Student Opposition to Affirmative Action Policies in Higher Education

by Grace Campagna

Affirmative action programs and policies in higher education have been divisive since their inception in the 1960s. Supporters have highlighted the positive effects of diverse student bodies and praised efforts to give preference to underrepresented groups and victims of systematic discrimination. Opponents often advocate for “colorblind” approaches to college admissions that value merit without regard to past discrimination or current socioeconomic contexts. Both claim to value equality and fairness yet interpret and apply those terms differently.1Moses, Michele S. Living with Moral Disagreement: The Enduring Controversy about Affirmative Action. The University of Chicago Press, 2016, 27. This is one reason that the debate over affirmative action has been so intense and complex. Students have consistently taken active roles in this process, from the 1960s protests that helped start the programs to lawsuits over rejected applications.

The most recent challenge to affirmative action policies in higher education was the high-profile case in which Students for Fair Admissions sued Harvard University over the school’s use of race in admissions decisions. The group believes that “racial classifications and preferences in college admissions are unfair, unnecessary, and unconstitutional” and that Harvard uses such policies to consistently discriminate against Asian American applicants.2“About.” Students for Fair Admissions, https://studentsforfairadmissions.org/about/. In October 2019, U.S. District Judge Allison D. Burroughs ruled in Harvard’s favor, citing a lack of evidence that the university’s policies negatively impact the chances of Asian-American applicants3.Griffith, Janelle. “Judge Rules in Favor of Harvard in Affirmative Action Case.” NBCNews.com. NBCUniversal News Group, October 1, 2019. https://www.nbcnews.com/news/us-news/judge-rules-favor-harvard-affirmative-action-case-n1060921. While this case is not the first to question policies that take race into account, it is unique in asserting that a school’s affirmative action policies are harming minorities. This case, and similar lawsuits against the University of North Carolina-Chapel Hill and the University of Texas at Austin (the plaintiff in both cases is Students for Fair Admissions) complicate a history of primarily white student opposition to affirmative action. Other high-profile cases that challenged the use of race in admissions (Regents of the University of California v. Bakke (1978), Gratz v. Bollinger (2003), Grutter v. Bollinger (2003), and Fisher v. University of Texas (2013)) alleged that race-conscious policies harmed white students. While the Harvard case includes white students in the case, the primary focus has been discrimination against Asian-Americans. 

Students for Fair Admissions brought its lawsuit under Title VI of the Civil Rights Act of 1964 which “prohibits discrimination on the basis of race, color, and national origin.”4Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d, et seq. The organization claims that Harvard’s policies contradict American principles of equality, promote “racial balancing” in the form of predetermined racial percentages, use race as a primary factor in admissions decisions, and do not fulfill the school’s goal of creating a diverse student body.5Students for Fair Admissions, Inc., Plaintiff, v. President and Fellows of Harvard College (Harvard Corporation); and The Honorable and Reverend the Board of Overseers, Defendants., 1:2014cv14176. In Understanding Affirmative Action: Politics, Discrimination, and the Search for Justice, J. Edward Kellough presents a synthesis of the five key and most common arguments against affirmative action.6Kellough, J. Edward. Understanding Affirmative Action: Politics, Discrimination, and the Search for Justice. Georgetown University Press, 2008, 83-91. The complaint against Harvard makes use of three of them, demonstrating that, while the case is unique, the arguments are not. The plaintiff and Asian American students involved in the Harvard case use many of the same arguments that others have traditionally used to support white interests in order to support those of Asian American students. Recent cases that accuse universities of using race-conscious admissions policies to discriminate against Asian-American applicants demonstrate that student opposition to affirmative action extends beyond the white student population. It is when students view affirmative action policies, or those they seek to benefit, as a threat to their chances of admission or position on campus that they take action against those policies. 

Student opposition to affirmative action programs began as soon as universities began to implement them in the 1960s. During that period, backlash centered around the idea that programs to help minority students “upset a meritocratic order that many Americans had come to believe helped create postwar prosperity and improved social relations.”7Deslippe, Dennis. Protesting Affirmative Action: The Struggle over Equality after The Civil Rights Revolution. Baltimore: Johns Hopkins University Press, 2014, 52. Supporters of this meritocracy argued that affirmative action programs impeded the education of the most talented students and that race and gender should not be factors in admissions decisions. The implementation of some programs occasionally prompted violent backlash against minority students. In 1969, “white students, shouting racial epithets, pursued black and Puerto Rican” CUNY students who had been protesting admissions policies.8Deslippe, Dennis. Protesting Affirmative Action: The Struggle over Equality after The Civil Rights Revolution, 69. In this case, it was white students who opposed affirmative action programs because they viewed an increased population of minority students as a threat to their privileged position on campus (in 1969, around 80% of CUNY’s student body was white) and the admission chances of other white students.9Deslippe, Dennis. Protesting Affirmative Action: The Struggle over Equality after The Civil Rights Revolution, 62.

