A critical issue faced by educational institutions in the twenty-first century is that of the ever-growing diversity of the student population. The concept of hegemony, created by a euro-centric view of the white heterosexual male dominated society of early America, is no longer practical in the modern world. So-called minority groups are outnumbering the preconceived majority in many large urban school districts, and the idea of inclusion is permeating the classroom, encompassing students of various learning and physical disabilities and facilitating their entrance into the mainstream world of education.

As a result, many of the traditional theories and practices of educational pedagogy are insufficient to cope with the increasing demands for diversified instruction. Areas of diversity are not limited to racial and ethnic characterization, but also include religious preference, disability status and, in recent years, sexual orientation. In order to provide a fully inclusive environment, educators must first be aware of the issue and also make a true commitment to open and unbiased acceptance.

The issue of the right of non-heterosexual students to receive an education in an environment that is free from harmful emotional and physical threats has come increasingly to the forefront. Bettina Boxall and Duane Noriyuki, staff writers for the Los Angeles Times, expose the serious nature of this issue in an article in the May 28, 1999 issue of the paper titled Harassment: Victims, once silent or ignored, now strike out against a favorite form of campus torment. He cites a student’s own remembrances of her time in high school: “…the halls of the local high school, the words “faggot” and “dyke” were routinely uttered, about as often, Alana Flores remembers, as hello and goodbye”.

These insulting words, along with death threats which included the pornographic image of a woman, bound and gagged, with her throat slit, were common occurrences for Flores and her fellow gay and lesbian classmates at Live Oak High School in San Jose, California. With regards to the specific incident surrounding the photo, which had been placed in Flores’ locker, when she took the matter to the assistant principal, she was openly asked to identify herself as a lesbian and told that she was not to bring “bring me this trash anymore”. The assistant principal later denied this remark.

To fight back against the torment that they were forced to endure, she and other students from the school, all now graduated, are suing the Morgan Hill School District for the role that they played by ignoring the fact that administrators and teachers at the school did nothing to stop the abuse. The suit was filed in 1998 in U.S. District Court by the American Civil Liberties Union of Northern California, the National Center for Lesbian Rights and San Jose attorney Diane Ritchie and mentions this as well as numerous other incidents of taunting in the classroom in which the teacher present did nothing to end the remarks. Ultimately, Torres, who was active in both dance and drama during her high school years, was so affected by the increasingly hostile nature of these threats that she turned down a scholarship to the California Institute for the Arts out of fear of leaving the safety of her supportive family.

Boxall and Noriyuki go on to state in the article that this case is only one of an ever increasing number of similar lawsuits being filed in the years between 1995 and 1999 against school districts around the country, noting that “…the lawsuit represents the latest frontier in school harassment issues–a legal front that gained ground this week when the U.S. Supreme Court ruled that school districts can be held liable in similar cases involving extensive sexual harassment of students by one another”. The article notes: “In the past decade a growing number of lawsuits have sought to hold schools accountable for student sexual harassment, arguing that it violates Title IX, the federal law barring sex discrimination in schools and colleges”.

Tamar Levin of the New York Times exposes another lawsuit in the making in the article Openly Gay Student’s Lawsuit Over Privacy Will Proceed published on December 2, 2005. At issue in this case is Charlene Nguon, whose right to privacy was violated when the principal of Santiago High School in California disclosed Nguon’s sexual orientation to Nguon’s mother. An academically excellent honors student, Nguon was targeted by Principal Ben Wolf for the fact that she openly chose to hold hands with her girlfriend on the school grounds.

Although Nguon’s parents proved to be supportive of her, Judge James V Selna of the Central District Court of California ruled that the defendant had a sufficient premise from which to assert that her rights to privacy had been violated. Christine Sun, ACLU attorney involved in the case, noted the significance of this ruling from the standpoint that the issue of Charlene’s parents as supportive of their daughter id not the case. Coming out is a difficult choice for a person to make, and that choice should never be taken away from the individual involved.

