Ari Ezra Waldman | Boy Scouts | Law - Gay, LGBT | News

Legalizing Gay: The Boy Scouts, The St. Patrick's Day Parade, and Fighting Private Discrimination

BY ARI EZRA WALDMAN

To celebrate Pride 2012 and to honor the great civil rights and political successes we have earned recently, I would like to offer a series of columns on the lawyers, advocates, scholars, and individual leaders who have sacrificed so much, developed novel legal arguments, and won the legal victories upon which we stand today. It is impossible to include everyone; an entire life's work would fail to honor all of our forefathers. But these few representatives symbolize the contributions of the greater whole: a group of men and women, young and old, who have sacrificed so that we can live a life of freedom today. In today's column, the men and women fighting discrimination by private actors.

Last month, the Boy Scouts of America forced Jennifer Tyrrell to resign as den mother of her 7-year-old son's Tiger Scout troop because she is a lesbian. The incident prompted a resignation from the BSA Board, a longing for the Mitt Romney of 1994, an affirmation of BSA's antigay ways, and, ultimately, a policy reassessment that no one thinks will result in any change. The fracas has inspired grand defenses of the Boy Scouts, rants against obvious and pointless discrimination, the meaning of citizenship, and the difference between private and public entities. There has, however, been very little talk about a man named James Dale.

StoryBefore Ms. Tyrrell brought her children onto the stage at the GLAAD Awards, Mr. Dale was the face of the struggle against the Boy Scouts. He was a scout himself and then an assistant scout master in New Jersey when he was fired for being the president of Rutgers University's Lesbian & Gay Association or, as the Scouts put it, an "avowed homosexual." Evan Wolfson, Beatrice Dohrn, and Jon Davidson (among others) at Lambda Legal took Mr. Dale's case to New Jersey's highest court (where they won unanimously) and to the United States Supreme Court (where they lost by one vote), arguing that the Scouts had no right to flout nondiscrimination laws. Boy Scouts of America v. Dale (2000), is the story of the gay rights movement of the 1990s: reeling from Bowers v. Hardwick (1986), clawing for small victories, beset by a judiciary too slow to recognize the human dignity of gay persons, and fighting a lonely but necessary battle. Without Mr. Dale, there would be no Ms. Tyrrell, no thousands of signatures on a change.org petition urging the Boy Scouts to mend its ways, and no men and women willing to stand up to private hate.

Dale and the St. Patrick's Day parade case, Hurley v. Irish-American Gay, Lesbian, and Bisexual Group of Boston (GLIB), form the foundation of today's governing law on the right of religious private actors to discriminate against gay persons. Neither are very favorable precedents, and their rationales haunt us to this day. And, yet, were it not for Mr. Dale and a group of proud gay Irish-Americans -- all of whom defined themselves as more than "gay" activists -- the Scouts and St. Patrick's Day parades would not be the focus on activism they are today. Nor would we be willing to stand up when copycats follow suit.

Most importantly, although Mr. Dale and GLIB may have brought cases about free expression, they were always the scariest enemies of anti-gay hate and discrimination. They cleared the way for none other than our marriage equality plaintiffs in California, Nevada, Illinois, New Jersey, and elsewhere because they sought inclusion in mainstream civil institutions, participation in which can only demystify the LGBT community and undermine conservatives' main line of attack against gays as licentious, depraved, overtly sexual, and marginal to society.

CONTINUED, AFTER THE JUMP...

Mr. Dale sued the Boy Scouts to stop the the organization from firing him as scout leader simply because he is gay. The U.S. Supreme Court concluded that applying New Jersey's public accommodations law, which bans private discrimination on the basis of sexual orientation (among other things), to the Boy Scouts violated the Boy Scout's right of "expressive association." That concept refers to a private group's right to constitute itself so as to offer a particular message, which in this case was a pro-heterosexuality message. Allowing a gay person to represent the organization would contradict its stated aim of teaching "that homosexual conduct is not morally straight" and of not "promot[ing] homosexual conduct as a legitimate form of behavior." The Court found that forced inclusion of an "avowed homosexual" severely hampered the Scouts' ability to preach heteronormative values.

