In the Name of Safety:
How Homosexual Activists are Using Anti-Bullying Policies to Gain Acceptance

Family North Carolina Magazine—Mar/Apr 2008

Imagine a school where teachers are instructed never to assume that students are heterosexual or that they have heterosexual parents, where teachers are not required to notify parents before introducing subjects related to homosexual relationships or transgenderism, and where students are allowed to choose their own “gender identity” when deciding how to dress, or which bathroom or shower to use. Now consider that all of this is done in the name of promoting tolerance and safety. If you think this scenario sounds far-fetched, think again:

• In the UK, the Department of Children, Schools and Families recently commissioned a homosexual advocacy group to write guidelines for school administrators, teachers and staff on “how to prevent homophobic bullying.” The guidelines instruct educators not “to assume that all pupils in a class are, or will be, heterosexual,” and “to ensure that boys who are openly gay are given appropriate support and understand that there is nothing wrong with them being gay.”¹
  
• A new law in California defines gender in the state’s public education laws as including “a person’s gender identity and gender-related appearance and behavior whether or not stereotypically associated with the person’s assigned sex at birth.”²
  
• Also in California, the Los Angeles Unified School District has a policy that instructs teachers to: address students “by a name and pronoun that corresponds to the gender identity” they consistently use at school, allow transgender students to dress according to the gender they choose, and allow transgender students to use the restroom that corresponds to their gender identity. In addition, the school is instructed to keep a “student’s transgender status private” from parents.³
  
• In Massachusetts, two families who objected to the use of several pro-homosexual books (King and King, Molly’s Family and Who’s in a Family?) at their children’s elementary school and requested that they be notified about similar materials in the future were told by the school district’s superintendent that they would not be notified about “discussions, activities or materials that simply reference same-gender parents or that otherwise recognize the existence of differences in sexual orientation.” A federal appeals court recently upheld the school district’s action.
  

These examples are largely the result of a successful campaign by homosexual advocacy groups to gain access to students under the guise of promoting student safety. At the national, state and local levels, homosexual advocacy groups are using the issue of student safety to pressure school systems into adopting anti-bullying policies that include “sexual orientation” and “gender identity/expression.” The ultimate goal of these policies is to promote the acceptance of homosexuality, bisexuality and transgenderism among school children.⁴

History of Pro-Homosexual Safe Schools Initiative
The effort to get schools to adopt pro-homosexual anti-bullying policies is part of a national initiative by homosexual advocacy groups to get “comprehensive” safe schools laws enacted in every state. The leading group behind the effort is the Gay, Lesbian and Straight Education Network (GSLEN), which defines comprehensive safe schools laws as “statewide anti-harassment and/or non-discrimination laws that are inclusive of the categories of sexual orientation and/or gender identity/expression.”⁵ GLSEN was founded in 1995 by Kevin Jennings, a former Winston-Salem, North Carolina schoolteacher who is open about his homosexuality. For Jennings, ending what he perceives to be discrimination against “LGBT” (lesbian, gay, bisexual and transgender) students and teachers is a personal mission.

As the fifth and youngest child of a part-time Baptist preacher who died when he was eight, Jennings was raised by his mother, and spent much of his life in poverty in North Carolina. In his 2006 memoir, Mama’s Boy, Preacher’s Son, he writes about the painful rejection he experienced as a child from his father, his older brothers, and his peers, noting that “there was never a time when I felt like I was a normal boy.”⁶ Throughout his school years, Jennings was the victim of name-calling, taunting, and bullying at school.⁷

He went on to graduate from Harvard, and became a popular teacher—first at a public school in North Carolina and later in Massachusetts. While teaching at Concord Academy, a private school in Massachusetts, Jennings “came out” as a homosexual to his students, helped organize the nation’s first homosexual student club, and began actively pushing for pro-homosexual non-discrimination policies for both students and teachers. Jennings left the school in 1993, after increasing confrontations with the school’s administration. During his final speech at a school chapel in 1993, Jennings described his vision for America: “I yearn for the day when it won’t matter that I am gay. I yearn for the day when I can walk down the street with my partner and feel safe. I yearn for the day when I will feel like I really belong.”⁸

