect that is
analogous to electoral institution. When electoral institutions such as voting procedures,
electoral formula, or district boundaries are altered, the change in electoral context is
stable and enduring, so the mix of the electorate may be permanently altered. This makes
it relatively easy for us to reach conclusions about how the composition of the electorate
may be affected by such changes. However, the mix of initiatives is quite unique in each
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 90 of 99 Pg ID 1282
18
state at any point in time. When the mix of initiatives changes, the electoral context
changes. By extension, we should expect to see a change in which voters are more or
less likely to turnout and vote. That being said, the change in the electoral context
associated with the mix of initiatives is fluid, rather than institutionalized, so it is quite
difficult to reach generalizable conclusions about how initiatives alter the mix of the
electorate.
Nevertheless, the findings in this study to bring us closer to understanding how
shifts in the dynamic mix of initiatives might shape the composition of a states electorate
across time. Our results suggest that these initiatives activated people who resemble
regular voters. Partisan identifiers (Democrats in Arizona and Colorado; strong partisans
of both parties in Colorado), those with self-identified ideological predispositions (in
Colorado), older (in Oregon and Colorado), and better educated (in Colorado)
respondents were most likely to say that initiatives figured heavily in their decisions to
participate in an election. In some years, these people might not turnout because they are
not turned on by regular election choices, or because they are not worried enough about
anything on the ballot that year. When an initiative turns them on, or conversely,
aggravates them, their likelihood of voting increases. In contrast, we find little evidence
that initiatives mobilize people who resemble hard-core non-voters or independents who
might be dealigned from partisan politics.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 91 of 99 Pg ID 1283
19
Table 1
Micro-level Evidence that Ballot Initiatives Increase Turnout
Arizona: Has there ever been a proposition on the ballot so important that it alone got
you to go out to the polls and vote?
Frequency Percent
Yes 155 28
No 356 65
Dont know 34 6
N=545
Colorado: How much did your support or opposition to ballot measures in this election
motivate you to vote?
Frequency Percent
Extremely motivating 64 11
Very motivating 86 14
Somewhat motivating 189 32
Only a little motivating 151 25
Not at all motivating 101 17
Don't know 4 1
N=600
Oregon: How much did your support or opposition to the Oregon ballot measures
motivate you to vote on Tuesday?
Frequency Percent
Very motivating 96 31
Somewhat motivating 96 31
Not very motivating 27 9
Not at all motivating 66 21
Dont know/Refuse 25 8
N=310
Sources: Colorado and Arizona polling conducted by Lake Snell Perry and Associates in
November 2002 and May 2003, respectively. Oregon polling conducted by Penn Shoen
Associates in November 2002. All three surveys commissioned by the Ballot Initiative
Strategy Center (BISC).
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 92 of 99 Pg ID 1284
20
Table 2
Are Voters Mobilized by their Support or Opposition to Ballot Initiatives?
those mobilized those not mobilized
by ballot measures by ballot measures
Vote Net Vote Net
Yes No Yes Yes No Yes
AZ, retrospective 49% 33% +16 58% 31% +27
CO, campaign finance 73% 21% +52 54% 32% +22
CO, anti-bilingual ed. 60% 38% +22 52% 36% +16
CO, same-day registration 55% 39% +16 49% 35% +14
OR, increase min. wage 43% 47% -4 50% 42% +8
OR, label GMO foods 25% 66% -41 25% 63% -38
OR, universal health care 25% 64% -39 24% 61% -37
Note: Samples were divided in terms of those claiming proposition alone led them to
vote (AZ), or that support or opposition to a ballot measure was extremely motivating
or very motivating (CO), or very motivating (OR). Voters only.
Sources: Colorado and Arizona polling conducted by Lake Snell Perry and Associates in
November 2002 and May 2003, respectively. Oregon polling conducted by Penn Shoen
Associates in November 2002. All three surveys commissioned by the Ballot Initiative
Strategy Center (BISC).
