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Federal courts ask: What is the meaning of ‘sex’?

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Existing prohibitions against discrimination ‘because of sex,’ already provide a civil rights umbrella wide enough to cover discrimination based on sexual orientation and transgender identity, some judges are beginning to say.

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A number of federal courts have begun to ask a question that has become more and more subtle over the past few years: What is the meaning of ‘sex’?

It’s a question that has in many ways evolved out of the storms of cultural change that have surrounded the country’s shifting ideas about human sexuality and gender over the past few decades. Many of these culminated in the US Supreme Court’s landmark 5-to-4 decision in 2015, in which a bare majority declared same-sex marriage a constitutional right.

On the one hand, the high court’s epoch-changing decision that legalized same-sex marriage created the kind of situation that inevitably arises out of rapid cultural change. Today, neither the federal government nor some 28 states offer any explicit civil rights protections for lesbian, gay, bisexual, and transgender people (LGBTQ), either in the workplace or any other arena of daily life.

“It is constitutionally jarring to know that, in most states, a lesbian couple can get married on Saturday and be fired from their jobs on Monday, without legal redress,” notes the legal scholar William Eskridge, professor at Yale Law School in New Haven, Conn.

And many throughout the country, even those with liberal-leaning views, continue to be uneasy about the presence of transgender people in certain sensitive places, including school bathrooms and locker rooms.

On Friday, President Trump issued a policy memo that would disqualify most transgender people from serving in the military, after tweeting about his plans to issue such a ban last July. As Defense Secretary Jim Mattis reported to the president in February, the administration is concerned that the presence of transgender soldiers could “undermine readiness,” “disrupt unit cohesion,” and create unreasonable health care costs for the military, echoing arguments used in the past for other groups.

At least four federal courts have found this reasoning constitutionally jarring as well, potentially violating the Constitution’s guarantee of equal protection under the law.

Yet beyond sweeping constitutional questions which regulate what the government can do to its citizens, the nation’s evolving definitions of sex, marriage, and gender have also been quietly transforming the nation’s civil rights laws, which regulate how citizens live their common lives together.

Title VII and Title IX

Indeed, a number of federal courts have recently begun to weigh in on a vigorous and relatively new legal idea, simmering for the past few years in federal civil rights cases but only now beginning to take a more defined legal shape.

There may be no need to press Congress and the majority of state legislatures to change their statutes and explicitly add LGBTQ people to their lists of protected classes. (Traditionally, these include race, color, religion, sex, and national origin.) Existing prohibitions against discrimination “because of sex,” already provide a civil rights umbrella wide enough to cover discrimination based on sexual orientation and transgender identity, some judges are beginning to say.

The Obama administration took this position in 2016, telling the nation’s public schools that transgender students should be able to use the bathroom of their choice, a directive that interpreted Title IX’s prohibitions against sex discrimination as covering transgender identity.

Last April, the US Court of Appeals of the Seventh Circuit in Chicago, which includes nine justices nominated by Republican presidents and five by President Ronald Reagan, also embraced this idea. In an 8-to-3 decision that spanned the panel’s ideological spectrum, the full court ruled that the Title VII’s prohibition against sex discrimination in the workplace also included any based on sexual orientation.

Last month, the Second Circuit in New York issued a similar ruling. “Sexual orientation discrimination is a subset of sex discrimination because sexual orientation is defined by one’s sex in relation to the sex of those to whom one is attracted,” wrote Chief Judge Robert Katzmann for the 10-3 majority. It would be impossible “for an employer to discriminate on the basis of sexual orientation without taking sex into account,” he continued.

Such an evolving legal definition of sex could again reshape the nation’s legal landscape. “Potentially a lot is at stake,” says Professor Eskridge. “Depending how broadly you go, this idea could affect dozens of state statutes and dozens of federal statutes, the chief of which are Title VII and Title IX,” sections in the landmark 1964 Civil Rights Act that forbids discrimination both in the workplace and in public schools.

Original intent

On the surface, the debate over the meaning of “sex” in these cases divides legal thinkers into classic liberal and conservative approaches to the law. Those who focus on the “original intent” of laws and the precise words of the legal text have generally rejected the expansive lines of thinking about the definition of sex.

“I think the better answer, the cleaner answer is just, let Congress go ahead and change the laws,” says Mark Goldfeder, senior fellow at the Center for the Study of Law and Religion at Emory Law School in Atlanta. And there’s virtue in hashing out such questions through a political process rather than letting a panel of judges make such society-shaping decisions.

Indeed, this was part of the reasoning behind a three-judge panel in the 11th Circuit in Atlanta, which came to the opposite conclusion. In a 2-to-1 decision, the majority said that discrimination “because of sex” and discrimination based on sexual orientation were two different things. The disagreement among appeals courts could invite a potential Supreme Court review, scholars say.

