came into being,”
when “the medical and psychological community considered
homosexuality an illness.”
Though attempting to change an individual’s sexual ori-
entation is today roundly condemned by the medical and psychological academy,
many states permit so-called “conversion therapy,”
which “encompasses a variety
of methods, including both aversive and non-aversive treatments.”
In the past, these
aversive techniques involved “inducing nausea, vomiting, or paralysis; providing
electric shocks; or having an individual snap an elastic band around the wrist when
aroused by same-sex erotic images or thoughts.”
Even today, non-aversive prac-
tices to “‘cure’ individuals of their same-sex sexual orientations . . . include a num-
ber of techniques ranging from shaming to hypnosis to inducing vomiting to electric
Many self-proclaimed therapists now use less invasive means, including
“assertiveness and affection training with physical and social reinforcement,” hyp-
nosis, and redirecting thoughts.
Nevertheless, even with less barbaric techniques,
the risk of serious psychological trauma to those who attempt to change their sexual
orientation, and especially to minors, who are often forced into treatment, is pro-
found. The Williams Institute at UCLA Law School reports that LGB people who
have suffered from conversion therapy showed far greater odds of having suicidal
thoughts and attempts compared to LGB people who were not subject to conversion
According to the American Psychological Association, “[t]he potential
risks of reparative therapy . . . includ[e] depression, anxiety and self-destructive
from sexual orientation conversion, are outside the scope of this note. As such,I will occasionally use the
terms “beingLGB” or “LGB,” but will remainfaithful to the sources that I relyupon.
3. Timothy Murphy, Redirecting Sexual Orientation: Techniques and Justifications,29J.S
501, 501 (1992).
4. GEOFFREY R. STONE,SEX AND THE CONSTITUTION 214 (2017).
(9th Cir. 2014).
6. After being LGB was removed from the DIAGNOSTIC &STATISTICAL MANUAL OF MENTAL
DISORDERS in 1973, organizations began to oppose sexual orientation discrimination: American
Psychological Association (1975), American Psychiatric Association (1973), American Psychoanalytic
Association (1991), National Association of Social Workers (2000). As such, once common literature on
“psychotherapeutic efforts to change sexual orientation” ceased, and the academy discredited
“approaches to psychotherapy that were not [LGB] affirmative.” AM.PSYCH.ASS’N,Report of the APA
Task Force on Appropriate Therapeutic Responses to Sexual Orientation 12 (2009) [hereinafter APA
7. Conversion therapy is sometimes called “reparative therapy” or “sexual orientation change
efforts” (“SOCE”). For consistency, I will use “conversion therapy,” because that is the term most
widely used. Conversion therapy includes “talk therapy, behavioral (e.g.[,] aversive stimuli), group
therapy or milieu (e.g.[,] ‘retreats or inpatient treatments’ . . .) treatments” to change an individual’s
sexual orientation heterosexual. Jack Drescher et al., The Growing Regulation of Conversion Therapy,
102 J. MED.REG. 7 (2016).
8. Pickup, 728 F.3d at 1048.
9. Id. at 1048–49.
10. MOVEMENT ADVANCEMENT PROJECT, LGBT POLICY SPOTLIGHT:CONVERSION THERAPY BANS
(July 2017), https://www.lgbtmap.org/file/policy-spotlight-conversion-therapy-bans.pdf.
11. Pickup, 728 F.3d at 1049.
12. Press Release, Williams Institute at UCLA School of Law, LGB People Who Have Undergone
Conversion Therapy Almost Twice as Likely to Attempt Suicide (June 15, 2020), https://williamsinstitute.
252 THE GEORGETOWN JOURNAL OF GENDER AND THE LAW [Vol. XXII:251