A decade later, the Supreme Court upheld the use of race-conscious admissions policies in Regents of the University of California v. Bakke (1978). Allan Bakke sued the University of California after the school denied his application to medical school twice. He argued that the University’s special admissions program, which evaluated minority candidates separately from the general application pool, violated Title VI of the Civil Rights Act of 1964 and the Equal Protection Clause.10Regents of the University of California v. Bakke, 438 U. S. 265 (1978), 266. The school reserved sixteen out of one hundred spaces in the class for students from minority and disadvantaged groups. Bakke believed that the university admitted less qualified students than himself in an effort to fill those sixteen spaces, which resulted in his rejection. In a 5-4 decision, the Court struck down the special admissions policy and the use of race as the sole determining factor in admissions decisions (i.e. quotas). However, it upheld race as a partial factor in admissions decisions in order to remedy past discrimination and disadvantage, as long as the university used race as only one of many points of consideration. This case illustrates the idea that student opposition to affirmative action oftentimes stems from a feeling of victimization. Bakke believed that the admission of minority students directly influenced his rejection and that, had the university not chosen to reserve the sixteen seats, they would have admitted him.11Horn, Catherine L., and Patricia Marin. “Realizing the Legacy of Bakke.” In Realizing Bakke’s Legacy: Affirmative Action, Equal Opportunity, and Access to Higher Education, edited by Catherine L. Horn and Patricia Marin, Stylus Publishing, LLC., 2008, pp. 1–14, 2. 

A similar process was at work in the Gratz v. Bollinger (2003), Grutter v. Bollinger (2003), and Fisher v. University of Texas (2013) cases. In each one, white plaintiffs challenged university affirmative action policies over rejected applications. Rather than stemming from a dislike of minority students or a commitment to equality, the students’ opposition was the result of a negative personal experience. This assertion is consistent with previous studies that have identified a correlation between support for affirmative action and self-interest. Those that will not benefit from the policy will be less likely to support it.12Sax, Linda J., and Marisol Arredondo. “Student Attitudes toward Affirmative Action in College Admissions.” Research in Higher Education 40, no. 4 (1999): 439-59, 452. For some students, diversity on college campuses is admirable until it comes at a perceived personal cost.  

Understanding student opposition to affirmative action through the language of personal victimization and threat does not provide an all-encompassing framework with which to approach this complex issue. However, it does help to contextualize a few of the prominent examples, explain the motivations behind some of the individuals involved, and provide one possible explanation for minority opposition to affirmative action in the Harvard case. Although both student and public opinions on affirmative action change regularly in reaction to new developments, college students may approach the issue differently than the general public because of their personal stake in the matter. Further research into how students have formed opinions, which factors influenced their viewpoints, and how they differed from the general public will help shed light on student positions over time and how their current states came to be. 

Bibliography 

“About.” Students for Fair Admissions, https://studentsforfairadmissions.org/about/.

Deslippe, Dennis. Protesting Affirmative Action: The Struggle over Equality after The Civil Rights Revolution. Baltimore: Johns Hopkins University Press, 2014.

Griffith, Janelle. “Judge Rules in Favor of Harvard in Affirmative Action Case.” NBCNews.com

NBCUniversal News Group, October 1, 2019. https://www.nbcnews.com/news/us-news/judge-rules-favor-harvard-affirmative-action-case-n1060921.

Horn, Catherine L., and Patricia Marin. “Realizing the Legacy of Bakke.” In Realizing Bakke’s Legacy: Affirmative Action, Equal Opportunity, and Access to Higher Education, edited by Catherine L. Horn and Patricia Marin, Stylus Publishing, LLC., 2008, pp. 1–14.

Jacobson, Cardell K. “The Bakke Decision: White Reactions to the U.S. Supreme Court’s Test of Affirmative Action Programs.” Journal of Conflict Resolution 27, no. 4 (December 1983): 687–705. https://doi.org/10.1177/0022002783027004007.