HhIn Hurley, the Court made a similar conclusion. GLIB sued to be allowed to march in the St. Patrick's Day parade under its own banner. The Supreme Court declined to force the group's participation under the Massachusetts public accommodation law because the parade had some "collective message" that was inconsistent with allowing gays in. The fiercely independent Justice Souter had a lyrical way of making his point: "Rather like a composer, the [parade organizer] selects the expressive units of the parade from potential participants, and though the score may not produce a particularized message, each contingent's expression in the [organizer's] eyes comports with what merits celebration on that day." Run by a private association, the Parade was a private speaker, free to choose its message and free to say that a given applicant's message was inconsistent with overall voice of the Parade. After all, we cannot let the state compel the agitator in Union Square to say (or not to say) this or that.

Dale and Hurley pitted two private groups' desire to control their messages against state laws that mandated the equal treatment of gay persons. In this very basic way, the cases seemed to represent a classic conflict between two Constitutional rights -- freedom of expression and equality -- and a neat neo-liberal or libertarian solution: private institutions are free to settle on their own mission and means for effectuating that mission, and the State should not interfere by ordering a private association to adopt certain values. That rationale makes some sense; it's even rather progressive in the same way that we do not want a President Santorum enforcing his own brand of radical Catholicism on our behavior or private associations.

But, Dale and Hurley were never that simple. Nor were the majorities' cavalier solutions particularly scholarly or judicious.

The Court thought it faced a conflict between a group's freedom of expression and another group's guarantee of equality and, quite simply, chose expressive freedom over equality. We are left asking: if the Boy Scouts and the St. Patrick's Day parade organizers can ignore equality legislation when it comes to gays, can other private institutions? The answer must be no for three reasons: First, any other answer would let Dale eviscerate all nondiscrimination laws; second, the Court said that the discriminatory message has to be essential to the purpose of the group; and, third, after Lawrence v. Texas, Dale may no longer be good law.

It is evident that if any organization could write a line in its mission statement -- "We formed this organization to teach the values of God, morality, and tradition by selling heterosexual lounge chairs," for example -- and avoid anti-discrimination laws, there would no longer be any such thing as anti-discrimination laws.

It is also clear from the Court's opinion in Dale that the reason the organization excludes someone has to be linked to a purpose of the organization that is essential to its identity. in Dale, the Court made clear that, at the time, the Scouts had an official position against "avowed homosexuals" being scout leaders and because heterosexuality was part of the Scouts' message, keeping Mr. Dale as a leader while letting him "avow" his sexual identity would burden the Scouts' ability to push its own message. The Court said the exact same thing in Hurley.

However, even if we accept the legitimacy of this reasoning in 1995 and 2000, it seems outdated in a post-Lawrence world. Lawrence made clear that homosexuality as an identity, and the individual or group conduct that accompanied that identity, could neither be criminalized nor the subject of state opprobrium simply because some people think it immoral. And, more recently, in Christian Legal Society v. Martinez, Justice Ginsburg's majority opinion collected cases to make the point clear: there is no such thing as laws that are constitutionally appropriate simply because they attack, criminalize, or censure conduct, and not identity, when that conduct is so wrapped up with the target's identity that they are, at a minimum, proxies for one another.

In Lawrence, that act-identity distinction was between being gay and sodomy, a distinction that held sway in Bowers v. Hardwick; in Dale and Hurley, it was about being gay and saying you are. In other words, that Mr. Dale was a so-called "avowed homosexual" and that his openness about his sexuality was the reason for his dismissal is an outdated, discriminatory way of saying, "We love the sinner, hate the sin." "Don't Ask, Don't Tell" was supposed to fit that bill, and so did cases where a gay employee was fired not because she was gay, but because she got married and put a notice in the newspaper. After Lawrence and other cases, the Constitution no longer countenances that canard. In a society that, through public accommodation laws, has denounced private -- not just public -- discrimination, permitting the Dale and Hurley loopholes seems anti-democratic and contrary to our values.

The conservative federal judiciary is unlikely to reconsider these precedents anytime soon. But, we still own Mr. Dale and the members of GLIB a great debt for not only highlighting the Boy Scouts and the St. Patrick's Day parade as bastions of discrimination, but for challenging the codification of an act-identity distinction that once allowed all manner of morality laws to either keep us in the closet or silence us entirely. 

They also paved the way for other impact litigation plaintiffs, like Sandy Stier and Kris Perry, two of the marriage equality plaintiffs in Perry v. Brown, and all those men and women seeking marriage recognition for gays. By seeking to join conservative institutions -- civil organizations that teach citizenship and morality and stability -- Mr. Dale, Ms. Stier, and Ms. Perry are all at the vanguard of gay integration into mainstream society. They are our greatest symbols, and bigotry's greatest enemies, because they represent everything conservatives refuse to recognize about us: that we are just like everyone else, willing to devote ourselves to others, to love, to support our country, to do charity, to raise kids, and to sacrifice.