Massachusetts—While he was still teaching at Concord, Jennings helped start the nation’s first state-funded safe schools program in Massachusetts in 1993.⁹ Titled “The Safe Schools Program for Gay and Lesbian Students,” it includes four components: policies that protect homosexual students from harassment, violence and discrimination; violence prevention and suicide prevention training for school personnel; school-based support groups for homosexual students; and school-based counseling for family members of homosexual students, which Jennings describes as counseling to help families “adjust to the fact that their kid is gay rather than trying to convince the kid ‘it was just a phase.’”¹⁰ As part of the safe schools program, the state education department provides funding to establish homosexual student clubs, known as Gay Straight Alliances (GSAs), in secondary schools throughout the state.¹¹

Since 1995, GLSEN has helped to enact pro-homosexual safe schools laws in nine other states. According to GLSEN, 10 states currently have safe schools laws that specifically enumerate “sexual orientation” as a protected category (California, Connecticut, Iowa, Maine, Massachusetts, Minnesota, New Jersey, Vermont, Washington, and Wisconsin). Five of these states (California, Iowa, Maine, Minnesota and New Jersey) also include the category of “gender expression.”¹²

Presenting LGBT Students as Victims
A key strategy of the homosexual rights movement is to present homosexuals as victims in need of special protections (see sidebar). The victim strategy has proven successful in their efforts to infiltrate the education system, such as in Massachusetts.

During a speech in 1995, Jennings explained how he and his allies used the safety issue in Massachusetts to their advantage: “In Massachusetts, the effective reframing of this issue was key to the success of the Governor’s Commission on Gay and Lesbian Youth. We immediately seized upon the opponent’s calling card—safety—and explained how homophobia represents a threat to students’ safety by creating a climate where violence, name-calling, health problems and suicide are common. Titling our report, ‘Making Schools Safe for Gay and Lesbian Youth,’ we automatically threw our opponents onto the defensive and stole their best line of attack.”¹³

In pushing for inclusive anti-bullying/harassment policies, GLSEN argues that LGBT students are disproportionately targeted in school by bullying and name-calling. For evidence, they point to surveys—often commissioned by homosexual advocacy groups—that supposedly reveal an “epidemic” of violence and harassment against LGBT students. GLSEN’s “2005 National School Climate Survey” found that 37.8 percent of students reported physical harassment at school because of their sexual orientation, followed by 26.1 percent because of their gender identity.¹⁴

GSLEN also helps to organize events in schools that help to reinforce the idea that LGBT students are victims, such as the annual “Day of Silence,” which is held in April. During the “Day of Silence,” LGBT students and their allies remain silent throughout the school day to protest discrimination, bullying and harassment of LGBT students.¹⁵

Targeting North Carolina
North Carolina is one of several states where advocacy groups are hard at work to convince schools to enact pro-homosexual anti-bullying policies. During the 2007 legislative session, Representative Rick Glazier (D-Cumberland) introduced a bill that on its face would outlaw bullying and harassment in North Carolina’s public schools but in reality would promote homosexuality and gender confusion in the classroom. House Bill 1366-School Violence Prevention Act would direct local school boards to adopt policies to prohibit bullying or harassing behavior of students or school employees in the state’s public schools. In its definition of bullying, the bill included a list of a dozen specially protected categories, including “actual or perceived . . . sexual orientation and gender identity or expression.”¹⁶ HB 1366 passed the House in 2007 with this language intact, but it was later removed by the Senate. The Senate version is now pending in the House awaiting acceptance or rejection by that body when they return in May 2008.

A similar attempt to get “sexual orientation” and “gender identity or expression” added to local school anti-bullying policies failed in 2004. That summer, the State Board of Education considered a policy that would have required all local boards of education in North Carolina to implement anti-bullying policies that included special protections for 16 specific characteristics, including “sexual orientation” and “gender identity/expression.” After public outcry over the issue, the board voted to omit the 16 characteristics and approved a more general anti-bullying policy that did not include enumerated categories of victims.¹⁷

Efforts are also being made at the local level. Recently, the Charlotte-Mecklenburg School Board considered adopting an anti-bullying policy that includes the categories of “sexual orientation” and “gender identity or expression.”¹⁸

Safe Schools NC is one of several homosexual advocacy groups behind efforts to get schools to adopt pro-homosexual anti-bullying policies in North Carolina. The group describes itself as “a statewide partnership of organizations and individuals dedicated to eliminating bullying, harassment, and discrimination on the basis of actual or perceived sexual orientation and gender identity in North Carolina’s schools.”¹⁹