Kellough, J. Edward. Understanding Affirmative Action: Politics, Discrimination, and the Search for Justice. Georgetown University Press, 2008.

Moses, Michele S. Living with Moral Disagreement: The Enduring Controversy about Affirmative Action. The University of Chicago Press, 2016.

Regents of the University of California v. Bakke, 438 U. S. 265 (1978).

Sax, Linda J., and Marisol Arredondo. “Student Attitudes toward Affirmative Action in College Admissions.” Research in Higher Education 40, no. 4 (1999): 439-59.

Schmidt, Peter. Color and Money: How Rich White Kids Are Winning the War over College Affirmative Action. New York, NY: Palgrave Macmillan, 2007.

Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d, et seq.

Almost 100 years after Harvard expelled students for their sexuality, are universities doing enough to welcome and protect LGBTQ students?

by Grace Campagna 

Until 2015, Baylor University listed homosexuality as a punishable offense under its sexual misconduct policy. LGBTQ students could not publicly display affection for their partners and could face disciplinary procedures for engaging in “homosexual acts.”1“Sexual Misconduct BU-PP 031.” Baylor University, 2007. The university has also consistently refused to grant official recognition to LGBTQ groups on campus and allowed instances of discrimination to go unaddressed.2Retta, Mary. “These LGBTQ Students Say Their School Treats Them Like Second-Class Citizens.” The Nation. The Nation Company , December 2, 2019. https://www.thenation.com/article/christian-university/. Although perhaps an extreme example, the experiences of Baylor students are not unique to the private, Christian university. American universities have a long history of anti-LGBTQ policies and unchecked discrimination. Some attitudes and issues are remnants from the past, while others are new to the 21st century. All are the result of reactive university policies that treat LGBTQ students as problems, a tendency to prioritize the interests of straight and cisgender students, little attention to the specific needs of LGBTQ students, and a lack of comprehensive federal regulations designed to protect students in all forms of higher education.3This blog post uses the term “LGBTQ” to refer to anyone who does not identify as heterosexual and/or cisgender. Although this is a more recent term, the blog also uses it to describe groups of students in the 1920s and 1960s for the sake of consistency.

Hostility towards LGBTQ students is not new. In fact, it used to be much more severe. In 2002, Harvard University student Amit Paley discovered a box of secret files in the school’s archives. After a drawn-out appeal process to achieve their release, the records turned out to be court proceedings from a 1920 university investigation into gay men and their associations at Harvard. The Secret Court files reveal several weeks of interrogations that began after the suicide of a gay student and aimed to expose a gay community at the school. Administrators targeted students that they observed entering specific dorm rooms, frequenting bars and restaurants known to be gay meeting places, and those who did not strictly adhere to masculine gender norms in their clothing and behavior. Deliberations by several university officials resulted in the expulsion of seven undergraduates, the termination of several employees, and a second suicide of a gay student.4Wright, William. Harvard’s Secret Court: The Savage 1920 Purge of Campus Homosexuals. New York: St. Martins Press, 2005.

The university’s policies were generally consistent with the popular beliefs about gay men at the time: “While the 1920s became known as a period of sexual liberation, the new freedom was for young women and did not apply to homosexuals.”5Wright, William. Harvard’s Secret Court: The Savage 1920 Purge of Campus Homosexuals, 82. Early twentieth-century officials, doctors, and religious leaders characterized homosexuality as a disease, in addition to a moral problem.6Wright, William. Harvard’s Secret Court: The Savage 1920 Purge of Campus Homosexuals, 29. Harvard officials in the Secret Court case subscribed to this understanding. A dean who wished to “reduce the chances of another outbreak” was instrumental in targeting close friends and roommates of gay students, suggesting he believed homosexuality functioned as a contagious disease.7Wright, William. Harvard’s Secret Court: The Savage 1920 Purge of Campus Homosexuals, 169. The documents also implied that this sort of purge was an unpleasant, but necessary (and not uncommon) task that preserved the safety and integrity of the entire university community. Many officials expressed regret at having to expel the students, but maintained that the well-being of other students and faculty had to come first. Police operations around this time frequently targeted urban gay establishments and meeting places, increasing public wariness of a secretive gay underworld. Much of the early 20th century upper-class acknowledged the existence of the LGBTQ community but, because they viewed homosexuality as a disease and moral problem, believed that its members resided in low-income communities separate from their own and that immoral acts did not occur in their neighborhoods and institutions. This was likely the mindset of university officials who saw Harvard’s gay community as an infestation and a threat to student safety. To deal with a gay “problem” at the school, officials employed policies to remove the offending students as quickly as possible and prevent them from entering other universities. University policies on LGBTQ students did not seek to protect them or ensure a positive college experience. Instead, they only came into play once the students became an issue, thus the term “reactive.” This case illustrates general trends in university attitudes and policies towards LGBTQ students that continue through the 20th century and are still visible today. 