***

Ari Ezra Waldman teaches at Brooklyn Law School and is concurrently getting his PhD at Columbia University in New York City. He is a 2002 graduate of Harvard College and a 2005 graduate of Harvard Law School. His research focuses on technology, privacy, speech, and gay rights. Ari will be writing weekly posts on law and various LGBT issues. 

Follow Ari on Twitter at @ariezrawaldman.

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Comments

  1. Too bad Mr. Dale wasn't my scout master! Those horrible meetings would have been way more enjoyable.

    Posted by: Mickey | Jun 15, 2012 11:27:06 AM


  2. Ari - thank you yet again for your informed and eloquent championship of gay leaders, now the nearly forgotten James Dale, a hero in his time, and ours, and someone I remember well. A word about his life these days would also be appreciated if you have such information. But by all means say on, I will be reading every word.

    Posted by: UFFDA | Jun 15, 2012 11:46:14 AM


  3. When everyone was afraid to bring cases due to the Supreme Court, I thought it was important to do it. Gandhi knew that to win against injustice, you had to highlight the inhumanity of the laws and those who sought to enforce them.

    Without Bowers or Dale or other cases that came out wrong, we cannot get to the right decisions. It takes time and shame to get people to do the right thing for a minority group. Justices are people, too. It took Justice Powell admitting his regret over the Bowers case to move other justices to consider their positions again.

    Without Bowers and other gay rights legal "failures" we couldn't have reached the successes. We'll continue to have cases that fail, but in time they will lead to the cases that vindicate us.

    Posted by: Michael Rutledge | Jun 15, 2012 12:23:47 PM


  4. Thanks for remembering James Dale , he is a true pioneer of Human Rights.

    Posted by: ty | Jun 15, 2012 5:27:21 PM


  5. Ari, I usually like your stuff, but this time you're way off. You're arguing the emotion and not the law.

    Yes, the conflicting values here are freedom of expression and freedom of association. And in that battle with regard to the conduct of a private organization, association must be held over expression. The entire reason the association exists is because of the unified expression. By forcing contrary messages into the group, you defeat the purpose. The private group must be allowed to define their rules as to what constitutes the group, which necessarily means excluding people they don't want in. This can be both specific ("We don't want you") and general ("Or anyone like you.")

    This is why there was a discrepancy between the NJSC and the SCOTUS with regard to the Scouts: If you think the Scouts are a public accommodation, then of course they are required to abide by anti-discrimination laws. But if they aren't, then they don't. The California Supreme Court held similarly in Curran v. Moutn Diablo Council of the Boy Scouts of America: The BSA is not a "business establishment" and thus is not subject to the regulations for such.

    So what makes a public accommodation? Well, for a hospital, it's the fact that they are charged with providing services to all. They cannot turn away patients and thus they also cannot deny employment. But the Scouts are nothing like that. They don't allow females to be Scouts, for example. And if it's OK to have a group that is single-sex, then it is OK to have a group that is for straights only. The fact that they are popular may make it sad, but it doesn't make it unconstitutional.

    But by establishing themselves as a private institution, that means they cannot complain when they are treated as such. Since they are no longer a public accommodation, they can no longer avail themselves of public funds and treatment that other such institutions would have.

    Thus, we demand that Nazis be allowed to apply for a parade permit and that the permit be granted. The use of the public streets is something that is bestowed to all. But, we don't give them sweetheart deals for renting office space in the public buildings.

    And the SCOTUS has agreed: The Boy Scouts sued the State of Connecticut because it removed the BSA from a state workplace funding program due to its anti-gay position. The BSA claimed that the state was "sanctioning discrimination." But every court along the way sided with the state and the SCOTUS refused to hear it. The BSA is free to be as anti-gay as they want to be, but they don't have the right to demand nobody pay attention to that fact.

    And it happened again in San Diego: The BSA had a sweetheart deal regarding 18 acres of land in Balboa Park: $1/year. Yes, that's right. For one dollar per year, they had exclusive access to certain areas and were given free access to an aquatic facility in Mission Bay. When the Scouts asked for an early renewal, the city decided to treat them as the "private religious organization" they claimed to be and charged them $2500/year.