Safe Schools NC recently issued findings from a 2006 survey of students at Durham, Orange and Wake County high schools with “active” homosexual student clubs.²⁰ The survey found that 68.9 percent of students said they frequently or often heard expressions like “that’s so gay” or “you’re so gay” at their school, and nearly two-thirds said they frequently or often heard remarks such as “dyke” or “queer.”²¹ Safe Schools NC is using the survey, which is titled, “Homophobic Language and Verbal Harassment in North Carolina’s High Schools,” to pressure school systems across the state into adopting pro-homosexual safe schools policies.²²

Defining the Terms
Getting the terms “sexual orientation” and “gender identity/expression” added to school anti-bullying policies is a key objective of GLSEN and Safe Schools NC. In fact, they will accept nothing less, rejecting more general anti-bullying policies or laws aimed at protecting all students. According to GLSEN, “without specifically enumerating sexual orientation and gender identity as protected categories, many school officials may continue to believe that they do not have a responsibility to respond to anti-LGBT harassment.”²³

The definitions of “sexual orientation” and “gender identity/expression” are important to them because the behaviors for which these terms stand will be presented to students as normal. Interestingly, these terms are not defined in North Carolina law, nor are they defined in HB1366.²⁴ So how does GLSEN define these terms? In a 2001 article for educators, “The Language of Gender,” GLSEN includes the following definitions:

• Sexual Orientation—“The structure of our romantic, sexual, and/or emotional attractions. Some of the better-known categories include ‘heterosexual’ (or ‘straight’), ‘homosexual,’ (or ‘gay’ or ‘lesbian’), or ‘bisexual.’”
  
• Gender Identity—“An individual’s innermost sense of self as ‘male/masculine’ or ‘female/feminine,’ somewhere in between, or somewhere outside of these gender boundaries. Sometimes this ‘innermost sense’ does not correspond with anatomy (e.g. a person born anatomically male, but who identifies as female).”
  
• Gender expression—“Refers to the ways in which people externally communicate their gender identity to others through behavior, clothing, hairstyle, voice and emphasizing, de-emphasizing or changing their body’s characteristics. Gender expression is not necessarily an indication of sexual orientation.”²⁵
  

Based on these definitions, the “sexual orientation” category provides special protections to students and teachers who identify as homosexual or bisexual. The “gender identity/expression” category provides special protections to transgender students or staff, such as the “right” to express themselves as male or female, regardless of their biological sex, through changes to their appearance and voice. In addition, it raises the possibility that a transgender individual who is biologically male but identifies as female could claim that he is being bullied simply because another student or teacher refers to him as “male.”

Pro-Homosexual Anti-Bullying Policies
An in-depth look at what pro-homosexual anti-bullying policies encompass is key to understanding why they pose a significant threat to students. Once a pro-homosexual anti-bullying policy is in place, the school system will be required to implement various components, including teacher training and student awareness of the policy.

Teacher Training—HB 1366 instructs local school systems to provide training for teachers and staff about their anti-bullying policy.²⁶ So who will train teachers to comply with a pro-homosexual anti-bullying policy? At least some of these trainings will be presented by pro-homosexual activists and/or their allies.

Safe Schools NC recommends that schools provide training for personnel to “raise awareness about issues relevant to sexual orientation and gender identity/expression,” which it suggests be provided by organizations such as itself, the ACLU, or GLSEN. According to Safe Schools NC, these trainings should “raise awareness of the impact of homophobic language and harassment based upon sexual orientation, gender identity or gender expression, increase knowledge of legal issues related to sexual orientation, gender identity, and gender expression and school settings ... and provide access to local and national resources for school personnel to assist students in dealing with issues of sexual orientation, gender identity and gender expression.”²⁷

Student Awareness—Anti-bullying programs also require that students be educated about the policy, and why it is wrong to bully or harass their peers with special emphasis on certain groups that are bullied. For example, under HB 1366, schools would be required to incorporate awareness of their anti-bullying policies into character education, citizenship and civility classes/lessons.²⁸ The problem is that under a pro-homosexual anti-bullying policy, students will also be taught about homosexuality, bisexuality and transgenderism in a way that promotes these behaviors as normal. Homosexual advocacy groups define a safe learning environment as one that is inclusive of LGBT issues. For example, the National Gay and Lesbian Task Force (NGLTF) states that integrating LGBT issues into the curriculum “reduces the alienation felt by LGBT students who do not see themselves reflected in school materials.”²⁹

Safe School NC recommends that schools “include resources that pertain to issues of sexual orientation and gender identity alongside other resources that are provided to students.” What kind of resources? The group suggests: providing students with lists of pro-homosexual organizations and their contact information (such as GLSEN, Lambda Youth OUTreach, and Parents and Friends of Lesbians and Gays, or PFLAG); stocking school libraries with books that address sexual orientation, gender identity and gender expression; and making available to students information pamphlets and other materials on LGBT issues.³⁰