In such a climate of institutional hostility and widespread societal disapproval, most LGBTQ students and campus networks remained hidden until the 1960s, when gay student groups on campuses began to demand the right to organize as the Civil Rights Movement inspired many to fight for their rights. Some of the first official LGBTQ student organizations began in New York City. In 1966, Stephen Donaldson, an openly bisexual student at Columbia University, started the first college LGBTQ advocacy and support organization after the university forced him to move out of his residence hall due to complaints from his roommates about his sexuality.8Beemyn, Brett. “The Silence Is Broken: A History of the First Lesbian, Gay, and Bisexual College Student Groups.” Journal of the History of Sexuality 12, no. 2 (2003): 205-223, 207. The Student Homophile League initially encountered problems when Columbia would not grant official recognition to an organization without a list of members. If the students wanted to have an official group, they would have to provide a list of their names to the administration and risk exposing themselves to harassment and ridicule. After finally granting the group an official charter in 1967, the university faced both internal and external backlash to the decision. Responses ranged from deeming the group unnecessary to accusing its members of promoting “deviant behavior” at the university.9Beemyn, Brett. “The Silence Is Broken: A History of the First Lesbian, Gay, and Bisexual College Student Groups,” 207. 

While these students fared far better than those at Harvard in 1920, several aspects of their case illustrate persistent trends in how universities have approached LGBTQ students. In requiring a list of members, Columbia failed to understand the group’s need for privacy and refused to make an exception to their rules that would have allowed a disadvantaged community to create a space that met their needs. Although Donaldson founded the Student Homophile League after several initial civil rights victories, the organization predated the gay liberation movement, which promoted more widespread visibility of the LGBTQ community and its needs. Before this movement, universities had no incentives to attract LGBTQ students or give them adequate space on campus. In recent decades, however, universities began to see the advantages of having a visible LGBTQ student population as appearing diverse became a priority. Today, many colleges and universities actively recruit LGBTQ students through targeted marketing and advertising the presence of dedicated student groups.10Cegler, Tyler D. “Targeted Recruitment of GLBT Students by Colleges and Universities.” Journal of College Admission, Spring 2012, 18–23. Early LGBTQ student groups, such as the Student Homophile League at Columbia, paved the way for a multitude of other organizations, such as Gay-Straight Alliances and Pride Alliances, and most campuses now have some form of LGBTQ group. Several online resources keep updated lists of LGBTQ-friendly universities in order to help students identify institutions that will support them.11“Campus Pride Index.” Campus Pride. Accessed December 16, 2019. http://www.campusprideindex.org/search/index.

However, surface recognition of LGBTQ groups is often not enough to sufficiently attract, support, and retain LGBTQ students, many of whom still feel isolated on campus and have poorer academic records than straight students.12Greathouse, Maren, BrckaLorenz, Hoban, Huesman Jr., Rankin, and Bara Stolzenberg. “Queer-Spectrum and Trans-Spectrum Student Experiences in American Higher Education.” Rutgers University, August 2018, 37. Even universities that strive to support their LGBTQ populations often miss key opportunities to respond to the needs of that community and create a more welcoming environment. Harvard includes sexual orientation in its non-discrimination policy, facilitates several LGBTQ-run student and alumni groups (including one specifically for transgender students), and has an Office of BGLTQ Student Life. Despite these resources, the university has denied requests from a student movement to award posthumous degrees to the students it expelled during the investigations of 1920.13“Their Day in the Yard Movement at Harvard.” Their Day in the Yard. Secret Court RSS. Accessed December 11, 2019. http://secretcourt.org/about/. Taking this step would have represented a firm acknowledgement of Harvard’s past mistakes and current support for its LGBTQ community.