    At the District Court, the BSA lost since they defined themselves as a religious organization and thus the lease was in violation of the establishment clause. Thus, the new lease.

    All of this is quite different from the question of marriage, which is a public contract. The BSA wanted to be considered private. What we need to do is make sure they accept the consequences of that determination.

    And remember, this cuts both ways. If we overturn Dale, then that means Phelps and his clan gets to march *in* the Pride parade. If we want to have the ability to prevent anti-gay groups from being part of gay events, then we must allow the inverse. Anti-gay groups must have the ability to prevent gay groups from joining.

    Posted by: Rrhain | Jun 15, 2012 5:30:44 PM


  6. RRHain,

    You make some good points, particularly about the converse (and bizarre!) situation of Phelps marching in a Pride parade.

    Two questions:
    1) how can anyone be excluded from any public parade or demonstration, given that there is municipal funding and support for *all* such marches and parades (Pride, St Patricks, they all require assistance from the city, if only for road closures and emergency services)
    2) not being American, I may have misunderstood the Boy Scout basics, but why is it that the exclusion of gays would be acceptable here, but not the exclusion of, say, Jews or atheists? Ari's point on the single-sex boy scouts is well made, but I wonder if a Nzai group could legitimately exclude "avowed" blacks and Jews?

    Thanks, El

    Posted by: elegir | Jun 15, 2012 7:13:24 PM


  7. @Elegir

    Because public assistance to private organizations shouldn't be disallowed in and of itself. The public streets are there for all of us, including private individuals and groups. We shouldn't deny the use of public facilities by private groups simply because they are so large that they require management that the government is best able to provide.

    That is, the cops are there to protect the bigots just as much as you or me. We cannot deny a group we don't like the use of public facilities just because we don't like them.

    And so, like it or not, the Boy Scouts are free to be as exclusionary as they wish, so long as they remain private. As soon as they cross the line into public accommodation, then things will change.

    And with regard to your question about Jews, the Boy Scouts can and do exclude on the basis of religion. Various Unitarian groups have been kicked out of the Boy Scouts precisely because they do not toe the line regarding gay people. They don't allow atheists. As a private group, they are allowed to do whatever they want.

    The US Open, a golf tournament, is currently being played here in the US. It's one of the four major tournaments, of which the "Masters" is another...played at Augusta in Georgia.

    Augusta National Golf Club does not allow women. It didn't allow blacks to join until 1990. This is all perfectly legal because Augusta is a private organization.

    Posted by: Rrhain | Jun 15, 2012 9:00:57 PM


  8. Thanks for the insight. I feel that here in the UK we prefer to err on the side of equality. This may be because all businesses, charities and other organisations are ultimately granted their status by government and so cannot claim the same "freedom of expression" rights as an individual. Thus you're perfectly entitled to stop gays from entering your house, but not when you're a charity organisation claiming tax benefits, say. This was why the Catholic adoption agencies here can't discriminate against same-sex parents. Similar thing with the gentlemen's clubs around London.

    Just a different approach to the same "problems" of competing rights, I guess.

    Posted by: elegir | Jun 16, 2012 12:12:00 AM


  9. Ari, I loved this piece and agree with every point made.

    EQUALITY FOR ALL OR EQUALITY FOR NONE!

    Posted by: CJ | Jun 16, 2012 3:28:03 AM


  10. Ari-

    Great write up. Valid points. And yes, it's men like this who bring these injustices to the limelight and take it to court and fight for our behalf who bring about change.

    Posted by: Steve-ATL | Jun 16, 2012 3:28:49 AM


  11. If they don't eliminate those based on being black, or Latino, then they shouldn't based on being gay either. This whole notion that we need to tip toe around race, but completely be free to discriminate based on sexual orientation is ridiculous and finally is being confronted...and loudly so.

    Posted by: James | Jun 16, 2012 3:30:09 AM


  12. i, for once, have no opinion on the finer points of the law, in the main because the points of law used are utter bullsh*t. the simply hunted around until they found enough chaff to come to the preordained conclusion.

    what i am particularly grateful for is setting the record straight on when and who had the stones to take on the BSA.

    as much as i deeply admire zach wahls, whether by design or out of youthful zeal, his assumption that he is the only one who has tried to beard this particular dragon has set my teeth on edge. i have written to and tweeted mr wahls to no avail, so no correction of the records has been acknowledged or released. i await that clarification.