But the history of the legal concept of “sex discrimination” unfolded in a much more complex way, many observers note, and conservative jurisprudence, too, has played a key role in the evolving definitions of “sex” that almost immediately began to widen over time.

“There’s been this natural progression of the law,” says Susan Eisenberg, managing partner at the Miami office of Cozen O’Connor. As a trial attorney who has been defending companies from civil rights complaints for more than two decades, she’s has watched as the concept of “sex” in discrimination cases has evolved over time, changing the ways she defends her clients.

The evolution of civil rights law

In the first decade after the passage of the 1964 Civil Rights Act, she and others point out, the “original intent” of the prohibition against sex discrimination was clear. The nation’s elite law schools and medical schools were often reserved for male applicants only, single women could be denied leases and bank accounts, and the nation understood its merit-based workplace as the natural domain of men alone.

But by the 1970s, people began to claim that sexual harassment in the workplace also violated Title VII’s prohibition against sex discrimination, and the Supreme Court agreed, declaring “a hostile work environment” as a violation of Title VII.

By the end of the 1980s, the Supreme Court found that discrimination based on “gender stereotypes” was also a violation of civil rights laws – in this case a woman who was passed up for promotion because she did not act feminine enough.

“She argued: that’s discrimination against me on the basis of my sex,” says Steve Sanders, a professor at Indiana University’s Maurer School of Law in Bloomington. “They’re not discriminating against me as a woman per se, but they’re discriminating against me because I failed to demonstrate certain stereotypes of what it means to be a woman, and the Supreme Court accepted that.”

And the nation’s high court broadened the definition even further in 1998, ruling unanimously that Title VII’s workplace protections covered sexual harassment between members of the same sex – a key decision, says Ms. Eisenberg, citing a passage that in many ways redefined her job.

“Statutory prohibitions often go beyond the principal evil to cover reasonably comparable evils, and it is ultimately the provisions of our laws rather than the principal concerns of our legislators by which we are governed,” wrote Justice Antonin Scalia for the majority in the case Oncale v. Sundowner, explaining the expanding definition of sex in this area of civil rights law.

“The sexual orientation cases that we’re now seeing basically takes the logic of these cases one step further,” says Professor Sanders. “If you’re a man, the social stereotype and the social expectation is that you will want to have sex with a woman, that you will want to have a relationship and a marriage with a woman. But, no, you defy that gender stereotype about what it means to be a man, because you’re attracted to other men.”

“Well, if the idea that men should only be attracted to women and women should only be attracted to men is a form of gender stereotyping, ergo, the logic goes, it’s covered by Title VII,” he says.

The Trump administration, however, maintains that while the Justice Department “is committed to protecting the civil and constitutional rights of all individuals,” in these case it remains “committed to the fundamental principle that the courts cannot expand the law beyond what Congress has provided,” said Justice Department spokesman Devin O’Malley in February.

‘Lack of clarity can prove expensive’

Corporate attorneys say most businesses have already instituted their own antidiscrimination policies. “But though many have adopted these, only voluntarily, the unevenness, the irregularity of anti-discrimination laws, I think is very challenging for the business community to grapple with,” says Darren Rosenblum, professor at the Elisabeth Haub School of Law at Pace University in New York. “So I think there is an imperative to clarify the law on this point. That’s what they need first and foremost, because the lack of clarity can prove expensive, figuring out which norms to follow.”

Even so, Eisenberg points out that given the ways in which the high court has redefined the meaning of sex in past precedents, today simple claims of “gender stereotyping” already covers most claims of discrimination based on sexual orientation or gender identity.

“And if you’ve got people who are being discriminated against just because they’re not part of a protected characteristic, that’s just not good management,” Eisenberg says. “It’s not good for recruiting, it’s not good for maintaining employees, it’s not good all the way around.”

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Parents struggle to discuss sex with LGBTQ teens

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It’s hard enough for parents to have “the talk” about sexual health with their kids, but parents of LGBTQ children feel especially uncomfortable and unequipped when they try to educate them about sex and dating, reports a new Northwestern Medicine study.

The study examined parents’ attitudes toward talking about with their lesbian, gay, bisexual, transgender and queer teens (LGBTQ).

“Parents play an important role in helping their children learn how to have healthy sexual relationships, but they really struggle when discussing this with their LGBTQ teens,” said lead author , an assistant professor of medical social sciences at Northwestern University Feinberg School of Medicine.

In contrast to heterosexual youth, very little research has previously been conducted on the relationships between LGBTQ youth and their parents, and how parenting can affect children’s sexual behaviors.