What’s the Harm?
Adding “sexual orientation” and “gender identity/expression” to school anti-bullying policies opens the door for homosexual activists to influence what children learn about sex and gender. While GLSEN and its allies may claim that the goal is to promote safety and tolerance in the classroom, their agenda includes teaching children that homosexuality is normal, and that gender is a fluid concept. In addition, while homosexual activists may preach tolerance, their goal is to silence anyone who does not affirm their lifestyle—an obvious breach of First Amendment rights.

Sexual and Gender Confusion—As discussed, pro-homosexual anti-bullying policies involve student awareness and support, and this information is often provided to schools and students by local, state and national LGBT organizations that convey harmful messages about sexuality and gender.

In 2003, Time Out Youth, a homosexual youth group in Charlotte, attempted to rent five billboards from Adams Outdoor Advertising that featured the slogan, “It’s OK to be Gay.” The advertising firm turned down their request, pointing out that the slogan would be offensive to many parents.³¹ The simple slogan sums up the main message homosexual advocacy groups want to convey to youth.

A PFLAG brochure for adolescents has a similar message: “It is okay to be gay, lesbian, bisexual or transgender ... Not only is it as natural, it’s as healthy to be gay, lesbian and bisexual as it is to be straight—no matter what some people might tell you.”³²

Teaching students that homosexuality is acceptable or as “natural” as heterosexuality is not only erroneous, but also dangerous. Homosexuality among men is associated with higher risk sexual behaviors, such as anal sex, group sex, the use of “party” drugs, and a higher number of lifetime sexual partners. Furthermore, the Centers for Disease Control and Prevention (CDC) reports an alarming increase in these activities among men who have sex with men (MSM) in recent years. MSM in particular are at an increased risk of physical damage (from anal intercourse), anal cancer, and a number of sexually transmitted diseases, ranging from gonorrhea and syphilis to HIV/AIDS. While there is less known about the risks of female homosexuality, lesbians are at risk for a number of STDs that can be transmitted through skin-to-skin contact, such as HPV and Herpes, and certain cancers are more common among lesbians, including breast cancer. In addition, the Gay and Lesbian Medical Association reports that homosexual men and women are at an increased risk for drug and alcohol abuse and depression.³³

Homosexual activists and their allies also envision a gender-neutral society where being male or female is determined by feelings, not birth. For example, a GLSEN article for educators states: “gender is not intrinsically tied to a person’s biological sex” and “our biological maleness or femaleness does not naturally determine to whom we are attracted, and our sexual attractions do not naturally indicate whether we are male or female.”³⁴

The same article warns educators not to view terms associated with gender as “fixed or definitive,” stating: “Since gender is a social construction, the terms we use to describe it are ever-changing and can never reflect the complex identities of all members of the LGBT and other communities ... We must take care, then, to not impose these labels on others, but to always allow people to identify themselves how and when they wish, and to always respect those who choose not to label themselves at all.”³⁵

In the UK, government-commissioned guidelines on ending homophobic bullying advise teachers to “challenge ideas about how boys and girls should behave and take care not to reinforce stereotypes. Accepting a range of behaviors in boys is key to preventing homophobic bullying.³⁶”

This gender confusion not only promotes transgender behavior but is also linked to the acceptance of homosexuality. If gender is interchangeable, then how can there be anything wrong with a sexual relationship between two people of the same sex?

Silencing the Opposition—Across the nation, students with deeply held religious beliefs about homosexuality have been censored by school officials, all in the name of promoting tolerance and safety for LGBT students. Consider the following examples:

In December 2007, a district judge ruled that school officials at Neuqua Valley High School in Illinois had the right to prevent a student from wearing a t-shirt to school that read, “Be Happy, Not Gay.” U.S. District Judge William T. Hart wrote in his ruling that, “School officials may prohibit a public high school student from displaying negative statements about a category of persons, including homosexuals, that are inconsistent with the school’s educational goal of promoting tolerance.” The ruling is being appealed.³⁷