Disclosure of sexual orientation that is outside of the so-called norm can, in the case of many people whose families are not supportive, lead to ramifications including but not limited to physical violence and loss of a home in which the teen can live safely. At issue in the case are allegations by the school administration as well as school board officials that Nguon’s openly gay status on school grounds should negate her right to freedom from disclosure. The school board, with its limited understanding of the intricacies of gay and lesbian issues in a largely non accepting society, fails to understand the reasons why an individual would choose to be open about his or her sexuality in one setting but not in another.

The courts, however, in this particular case, seem to be leaning towards at least allowing the argument to be examined more closely before rendering a final decision. While students must be held accountable for behavior that is considered unacceptable with the educational setting, such as certain forms of public displays of affection, the punishment for breaking these rules needs to be applied equally between heterosexual and homosexual students. If the school requires parental notification when these rules are broken, then this notification should occur for all students regardless of sexual orientation.

However, when such notification also creates a potentially dangerous situation for the student that could, due to moral or religious beliefs, be far more severe than what would be expected under the circumstances, the rules become insufficient to deal with the larger situation. The lawsuit seeks to not only reach an agreement with regards to this one issue but to also establish guidelines and district wide policies that pertain to the treatment of gay and lesbian students as a whole.

The actual outcome to the various cases has been inconsistent to this point, but the first victory came in 1996 when a high school in Wisconsin was found liable for their failure to protect student Jamie Nabozny, who suffered severe emotional and physical injury. Represented by members of the Lambda Legal Defense fund, Nabozny sued his school district as well as specific staff and administrators for failing to protect him from verbal and physical assaults perpetuated upon him as a result of his sexual orientation, and the National Association of School Psychologists on their advocacy web portal provides details of his case. Nabozny sued for monetary damages, but also to be awarded his diploma and the opportunity to attend graduation ceremonies. He had previously left the school and completed his GED in an attempt to escape the daily torment that included:

…name calling, striking and spitting on him. On one occasion two boys held Jamie down and performed a mock rape on him while twenty other students looked on and laughed. In an assault in a bathroom, Jamie was knocked down and urinated on by several boys. In the most serious physical assault, Jamie was kicked in the stomach for five to ten minutes by a boy while a group of students looked on in laughter. Jamie later collapsed from internal bleeding.

In his suit, Jamie, now age 20, sought the award of his high school diploma, attendance at the high school graduation ceremony and $50,000 dollars in damages. A district court judge in Wisconsin dismissed the suit. Jamie, represented by the Lambda Legal Defense and Education Fund, appealed his case to the U.S. Seventh Circuit Court of Appeals… the Court of Appeals panel concluded that the Ashland Public School System, the principals of the middle and high schools, and the high school’s assistant principal “violated Nabozny’s Fourteenth Amendment right to equal protection by discriminating against him based on his gender or sexual orientation”.

Perhaps the greatest advancement being made by these lawsuits is to force the dialogue out into the open, taking it to the places where it most needs to be heard. Initially, these issues were discussed and negotiated within the gay and lesbian community. Many educators, who are most directly responsible for the changes that need to occur, became aware of the serious nature of these issues only when they began to be openly discussed in educational journals and publications. Until that time, they often turned a blind eye on harassment within the classroom, and many of them maintained similar prejudicial attitudes towards sexual minorities as their students.

In his article Gay Issues and Students’ Freedom of Expression–Is there a Lawsuit in Your Future Nathan Essex cites the importance of administrators and their role in acceptance as key to the advancement of diversity issues and also as a means of avoiding an ever-growing list of lawsuits being filed against schools who do not facilitate gender acceptance. He states that: “…school leaders must recognize and respect the freedom of expression rights of students within reasonable limits, but they may restrict student expression that creates material and substantial disruption to the educational process.” One of those freedoms is the right to freedom of expression of sexual orientation.