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 93 of 99 Pg ID 1285
21
Table 3
Logit Models of Likelihood that Respondent said
Ballot Measures Motivated Him/Her to Turnout
Arizona Colorado Oregon
B s.e B s.e B s.e
Male -0.56 0.21 ** -0.36 0.20 *
-0.18 0.24
Age -0.05 0.09 0.02 0.01 *
-0.13 0.08
^
Education 0.08 0.07 0.13 0.07 *
-0.14 0.10
Independent 0.23 0.31 0.43 0.32
-0.27 0.34
Democrat 0.39 0.25 ^ 0.48 0.22 *
-0.03 0.27
Strong Partisan 0.30 0.27 0.72 0.25 **
Very Ideological -0.04 0.22 0.53 0.22 *
0.13 0.25
Non white 0.77 0.29 ** 0.34 0.33
0.23 0.50
Constant -1.25 0.58 * -2.36 0.40 **
-0.14 0.56
N= 510 593 292
model chi-sq. 23.5 (p < .003) 36.1 (p <. 000) 7.1
Pseudo R
2
.06 .06 .02
*** = significant at p < .01; ** at p <.05, ^ at p < .10.
Note: Logistic regression coefficients estimated with StataSE 8.0. Dependent variables
constructed from responses to questions reported in Table 1. For Arizona, 1 = ballot
measures alone ever got you out to vote, 0 = other. For Colorado, 1 = ballot measure
extremely or very motivating, 0 = other. For Oregon, 1 = ballot measure very
motivating, 0 = other.
Sources: Colorado and Arizona polling conducted by Lake Snell Perry and Associates in
November 2002 and May 2003, respectively. Oregon polling conducted by Penn Shoen
Associates in November 2002. All three surveys commissioned by the Ballot Initiative
Strategy Center (BISC).
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 94 of 99 Pg ID 1286
22
Table 4
Substantive Effects of Estimates in Table 3:
Predicted Probability of Respondent saying
that Ballot Measure Motivated Him/Her to Turnout
Arizona Colorado Oregon
Democrat .33 .30
not Democrat .25 .21
Strong partisan .31
Not strong partisan .19
Very ideological .31
Not very ideological .21
High education .29
Low education .18
Oldest .27 .46
Youngest .23 .31
Female .33 .27
Male .22 .21
White .25
non White .42
Source: predicted from estimates in Table 4.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 95 of 99 Pg ID 1287
23
References
Abramson, Paul, John Aldrich, and David Rohde. 1998. Change and Continuity in the 1996
Elections. Washington, DC: CQ Press.
Banducci, Susan. 1998. Direct Legislation: When is it Used and When does it Pass? in Bowler,
Shaun, Todd Donovan, and Caroline Tolbert (eds.), Citizens as Legislators: Direct
Democracy in the United States. Columbus: Ohio State University Press.
Barretto, Matt, Gary Segura and Nathan Woods. 2004. The Mobilizing Effect of Majority
Minority Districts on Latino Turnout. American Political Science Review. 98:65-76.
Benz, Mattias and Alois Stutzer. 2004. Are Voters Better Informed when they have a Larger
Say in Politics? Public Choice. 119: 31-59.
Blais, Andre and R. Kenneth Carty. 1990. Does Proportional Representation Foster voter
Turnout? European Journal of Politics. 18:167-81
Bowler, Shaun, and Todd Donovan. 2002. Democracy, Institutions and Attitudes about Citizen
Influence on Government. British Journal of Political Science 32: 371-90.
Bowler, Shaun, and Todd Donovan. 1998. Demanding Choices: Opinion and Voting in Direct
Democracy. Ann Arbor: University of Michigan Press.
Bowler, Shaun and Todd Donovan. 1994. Information and Opinion Change on Ballot
Propositions. Political Behavior. 16: 411-435.
Bowler, Shaun, Todd Donovan, and David Brockington. 2003. Electoral Reform and Minority
Representation: Local Experiments with Alternative Elections. Columbus: Ohio State
University Press.