Parents in the study reported that they face many challenges when trying to educate their LGBTQ children about sex. These challenges include general discomfort with talking about sex with their children, as well as feeling unequipped to provide accurate advice about what constitutes safe LGBTQ sexual practices.

“My challenge around talking about sex is that I have no idea what sex is really like for men, especially for gay men,” commented one mother in an online focus group.

Another parent sent her bisexual daughter to a lesbian friend to talk to her about “gay sex.”

“I felt challenged that I’m straight, my daughter is dating a gal, and I didn’t know anything about that,” the mom said. “All my sex talks were about how not to get pregnant and how babies aare conceived.”

One parent reported feeling isolated in handling sex talks with her gay child. “I don’t have an opportunity to talk to other parents whose kids are LGBTQ,” she said.

“We need resources to help all parents—regardless of their child’s sexual orientation or gender identity—overcome the awkwardness and discomfort that can result from conversations about sexual ,” said Newcomb, associate director for scientific development at the Institute for Sexual and Gender Minority Health at Feinberg.

The Institute for Sexual and Gender Minority Health conducted the survey examining attitudes toward talking about sexual health from the perspective of parents of LGBTQ teens.

The study was published March 26 in the journal Sexuality Research and Social Policy. There were 44 participants in the study who were parents of LGBTQ adolescents ages 13-17.

“Having a healthy and supportive relationship with parents is one of the strongest predictors of positive health outcomes in teens, and this is true of both heterosexual and LGBTQ teens,” Newcomb said. “Many parents and their LGBTQ teens want to have supportive relationships with one another, so if we can design programs to strengthen these relationships, it could have a tremendous impact on LGBTQ teens’ health and well being.”

The Institute also recently published a separate study in the Archives of Sexual Behavior focused on talking about sex from the perspective of LGBTQ adolescents.

“We found that many of the gay and bisexual male youth in our study wanted to be closer to their parents and to be able to talk about sex and dating,” said lead author Brian Feinstein, a research assistant professor at the institute. “However, most of them said that they rarely, if ever, talked to their parents about sex and dating, especially after coming out. And, even if they did talk about sex and dating with their parents, the conversations were brief and focused exclusively on HIV and condom use.”

Participants in the youth study were ages 14-17 and identified as gay or bisexual males.

Brian Mustanski, director of Institute for Sexual and Gender Minority Health and professor of medical social sciences at Feinberg, noted, “Research on family relationships is a high priority for us because it is an extremely understudied area, and parents are asking us for advice. We need new research to give these the right answers.”

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Women who have sex with women orgasm much, much more, new study shows

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Women who have sex with women are more likely to orgasm, according to a new study.

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Researchers at the University of Arkansas have discovered that though straight partners have sex more often, bisexual and lesbian women have more orgasms – by far.

The study, which had 2,300 respondents, found that women were 33 percent more likely to orgasm when they were having sex with another woman.

And they also told the study, titled “Are Women’s Orgasms Hindered by Phallocentric Imperatives?”, that they were more likely to experience multiple orgasms with women.

Those in same-sex relationships said they orgasmed, on average, 55 times per month.

This stood in stark contrast with women in straight relationships, who said they usually achieved just seven orgasms per month.

Dr Kristen Jozkowski said: “Sex that includes more varied sexual behaviour results in women experiencing more orgasms,” according to The Sun.

Sex between women “was excitingly diversified,” she explained.

These results follow a study last year which showed that gay men and lesbians are better at sex than straight people.

The four researchers, David A. Frederick, H. Kate St. John, Justin R. Garcia and Elisabeth A. Lloyd, measured the orgasms which people across the sexuality spectrum have.

They found – perhaps not shockingly – that heterosexual men were most likely to say they “usually always orgasmed when sexually intimate,” doing so 95 percent of the time.

In contrast, straight women orgasm in just 65 percent of cases.

The orgasm gap is well-documented, and its generally accepted in the academic community that women climax less often than men – but this, of course, is a heteronormative theory.

It doesn’t consider the fact that possibly, just possibly, non-heterosexual people are better at sex.

The four professors, two of whom work at Indiana University, discovered just this.

Gay men orgasm 89 percent of the time, they found, while lesbians are not far behind on 86 percent.

That study came on the heels of research which revealed that gay and lesbian couples are happier than people in straight relationships.

So if we assume straight couples both climax 65% of the time – and that orgasms are a decent barometer of how good sex is – these results are excellent for gay and lesbian partners.

They come out 24 and 21 percentage points ahead of their straight counterparts, which equates to a hell of a lot more joint fun.

The study also found that “women who orgasmed more frequently were more likely to: receive more oral sex and have [a] longer duration of last sex”.

They are also “more satisfied with their relationship, ask for what they want in bed, praise their partner for something they did in bed, call/email to tease about doing something sexual and wear sexy lingerie”.