It is during the teen years that gendered identity begins to assert itself, and to deny that expression is to stifle the individuals right to personal freedom under the law. Essex notes that this presents an issue for school leaders as they struggle to allow for this diversity without creating an atmosphere in which student reactions become detrimental to the learning environment. Essex specifically examines the First Amendment rights granted to students in the public school system as they pertain to gender orientation issues. He mentions recent lawsuits and cautions that administrators who do not adhere to the rights of gay and lesbian students are leaving themselves open to additional lawsuits.

Essex’s article opens a crucial dialogue. While personal beliefs and prejudices may make it difficult for some conservative administrators to set aside their own ideals of morality in order to abide by the current letter of the law, they must do so in order to protect the interest not only of their school as an institution but also the emotional and physical safety of those students whom the laws most effect.

In June of 2006, Mark Vicars published the article Who Are You Calling Queer? Sticks and Stones Can Break My Bones but Names Will Always Hurt Me in the British Educational Research Journal. Citing the increase in harassment being reported by gay, lesbian and bisexual identifying students, Vicars utilizes an autobiographical or memoir style approach to the topic wherein he examines the impact of being identified as “queer” in the public school setting. The use of personal accounts brings to the forefront the damage that is actually done to these students, and the ways in which their lives are permanently altered by heteronormative educational practices. He examines the damages that words can cause on self esteem and the ways in which fear can isolate these students from not only their peers but also, and perhaps more importantly, from access to the education that the school is charged to provide to all individuals.

Philip A Rutter, Assistant Professor, School of Education, University of Colorado at Denver employs a similar technique in his article Sexual Minority Youth Perspectives on the School Environment and Suicide Risk Interventions: A Qualitative Study . Rutter explores the experiences of five gay, lesbian, and bisexual adolescents in an effort to place the dialogue into the context of their own personal perspective, as the often-maligned minority, as to their schools’ acceptance of their sexual orientation. In particular, Rutter examines the schools’ approach to suicide risk intervention, a danger among teenagers who experience feelings of isolation from the accepted norm.

Themes that emerged from a variety of interviews with these students included and almost unanimous feeling on the parts of the participants that they were judged by school counselors and teachers, the very individuals who should be there to listen to students feelings with unbiased ears. These students also acknowledged feeling unsafe at school. They were concerned about the lack of response on the part of school staff with regards to the possibility of increased suicide risk among the gay and lesbian population, and they felt that little was being done with regards to interventions. Rutter closes his article with an examination of the implications of increased suicide and other forms of isolation of non-heterosexual students as it pertains not to the students themselves but to the school counselors, teachers and administrators.

Rutter’s article, itself, contains a vast amount of information and gives the reader the opportunity to experience discrimination within the school system from the point of view of individual students, a unique perspective that allows educators who, for the most part, have little frame of reference with which to relate to the homosexual experience. More importantly, however, is the inclusion of this article in a journal devoted wholly to the expression if this dialogue.

The Journal of Gay and Lesbian Issues in Education, which initially published this article, began in 1993 in an attempt to provide a monitored scholarly journal dedicated solely to issues faced by educators with regards to GLBT issues faced by teachers in the classroom and also to provide ample support and information to teachers and advocates who choose to address these in front of the administration. Each article in the journal is reviewed by an international editorial board made up of well-known educators, researchers, and figures in the worldwide GLBT community. Additionally, a unique feature of this journal is its youth advisory board, composed of international LGBT youth, ranging in age from 16-24, who add the perspectives of current and recent high school students to the journal.

In an article in an earlier edition of this same journal, Anthony R. D’Augelli PhD, Professor of Human Development at Pennsylvania State University, and Arnold H. Grossman PhD, Professor of Applied Psychology at New York University, argue perhaps the most important core issue of acceptance of gendered diversity at the educational level. They note that developmental and educational researchers have not considered the development of sexual orientation among adolescents and youth. While there has been a vast amount of attention and research devoted to the understanding of sexual development and identity development during adolescence, both topics have largely been looked at as separate entities.