    Posted by: bandanajack | Jun 16, 2012 3:55:46 AM


  13. I have posted so many times that I have lost count of my telling of my experience as a Gay Boy Scout in the late 1930's, in a Troop whose Scout Master was a known Homosexual; in a Patrol of 8 Gay members and three other Patrols of 6 Strait members each. No Parents complained; the Public Grammar School in which we held our meetings did not complain; The County Summer camp we all went to did not complain.

    Just what is the REAL problem with the current batch of so-called Scout Leaders? When did Homophobia get such a hold on the Scout's current leadership. Is one of the top leaders a closet case who is afraid of being discovered? Would someone let me know?

    Posted by: Jerry6 | Jun 16, 2012 8:36:35 PM


  14. Thank you for not running pictures of gay couples and their children on your site. The Advocate did. I thought about how these pictures would appear in 200 years, as evidence of a bold social move, or freakish evidence of a major failure, Now the couples look content that "they got one, or two children." Like studying old pictures from the 1800's, I wonder if time will have been as kind, or how unkind.
    This too shall pass.

    Posted by: Gary | Jun 16, 2012 10:03:51 PM


  15. OMFG, Gary. Hush, silly.

    Plus, I think you are secretly just touting the Advocate. I'm glad you did though: The "26 Hot Gay Dads" spread makes my heart beat faster :-). Y'all SHOULD check it out.

    And maybe Towleroad can splay it out better for us than the Advocate site itself??

    Posted by: just_a_guy | Jun 17, 2012 1:24:55 AM


  16. What does the four leaf clover have to do with Eire or the St Patrick's day parade? You do know that the Shamrock has three leaves.

    Posted by: andrew | Jun 17, 2012 2:51:55 AM


  17. Just a Guy: " Made your heart beat faster?" What's exciting about a child as prop? It made for a campy movie about Joan Crawford. Maybe you need to be splayed out.

    Posted by: Gary | Jun 17, 2012 1:59:34 PM


  18. Just a Guy: " Made your heart beat faster?" What's exciting about a child as prop? It made for a campy movie about Joan Crawford. Maybe you need to be splayed out.

    Posted by: Gary | Jun 17, 2012 1:59:35 PM


  19. Such eloquence for such debauchery.

    Posted by: Smile | Jun 18, 2012 12:31:05 AM


  20. Disclaimer: Gary, I think ur just bein ironic; sorry if I'm slow :-)

    @Gary: you lost me, buddy.

    I don't know squat about Joan Crawford and resent any suggestion that I should care about ms. Crawford.

    Also, dude, did you just call me a pedophile?? ! Uh, what?

    And did you just oversexualize my appreciation, inspiration, etc., of these examples of brave role model celeb dads??

    Are you attempting to call me inherently overtly sexual because I make an innocent comment about the attractive gay male stars who the Advocate profiles as just a few high-profile examples of a growing brand of more honest, forthright, and ADMIRABLE parenting by men who happen to feel their strongest lifelong romantic attractions to the same sex?

    Isn't that outlook of yours, señor gary, part of the PROBLEM?!

    I suppose instead of playfully, innocently, and not inappropriately noting the emotional affect for me of looking at these role models of mine--all adorable with their children--you would have me neuter myself and fawn over some silly girl (Crawford or whoever) who does nothing for me?!

    And you lost me with the splay comment too.

    I take it you are from an older generation where you had even less luck than mine to be allowed to develop an appreciation of ourselves as equal human folk.

    In any case, Ari, I just now read your piece in full. ADORE it. !! The first time I learned Dale and Hurley, they were taught as good, well-reasoned law, as solid precedent we should respect. My two subsequent readings of them left me amazed that anyone could ever treat them as harmless, neutral or in any way wise decisionmaking. I see both opinions as an embarrassment to the Court. (So, Jack, I hear ya; I remember it took a lot of squinting for me to not imagine that they simply slapped language down to match preordained unexamined antigay bias: was one example of that implicit in changing the public/private test from the Jaycees case to allow duscrimination against gays?) All of this was years ago for me tho.

    Also, I didn't know much about Dale as a person, hmm. Why did I think he wasn't too involved with the BSA at all by the time the BSA balked at being associated with his name in an article he wrote at college or something??

    Btw, Ari, sorry if I've tarnished your eloquence with my called-for dispute with the Gares. But I do see TR as a community of sorts, the sort of place I can admire, look up to, and even express attraction for gay Dads :--), or others.

    And Gary, I do not mean to show you disrespect personally.