Bowler, S., T. Donovan J. Karp and D. Lanoue. 2004. Independents Day: Critical citizens
among the US voting public. Paper presented at the Southern Political Science
Association meeting, New Orleans, LA.
Branton, Regina. 2003. Examining Individual-Level Voting Behavior on State Ballot
Propositions. Political Research Quarterly 56: 367-377.
Campbell Angus, Philip Converse, Warren Miller and Donald Stokes. 1960. The American
Voter. New York: John Wiley and Sons.
Carmines, Edward and James Stimson. 1980. The Two Faces of Issue Voting. American
Political Science Review. 74: 78 -91
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 96 of 99 Pg ID 1288
24
Craig, Steven, Amie Kreppel, and James Kane. 2001. Public Opinion and Direct Democracy: A
Case Study, in Mendelsohn and Parkin (eds.), Referendum Democracy: Citizens, Elites,
and Deliberation in Referendum Campaigns. New York: Palgrave.
Chavez, Lydia. 1998. The Color Bind: Californias Battle to End Affirmative Action. Berkeley:
University of California Press.
Dalton, R. 2003. Citizen Politics: Public Opinion and Political Parties in Advanced Industrial
Democracies. Chatham, NJ: Chatham House.
Dalton, R. W. Burklin and A. Drummond. 2001. Public Opinion and Direct Democracy.
Journal of Democracy 12:141-53.
Donovan, Todd and Joe Snipp. 1994. Support for Legislative Term Limitations in California:
Group Representation, Partisanship, and Campaign Information. Journal of Politics 56:
492-501.
Downs, Anthony.1957. An Economic Theory of Democracy. New York: Harper & Row.
Erickson, Stephanie. 2003. Wage Issue could Shape Vote, Orlando Sentinel, September 22,
2003. Available: www.orlandosentinel.com
Everson, D. 1981.The Effects of Initiatives on Voter Turnout: A Comparative State Analysis.
Western Political Quarterly. 34: 415-25.
Flannigan, William and Nancy Zingale. 2003. Political Behavior of the American Electorate,
10
th
ed. Washington, DC: CQ Press.
Garrett, Elizabeth. 2004. McConnell v. FEC and Disclosure. Election Law Journal 3: 237-244.
Garrett, Elizabeth and Daniel A. Smith. 2003. Veiled Political Actors: The Real Threat to
Campaign Disclosure Statutes, USC-Caltech Center for the Study of Law and Politics
Working Paper No. 13.
Gerber, Elisabeth, and Arthur Lupia. 1995. Campaign Competition and Policy Responsiveness
in Direct Political Behavior. Political Behavior 17: 287-306.
Green, Donald, Bradley Palmquist and Eric Shickler. 2002. Partisan Hearts and Minds: Political
Parties and Social Identities of Voters. New Haven. Yale University Press
Hasen, Richard. 2000. Parties Take The Initiative (And Vice Versa). Columbia Law Review
100: 731-752.
Hero, Rodney and Caroline Tolbert. 2004. Minority Voices and Citizen Attitudes about
Government Responsiveness in the American States: Do Social and Institutional Context
Matter? British Journal of Political Science 34: 109-121.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 97 of 99 Pg ID 1289
25
Inglehart, R. 1977. Silent Revolution. Princeton, NJ: Princeton University Press.
Jackson, Robert, Robert Brown, and Gerald Wright.1998. Registration, Turnout, and Electoral
Representativeness of U.S. State Electorates. American Politics Quarterly 26: 259-87.
Karp, Jeffrey A.1998.The Influence of Elite Endorsements in Initiative Campaigns In Bowler,
T. Donovan and C. Tolbert (eds.), Citizens as Legislators: Direct Democracy in the
United States. Columbus, OH: Ohio State University Press.
Karp, Jeffrey A. and Susan Banducci. 2000. Going Postal: How All-Mail Elections Influence
Turnout. Political Behavior. 22(3):223-39.