Sexual orientation as a key factor of personal identity has been pushed to the side. D’Augelli and Grossman argue, in this article, some of the inherent difficulties as well as the benefits of conducting specific and targeted research on lesbian, gay, and bisexual youth. At heart in this paper is a growing awareness of the role stigmatization plays on adolescent identity development. They propose ideas that could be used to create the studies needed to determine long-term effects of such stigmatization and illustrate the necessity for completing these studies in a timely fashion in order to get them included into the vast font of pedagogical theory already available.

This research has already been started in some locations. In her Heterosexual Adolescents’ and Young Adults’ Beliefs and Attitudes about Homosexuality and Gay and Lesbian Peers, published in a 2006 edition of the Journal of Cognitive Development, Stacey Horn examines the emotional climate for gay and lesbian students in the United States. She suggests that research shows that negative attitudes toward gays and lesbians are commonplace, especially during adolescence.

She notes, however, that very little research has been undertaken in response to the actual development of gendered identity and the effects that negative attitudes have on young people during the critical formative ages. She cites a recent study in which 10th and 12thgrade adolescents as well as college-aged young adults were invited to complete a questionnaire that asked about both their beliefs and attitudes about homosexuality and their comfort with gay and lesbian students, as well as their feelings about the treatment of gay or lesbian students in their own school environments.

The result of this survey showed that teens aged 14-16 are far more likely to express open hostility and prejudice towards their LGBT peers, specifically with regards to inclusion in social activities. There were not, however, differences found between the age groups with regards to actual beliefs and feelings towards homosexuality as a whole. As a result, Horn argues for the need to create studies that not only examine the issue but also account for the differences in the way teens act towards their feelings as they age and mature. What this shows is a trend not to grow more accepting of difference in the course of the educational experience, but instead to express a greater degree of control in the outward display of prejudice. This is an important distinction in that Horn’s theory underscores the critical need for additional research into the attitudes of youth and how they display those attitudes in an all-inclusive setting.

An earlier study, Peer Victimization, Social Support, and Psychosocial Adjustment of Sexual Minority Adolescents, written byTrish Williams, Jennifer Connolly, Debra Pepler and Wendy Craig and published in the October 2005 issue of Journal of Youth and Adolescence, explores a recent study that examined a direct link between sexual orientation and adjustment in a community. In this study, a sample of 97 sexual minority high school students were asked to express their experiences of peer victimization and social support within peer and family contexts.

The survey was conducted using groups of students from five high schools, and the results of their responses to the questionnaire provided were compared to the results from a similar selection of heterosexual students. By and large, students who identified as members of a gendered minority group were far more likely to show outward signs of depression than heterosexual youth in the same age range. They also reported a greater incidence of sexual harassment, threats and bully-like behavior directed towards them from their peers. peers. They evidenced a lack of close relationships with family and friends, and more of a sense of isolation from a larger community.

These statistics remained consistent between gay male, lesbian, bisexual, and questioning adolescents. The authors tie this survey to evidence that lack of social support for sexual minorities during adolescence and the risks incurred by such a lack of support which include high-risk behaviors and an increased risk of long-term psychological damage. This research is critical in that it provides a “real world” context for such behavior. Teens who face high degrees of discrimination and victimization during their formative years are far more likely to exhibit anti-social or self-defacing behavior patterns later in life. These experiences can alter the victim’s entire framework for future existence within society.

A further examination of the ultimate ramifications of “gay-bashing” on adolescents can be found in Paul Poteat and Dorothy Espelage’s Predicting Psychosocial Consequences of Homophobic Victimization in Middle School Students, published in the 2007 edition of the Journal of Early Adolescence. Poteat and Espalage look at the same issues from the perspective of a slightly younger age group. Their research focuses on the extent to which homophobic victimization was directly tied to incidents of psychological and social distress for middle school students. The study, concluded over the course of one full school year, increased anxiety and depression, personal distress, and a lack of feeling of belonging in homosexual men and higher levels of withdrawal in lesbian students.