The enormous variety of policies also hinders widespread acceptance and support of LGBTQ students. While some schools, such as Grinnell University and Oregon State University, have active LGBTQ populations and a variety of resources to support them, other schools refuse to acknowledge these students as full members of the university population.14“Stonewall Resource Center.” Grinnell College. Accessed December 24, 2019. https://www.grinnell.edu/about/offices-services/intercultural-affairs/src.; “Grinnell College Student Attends Conference on LGBT Issues & Carleton College’s Gender & Sexuality Center.” Grinnell College. Accessed December 24, 2019. https://www.grinnell.edu/news/grinnell-college-student-attends-conference-lgbt-issues-carleton-colleges-gender-sexuality.; Leider, Steven. “OSU Launches New Program to Improve Recruitment, Retention of LGBTQ Students in Science and Engineering Programs.” Life at OSU. Oregon State University , October 8, 2010. https://today.oregonstate.edu/archives/2010/oct/osu-launches-new-program-improve-recruitment-retention-LGBTQ-students-science-and-e. Baylor University’s sexual misconduct policy, which the school updated in 2015, now states that “Baylor will be guided by the biblical understanding that human sexuality is a gift from God and that physical sexual intimacy is to be expressed in the context of marital fidelity.”15“Sexual Conduct BU-PP 031.” Baylor University, 2015. The primary difference between the 2007 and the 2015 policies is the absence of a list of prohibited behaviors. While the revised policy does not explicitly condemn “homosexual acts” as before, its open-ended language leaves plenty of room for interpretation and offers no protection for LGBTQ students who are acting consensually. Baylor is also one of a few universities which continues to refuse recognition to a campus LGBTQ organization. Gamma Alpha Upsilon, in operation since 2011, has requested an official charter every year. As of October 2019, the university had denied each request, citing either biblical motivations or code of conduct violations.16Retta, Mary. “These LGBTQ Students Say Their School Treats Them Like Second-Class Citizens.” The Nation. The Nation Company , December 2, 2019. https://www.thenation.com/article/christian-university/. Baylor’s reactive policies only address LGBTQ students when they have become a problem, instead of working proactively to create an accepting atmosphere. 

State and federal legislation has not played a large role in protecting LGBTQ students because of the variety of types of higher education institutions and their diverse policies. Both Title IX and the Civil Rights Act, which could offer some form of protection from discrimination, offer religious exemptions. Baylor’s 2015 Sexual Conduct policy claims exemptions from both pieces of legislation. More recent attempts to gain federal protections for LGBTQ people have focused on other areas of concern, such as healthcare, housing, and employment, instead of education.17“Full Policy & Legislation List.” National Center for Lesbian Rights, August 23, 2013. http://www.nclrights.org/cases-and-policy/full-policy-and-legislation-list/. Even those pushing for educational reforms often have to restrict their efforts to public elementary and high schools. Gaps in legislation and exemptions available to certain institutions prevent the creation and enforcement of comprehensive non-discrimination policies that protect LGBTQ students and create welcoming environments for them on campuses. As higher education becomes increasingly important for the modern job market, universities have become gatekeepers to social mobility. A lack of consistent and enforceable regulations to protect LGBTQ students restricts access to opportunities for a significant portion of the population. 

At the current moment, it is up to individual universities to determine their approach to LGBTQ students, which comprise approximately 11% of the undergraduate population, according to a 2017 study. LGBTQ students are more likely to face discrimination and violence at college, while at the same time they are less likely to seek help from a campus professional.18Greathouse, Maren, BrckaLorenz, Hoban, Huesman Jr., Rankin, and Bara Stolzenberg. “Queer-Spectrum and Trans-Spectrum Student Experiences in American Higher Education,” 37. Many do not feel valued at their institution: 33% of LGB students surveyed in 2016 said they considered leaving their university, while 38% of transgender students said the same.19Windmeyer, Shane. “The Path Forward: LGBTQ Retention and Academic Success.” INSIGHT Into Diversity, April 15, 2016. https://www.insightintodiversity.com/the-path-forward-LGBTQ-retention-and-academic-success/. Several reports from the last few years provide recommendations to universities to increase their support of LGBTQ students. Suggestions include “forming committees charged with the task of improving the quality of life for LGBTQ students and employees; creating LGBTQ resource centers and safe space programs… [and] establishing LGBTQ-themed residential programs.”20Beemyn, Genny and Sue Rankin. The Lives of Transgender People. New York: Columbia University Press, 2011, 85. Other first steps include hiring more LGBTQ faculty and specialized mental health professionals, collecting data on LGBTQ students, and giving student groups adequate space, funding, and freedom. While many universities have dedicated affirmative action programs to attract, support, and retain women and racial minorities, there are few such initiatives for LGBTQ students. In 2010, Oregon State University launched a “new program designed to attract LGBTQ students to its engineering and sciences programs,” both fields where LGBTQ students are underrepresented.21Leider, Steven. “OSU Launches New Program to Improve Recruitment, Retention of LGBTQ Students in Science and Engineering Programs.” This program, and others like it, are making concrete steps in the right direction to create more inclusive and welcoming institutions of higher education.