Lupia, Arthur.1994. Shortcuts versus Encyclopedias: Information and voting Behavior in
California Insurance Reform Elections. American Political Science Review 88:63-76.
Magleby, David.1984. Direct Legislation: Voting on Ballot Propositions in the United States.
Johns Hopkins University Press.
Mendelsohn, Matthew, and Fred Cutler. 2000. The Effect of Referenda on Democratic Citizens:
Information, Politicization, Efficacy and Tolerance. British Journal of Political Science
30: 669-698.
Nicholson, Stephen P. 2003. The Political Environment and Ballot Proposition Awareness.
American Journal of Political Science 47. 403-411.
Patterson, Thomas. 2002. The Vanishing Voter: Public Involvement in an Age of Uncertainty.
New York: Knopf.
Rosenstone, Steven and John Mark Hanson. 2003. Mobilization, Participation, and Democracy
in America. New York: Longman.
Schrag, Peter. 1998. Paradise Lost: Californias Experience, Americas Future New York: New
Press.
Smith, Daniel A. and Caroline Tolbert. 2004. Educated by Initiative: The Effects of Direct
Democracy on Citizens and Political Organizations in the American States. Ann Arbor:
University of Michigan Press.
Smith, Daniel A. and Caroline Tolbert. 2001. The Initiative to Party: Partisanship and Ballot
Initiatives in California. Party Politics 7: 781-99.
Smith, Mark A. 2001.The Contingent Effects of Ballot Initiatives and Candidate Races on
Turnout. American Journal of Political Science 45: 700-6.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 98 of 99 Pg ID 1290
26
Smith, Mark A. 2002. Ballot Initiatives and the Democratic Citizen. Journal of Politics 64:
892-903.
Southwell, Priscilla and Justin Burchett. 2000. The Effect of All-Mail Elections on Voter
Turnout. American Politics Quarterly. 28:72-79.
Tolbert, Caroline J. 2003. Cycles of Democracy: Direct Democracy and Institutional
Realignment in the American States. Political Science Quarterly 118: 467-489.
Tolbert, Caroline, Ramona McNeal, and Daniel A. Smith. 2003. Enhancing Civic Engagement:
The Effect of Direct Democracy on Political Participation and Knowledge. State Politics
and Policy Quarterly 3: 23-41.
Tolbert, Caroline, John Grummel, and Daniel Smith. 2001. The Effects of Ballot Initiatives on
Voter Turnout in the American States. American Politics Review 29: 625-48.
Tolbert, Caroline, Daniel Lowenstein, and Todd Donovan. 1998. Election Law and Rules for
Using Initiatives, in Shaun Bowler, Todd Donovan, and Caroline Tolbert (eds.), Citizens
as Legislators: Direct Democracy in the United States. Columbus: Ohio State University
Press.
Sniderman, Paul, Richard Brody and Philip Tetlock, et al 1991. Reasoning and Choice:
Explorations in Political Psychology. Stanford University Press.
Waters, M. Dane. 2003. The Initiative and Referendum Almanac, A Comprehensive Reference
Guide to the Initiative and Referendum Process. Carolina Academic Press.
Wattenberg, Martin. 2002. Where Have All the Voters Gone? Cambridge: Harvard University
Press.
Wattenberg, Martin. 1996. The Decline of American Political Parties. Cambridge: Harvard
University Press.
Wenzel, James, Todd Donovan and Shaun Bowler. 1998. Direct Democracy and Minorities:
Changing Attitudes about Minorities Targeted by Initiatives. In Bowler, T. Donovan
and C. Tolbert (eds), Citizens as Legislators: Direct Democracy in the United States.
Columbus, OH: Ohio State University Press.
2:12-cv-10285-BAF-MJH Doc # 65-4 Filed 08/12/13 Pg 99 of 99 Pg ID 1291

Anda mungkin juga menyukai