In North Carolina, Benjamin Arthurs, a student at Midway High School in Dunn was suspended in April 2006 for attempting to participate in the “Day of Truth,” an annual event sponsored by the Alliance Defense Fund (ADF) that counters the pro-homosexual “Day of Silence.” Benjamin was told that he could not wear a religious shirt or distribute “Day of Truth” message cards, even though the day before, other students were allowed to participate in the “Day of Silence.” The superintendent of schools argued that Benjamin was “pushing his religion on others” and that “religion is not allowed in school.” ADF filed a lawsuit against the school district, and the district has since revised its policy regarding religious speech, and agreed to allow students to observe the “Day of Truth.”³⁸

In a similar case in Boone, N.C., Mark Austin was suspended from Watauga High School in April 2004 for refusing to remove a t-shirt he designed to protest the observance of the pro-homosexual “Day of Silence” at his school. School officials said Mark’s shirt was “offensive” because it featured the words: “Homosexuality is sin,” “Hell is REAL,” and “Jesus is the Answer” on the front, and “Shout for Joy” on the back.³⁹

Pro-homosexual anti-bullying policies increase the possibility that the religious and free speech rights of more students will be squelched in the name of keeping LGBT students safe. Will it be considered “bullying” to state that homosexuality is a sin according to the Bible? Will Christian students who attempt to witness to their LGBT peers be accused of “harassment?” Will parents be free to protest the pro-homosexual nature of an anti-bullying program without being portrayed as bigots?

A Better Way
Homosexual activists are right about one thing—bullying is a serious problem in schools today. While bullying has always been a part of school life, there are signs that it is more common and malicious than ever before. According to a 2002 survey of students in grades K-12 by the Families and Work Institute, 32 percent reported being the victim of bullying at least once in the past month, and 12 percent said they had been bullied five times or more during the same time period.⁴⁰ Another 2002 study by the U.S. Secret Service determined that bullying had played a role in many school shootings.⁴¹

Although bullying is a legitimate concern for schools, it is wrong to use the issue of student safety to promote a social agenda, and that is exactly what GLSEN and its allies are doing. Teaching children to respect one another, regardless of differences, does not require the acceptance of homosexuality, bisexuality or transgenderism. In fact, the N.C. General Assembly already requires public schools to teach character education including traits such as kindness and respect.

According to Brenda High, the founder and co-director of Bully Policy, U.S.A., there is a more effective way to stop bullying. Brenda’s youngest son, Jared, committed suicide in 1998, after being brutally beaten by a school bully months earlier. Jared was a victim of bullying most of his life, and he became depressed and suicidal as a result. Just a few days after his 13th birthday, he shot himself while he was on the phone with his father.⁴²

Brenda has been involved in the successful passage of anti-bullying laws in several states, but she does not believe that anti-bullying laws should include enumerated categories of victims. On her web site, she argues that “defining victims will slow the process of lawmaking, dividing political parties who will argue over which victims get special rights over other victims.”⁴³

In a recent interview on the North Carolina Family Policy Council’s weekly radio program (see page 28), Brenda explained why she opposes the enumeration of victims in anti-bullying laws. “Adding the protective language for victims to a law, or what I call inclusive language, assumes that having the ‘wrong’ attitude about sexual orientation and gender identity will increase one’s likelihood of being a bully or harasser,” she said. “Bullies bully because they can and because they get away with it. All that needs to be done to stop bullying is to stop the behavior of these bullies. It’s as simple as that.”⁴⁴

“What kids need to learn to do is respect one another, not to particularly like someone,” Brenda continued. “We as a nation are putting too much emphasis on solving the bullying problem by looking at victims and defining what they do. We need to look at the bully, and what they are doing.”⁴⁵

Protecting Every Child
It is not necessary to teach students “It’s OK to be gay” in order to teach them that it is wrong to bully LGBT students. Children in North Carolina should be taught to respect their peers, regardless of differences, or disagreements over beliefs. Any child can be a victim of bullying, so every child deserves protection. Rather than arguing over which categories of victims deserve the most protection from bullying, North Carolina lawmakers and educators should focus on partnering with parents to teach values that everyone can embrace, such as respect and compassion for our fellow human beings.

Alysse ElHage is Senior Research Associate for the North Carolina Family Policy Council.

Endnotes

1 UK Department of Children, Schools and Families, Safe to Learn: Embedding Anti-Bullying Work in Schools—Preventing and Responding to Homophobic Bullying in Schools, 2007, pgs. 7 & 131, http://www.teachernet.gov.uk/wholeschool/behaviour/tacklingbullying/homophobicbullying/

2 Equality California, Fact Sheet: Student Civil Rights Act (SB 777), pg. 2, www.eqca.org.

3 Los Angeles Unified School District, “Transgender and Gender Nonconforming Students—Ensuring Equity and Nondiscrimination,” REF-1557, Office of the General Counsel, 2/15/05.