Victimization on the basis of sexual orientation, argue Poteat and Espalage, has an enormous impact on both psychological and social development, although young males generally present a higher level of observable symptoms. The writers also argue that teachers and administrators must intervene in situations where LGBT students are being targeted in the school setting. The importance of this article lies in the fact that it goes beyond the statistical research to charge educators with a duty to intervene. No longer is gender-orientation based verbal and physical abuse allowed to be ignored. Attitudes and perceptions must shift in order to allow these students an equal opportunity to learn and grow in an environment that does not foster exclusion.

While a growing awareness of the seriousness of the issue is the first step towards solving the issue, we have a long way to go, both as a society and as an educational network, towards truly addressing the needs of the LGBT community. Each of the articles mentioned explore, in some way, aspects of this issue. They examine the often brutal treatment of gender-different students, and they promote awareness of the growing litigation against educators and administrators in response to the situation; however, they do not propose solutions.

This is because the ultimate solution to the issue of discrimination against queer students at the high school level is tied not only to the imposition of rules and regulations within the school system, but also to the expansion of laws in the United States as a whole, as well as the education of the general public who still suffers under many dangerous misconceptions fostered by an historic acceptance of heteronormal culture as the dominant culture. In order to implement change as educators, we need to step beyond the district and school board level and address these issues at the national level as well. Educators must strive to facilitate change at the national level through involvement in hate crimes legislation as these crimes are the basis from which acceptance of violence against the other has its foundation.

Throughout the 1960’s, an ever-growing dissatisfaction with inequality led to the beginnings of change. The Civil Rights Movement, the Black Power Movement and the Black Arts Movement promoted awareness of the needs of the African American community. The Feminist Movement and the Womanist Movement, similarly, began to address the concerns of women.

Shortly after midnight on June 28, 1969, at the end of a decade of awareness and activism, the Gay Rights movement received its first major boost in the form of a spontaneous act of unification against unfair treatment of homosexuals by the police, immortalized in history as the Stonewall Rebellion. Since then, strides have been made in other areas to foster inclusion of all groups into the educational system, but the gay rights movement has lagged in its acceptance. Throughout history, human beings have sought to form groups based on similarities such as race, gender, and political or religious ideology.

We have learned to be tolerant of difference, but only to a point. Fear of the other, that which is not the self, that which has difference, has always prevailed. Out of this fear we breed hate ands violence and, ultimately, the need to legislate against such violence. For all people whose gendered identity differs from that of the majority, this fear is a real issue. Until we, as a society, reach a full understanding of gendered difference, that fear will continue to exist and permeate all aspects of life, including education. School districts and education programs at the college level need to take an active role in fostering understanding and acceptance of LGBT issues in the minds of current and future teachers.

Because much of this hate and fear is born out of religious and moral conditioning, change might, at times, have to be forced upon certain individual through the establishment of laws and legislation. Religion and its inherent belief systems as held by specific individuals has been used, or misused, for centuries to defend such violence as the Crusades and the Spanish Inquisition, and acts of persecution such as the Apartheid in South Africa and slavery here in the United States, as well as Hitler’s Third Reich and the Holocaust and even the Salem Witch Trials. It is the same for prejudice and hatred in the school system.

The need to educate and fight discrimination in the school system is no different for the LGBT community than it was for the black community after Brown v. Board of Education enforced desegregation on the basis of race. Certain individuals will never be coerced into acceptance, but they can be legislated into accountability for their actions or, in many cases, their inaction in certain key situations. School boards, administrators, and teachers cannot be allowed to allow personal beliefs to sway their actions.

If a student is being harassed or threatened in any way, the issue must be addressed immediately. The current trend towards openly discussing these issues in education journals is a key starting point for the dialogue. As educators continue to be made aware of their responsibility to protect teenagers at the formative stage of their gender-orientation identity, attitudes will begin to change and inclusion will be more equitable for all students, regardless of sexual orientation.