    Posted by: just_a_guy | Jun 18, 2012 4:20:26 AM


  21. Disclaimer: Gary, I think ur just bein ironic; sorry if I'm slow :-)

    @Gary: you lost me, buddy.

    I don't know squat about Joan Crawford and resent any suggestion that I should care about ms. Crawford.

    Also, dude, did you just call me a pedophile?? ! Uh, what?

    And did you just oversexualize my appreciation, inspiration, etc., of these examples of brave role model celeb dads??

    Are you attempting to call me inherently overtly sexual because I make an innocent comment about the attractive gay male stars who the Advocate profiles as just a few high-profile examples of a growing brand of more honest, forthright, and ADMIRABLE parenting by men who happen to feel their strongest lifelong romantic attractions to the same sex?

    Isn't that outlook of yours, señor gary, part of the PROBLEM?!

    I suppose instead of playfully, innocently, and not inappropriately noting the emotional affect for me of looking at these role models of mine--all adorable with their children--you would have me neuter myself and fawn over some silly girl (Crawford or whoever) who does nothing for me?!

    And you lost me with the splay comment too.

    I take it you are from an older generation where you had even less luck than mine to be allowed to develop an appreciation of ourselves as equal human folk.

    In any case, Ari, I just now read your piece in full. ADORE it. !! The first time I learned Dale and Hurley, they were taught as good, well-reasoned law, as solid precedent we should respect. My two subsequent readings of them left me amazed that anyone could ever treat them as harmless, neutral or in any way wise decisionmaking. I see both opinions as an embarrassment to the Court. (So, Jack, I hear ya; I remember it took a lot of squinting for me to not imagine that they simply slapped language down to match preordained unexamined antigay bias: was one example of that implicit in changing the public/private test from the Jaycees case to allow duscrimination against gays?) All of this was years ago for me tho.

    Also, I didn't know much about Dale as a person, hmm. Why did I think he wasn't too involved with the BSA at all by the time the BSA balked at being associated with his name in an article he wrote at college or something??

    Btw, Ari, sorry if I've tarnished your eloquence with my called-for dispute with the Gares. But I do see TR as a community of sorts, the sort of place I can admire, look up to, and even express attraction for gay Dads :--), or others.

    And Gary, I do not mean to show you disrespect personally.

    Posted by: just_a_guy | Jun 18, 2012 4:20:28 AM


  22. Btw, I qualify my "ever" reasonable statement above: I suppose pre-Lawrence, as Ari points out, Dale and Hurley might have made more sense.

    Their apparent injustice aside, it's interesting to see them entrenched as good law, even if more recent and upcoming cases might arguably show a chipping away at them.

    Posted by: just_a_guy | Jun 18, 2012 4:46:45 AM


  23. I'd be curious to see Ari's response to Rrhain.

    Posted by: just_a_guy | Jun 18, 2012 4:49:53 AM


  24. @ELEGIR, we have that here in the US, too. In various jurisdictions, Catholic organizations have declared that they will stop providing adoption services rather than accept gay clientele as prospective parents as the law requires them to do. They claim their religious freedom is being violated. It isn't, but that's what they claim.

    The needs of the child come first and adoption is controlled by the state. The establishment of parentage is a legal contract and while various agencies may be set up to help place children in families due to various aspects of the case, they must abide by the legal strictures regarding who can adopt and not deny access. Nobody is forcing the Catholic Church to provide adoption services. They decided to do that on their own. Thus, they are not being denied anything by insisting that they, just like all other adoption agencies, follow the law.

    You are having the same debate in the UK, though from the other side: Cameron's push to have full marriage equality in the UK has the Anglican church complaining that their religious freedom is being violated.

    Posted by: Rrhain | Jun 18, 2012 11:19:27 AM


  25. The focus seems to be the "parents" not the children. They are merely what is acquired (in any way possible) to satisfy the parents "wants." Joan Crawford refers to the 1981 film "Mommie Dearest".It is a film based on the true account of a miserable, abused adopted child of a real Hollywood movie star of the 1940's. It's rather camp but also revealing. Joan Crawford couldn't have children,, but wanted to appear like the good mother at any cost -- which she was incapable of being. Rather like inexperienced boys being Mommy and Daddy. And it appears you have to be rich to pull it off as well. Neil Patrick Harris, showed his "nanny" to Oprah. aka: real female influence, caregiver, mother?

    Posted by: GB | Jun 18, 2012 2:47:13 PM


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