4 PENDING

5 GSLEN, State of the States, 2004: A Policy Analysis of Lesbian, Gay, Bisexual and Transgender Safer Schools Laws, 2004, pg. 6.

6 Jennings, Kevin, Mama’s Boy, Preacher’s Son: A Memoir, Boston: Beacon Press, (2007), pg. xii.

7 Ibid. pgs. 202-208 (see pg. 205 in particular).

8 Ibid. pg. 209.

9 Ibid. pg. 202.
                                                                                                                                                                                                                                         11 10 Ibid. pg. 200.

11 Cianciotto, Jason and Sean Cahill, Education Policy: Issues Affecting Lesbian, Gay, Bisexual and Transgender Youth, National Gay and Lesbian Task Force, 2003, pg. 57-58.

12 GLSEN, “GLSEN Hails Signing of Comprehensive Safe Schools Bill in Iowa,” Press Release, 3/5/07.

13 Quoted in: Citizens for Community Values, The Legal Liability Associated With Homosexuality Education in Public Schools, Special Report, 2002, pg. 1, www.ccv.org.

14 GSLEN, “GLSEN’s 2005 National School Climate Survey Sheds New Light on Experiences of LGBT Students,” Press Release, 4/26/06.

15 See: http://www.dayofsilence.org/index.html

16 NC General Assembly, HB 1366-School Violence Prevention Act,” 2007 session.

17 NCFPC, “State Board Removes Sexual Orientation From Bullying Policy,” Family Policy Facts, 7/2/2004. Board Policy at: http://sbepolicy.dpi.state.nc.us/

18 Helms, Ann Doss, “Gorman: Let’s Do More on Bullying,” Charlotte Observer, 1/30/08.

19 Safe Schools NC, “Homophobic Language and Verbal Harassment in North Carolina High Schools,” 2006, pg. 2, www.safeschoolsnc.com.

20 Ibid. pg. 6.

21 Ibid. pg. 8.

22 Ibid. pg. 17-20.

23 GSLEN and National Center for Lesbian Rights, “Frequently Asked Questions on Safe Schools Policies,” www.glsen.org.

24 Op. Cit. HB 1366.

25 Siragusa, Nicolette, “The Language of Gender: A Discussion and Vocabulary List for Educators on Gender Identity,” GLSEN Education Department, 2001, pg. 1&3.

26 Op. Cit., HB 1366.

27 Op. Cit. Safe Schools NC, pg. 17.

28 HB 1366

29 National Gay and Lesbian Task Force, Education Policy: Issues Affecting Lesbian, Gay, Bisexual, and Transgender Youth, NGLTF Policy Institute, 2003, pg. 55.

30 Op. Cit. Safe Schools NC, pg. 19.

31 NCFCP, “Homosexual Group’s Message Rejected,” Family Policy Facts, 8/15/03.

32 PFLAG, “Be Yourself: Questions and Answers for Gay, Lesbian, Bisexual and Transgender Youth,” 1999/2002, pgs. 4&7.

33 ElHage, Alysse, "The Physical Health Risks of Homosexuality," Family North Carolina, Spotlight Article, July/August 2007, http:ncfamily.org/familync/familync200707.html.

34 Op. Cit., Siragusa, Nicolette (GLSEN, “The Language of Gender”), pg. 2.

35 Ibid., pg. 2.

36 PENDING

37 GLSEN, “Judge Rules in Favor of Tolerance, Denies Student’s Request to Wear ‘Be Happy, Not Gay,’” Press Release, 1/7/08.

38 Alliance Defense Fund, “ADF Attorneys Seek Justice for High School Student Silenced on the Day of Truth,” 8/28/06.

39 Zeigher, Hans, “Silenced on the Day of Silence,” WorldNetDaily.com, 4/22/04, www.worldnetdaily.com/news/article/asp?ARTICLE_ID=38160.

40 Ferrell-Smith, Finessa, “Tackling the Schoolyard Bully: Combining Policy Making With Prevention,” National Center for , 2008, pg. 1.

41 Ibid.

42 Bully Police USA, “About Brenda High,” http://www.bullypolice.org/brenda.html.

43 High, Brenda “Making the Grade,” Bully Police USA, http://www.bullypolice.org/grade.html.

44 Transcript of radio interview with Brenda High on “Family Policy Matters” radio show, January 2008.

45 Ibid.