Bibliography 

Beemyn, Brett. “The Silence Is Broken: A History of the First Lesbian, Gay, and Bisexual College Student Groups.” Journal of the History of Sexuality 12, no. 2 (2003): 205-223.

Beemyn, Genny and Sue Rankin. The Lives of Transgender People. New York: Columbia University Press, 2011.

“Campus Pride Index.” Campus Pride. Accessed December 16, 2019. http:// www.campusprideindex.org/search/index.

Cegler, Tyler D. “Targeted Recruitment of GLBT Students by Colleges and Universities.” Journal of College Admission, Spring 2012, 18–23.

“Full Policy & Legislation List.” National Center for Lesbian Rights, August 23, 2013. http:// www.nclrights.org/cases-and-policy/full-policy-and-legislation-list/.

Greathouse, Maren, BrckaLorenz, Hoban, Huesman Jr., Rankin, and Bara Stolzenberg. “Queer- Spectrum and Trans-Spectrum Student Experiences in American Higher Education.” Rutgers University, August 2018.

“Grinnell College Student Attends Conference on LGBT Issues & Carleton College’s Gender & Sexuality Center.” Grinnell College. Accessed December 24, 2019. https://www.grinnell.edu/news/grinnell-college-student-attends-conference-lgbt-issues-carleton-colleges-gender-sexuality.

“Harvard Secret Court Expelled Gay Students in 1920.” The Washington Post. WP Company, December 1, 2002. https://www.washingtonpost.com/.

Leider, Steven. “OSU Launches New Program to Improve Recruitment, Retention of LGBTQ Students in Science and Engineering Programs.” Life at OSU. Oregon State University , October 8, 2010. https://today.oregonstate.edu/archives/2010/oct/osu-launches-new- program-improve-recruitment-retention-LGBTQ-students-science-and-e.

Paley, Amit R. “The Secret Court of 1920.” The Harvard Crimson, November 21, 2002. https://www.thecrimson.com/article/2002/11/21/the-secret-court-of-1920-at/.

Reichard, David A. “”We Can’t Hide and They Are Wrong”: The Society for Homosexual Freedom and the Struggle for Recognition at Sacramento State College, 1969–1971.” Law and History Review 28, no. 3 (2010): 629-674.

Renn, Kristin A. “LGBTQ and Queer Research in Higher Education: The State and Status of the Field.” American Educational Research Association 39, no. 2 (March 2010): 132–41.

Renn, Kristin. “LGBTQ Students on Campus: Issues and Opportunities for Higher Education Leaders.” Higher Education Today. American Council on Education, April 10, 2017. https://www.higheredtoday.org/2017/04/10/lgbtq-students-higher-education/.

Retta, Mary. “These LGBTQ Students Say Their School Treats Them Like Second-Class Citizens.” The Nation. The Nation Company, December 2, 2019. https:// www.thenation.com/article/christian-university/.

Savage, Rachel. “Barred, Bullied, Depressed: Life for Many U.S. Trans Students.” Reuters. Thomson Reuters, August 16, 2019. https://www.reuters.com/article/us-usa-lgbtq- education/barred-bullied-depressed-life-for-many-u-s-trans-students-idUSKCN1V609P.

“Sexual Conduct BU-PP 031.” Baylor University, 2015.

“Sexual Misconduct BU-PP 031.” Baylor University, 2007.

“Stonewall Resource Center.” Grinnell College. Accessed December 24, 2019. https://www.grinnell.edu/about/offices-services/intercultural-affairs/src.

“Their Day in the Yard Movement at Harvard.” Their Day in the Yard. Secret Court RSS. Accessed December 11, 2019. http://secretcourt.org/about/.

Windmeyer, Shane. “The Path Forward: LGBTQ Retention and Academic Success.” INSIGHT Into Diversity, April 15, 2016. https://www.insightintodiversity.com/the-path-forward- LGBTQ-retention-and-academic-success/.

Wright, William. Harvard’s Secret Court: The Savage 1920 Purge of Campus Homosexuals. New York: St. Martins Press, 2005.