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Omnisexual, gynosexual, demisexual: What’s behind the surge in sexual identities?

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There’s been a proliferation of sexual identities.

by Olivia Goldhill

In 1976, the French philosopher Michel Foucault made the meticulously researched case that sexuality is a social construct used as a form of control. In the 40 years since, society has been busy constructing sexualities. Alongside the traditional orientations of heterosexual, homosexual, and bisexual, a myriad other options now exist in the lexicon, including:

  • pansexual (gender-blind sexual attraction to all people)
  • omnisexual (similar to pansexual, but actively attracted to all genders, rather than gender-blind)
  • gynosexual (someone who’s sexually attracted to women—this doesn’t specify the subject’s own gender, as both “lesbian” and “heterosexual” do)
  • demisexual (sexually attracted to someone based on a strong emotional connection)
  • sapiosexual (sexually attracted to intelligence)
  • objectumsexual (sexual attraction to inanimate objects)
  • autosexual (someone who prefers masturbation to sexual activity with others)
  • androgynosexual (sexual attraction to both men and women with an androgynous appearance)
  • androsexual (sexual attraction towards men)
  • asexual (someone who doesn’t experience sexual attraction)
  • graysexual (occasionally experiencing sexual attraction, but usually not)

Clearly, people felt that the few existing labels didn’t apply to them. There’s a clear “demand being made to have more available scripts than just heterosexual, homosexual, and bisexual,” says Robin Dembroff, philosophy professor at Yale University who researches feminist theory and construction.

Labels might seem reductive, but they’re useful. Creating a label allows people to find those with similar sexual interests to them; it’s also a way of acknowledging that such interests exist. “In order to be recognized, to even exist, you need a name,” says Jeanne Proust, philosophy professor at City University of New York. “That’s a very powerful function of language: the performative function. It makes something exist, it creates a reality.”

The newly created identities, many of which originated in the past decade, reduce the focus on gender—for either the subject or object of desire—in establishing sexual attraction. “Demisexual,” for example, is entirely unrelated to gender, while other terms emphasize the gender of the object of attraction, but not the gender of the subject. “Saying that you’re gay or straight doesn’t mean that you’re attracted to everyone of a certain gender,” says Dembroff. The proliferation of sexual identities means that, rather than emphasizing gender as the primary factor of who someone finds attractive, people are able to identify other features that attract them, and, in part or in full, de-couple gender from sexual attraction.

Dembroff believes the recent proliferation of sexual identities reflects a contemporary rejection of the morally prescriptive attitudes towards sex that were founded on the Christian belief that sex should be linked to reproduction. “We live in a culture where, increasingly, sex is being seen as something that has less to do with kinship and reproduction, and more about individual expression and forming intimate bonds with more than one partner,” Dembroff says. “I think as there’s more of an individual focus it makes sense that we have these hyper-personalized categories.”

The same individuality that permeates western culture, leading people to focus on the self and value their own well-being over the group’s, is reflected in the desire to fracture group sexual identities into increasingly narrow categories that reflect personal preferences.

Some believe this could restrict individuals’ freedom in expressing fluid sexuality. Each newly codified sexual orientation demands that people adopt increasingly specific criteria to define their sexual orientation.

“Language fixes reality, it sets reality,” says Proust. “It paralyzes it, in a way. It puts it in a box, under a tag. The problem with that is it doesn’t move. It negates or denies any instability or fluidity.”

There’s also the danger that self-definition inadvertently defines other people. Just as the terms “heterosexual” and “homosexual” demand that people clarify their sexual preference according to their and their partner’s gender, “sapiosexual” asks that we each of us define our stance towards intelligence. Likewise, the word “pansexual” requires people who once identified as “bisexual” clarify their sexual attraction towards those who don’t identify as male or female. And “omnisexual” suggests that people should address whether they’re attracted to all genders or oblivious to them.

In Foucault’s analysis, contemporary society turns sex into an academic, scientific discipline, and this mode of perceiving sex dominates both understanding and experience of it. The Stanford Encyclopedia of Philosophy summarizes this idea neatly:

Not only is there control exercised via others’ knowledge of individuals; there is also control via individuals’ knowledge of themselves. Individuals internalize the norms laid down by the sciences of sexuality and monitor themselves in an effort to conform to these norms.

The new terms for sexual orientations similarly infiltrate the political discourse on sexuality, and individuals then define themselves accordingly. Though there’s nothing that prevents someone from having a demisexual phase, for example, the labels suggest an inherent identity. William Wilkerson, a philosophy professor at the University of Alabama-Huntsville who focuses on gender studies, says this is the distinctive feature of sexual identities today. In the past, he points out, there were plenty of different sexual interests, but these were presented as desires rather than intrinsic identities. The notion of innate sexual identities “seems profoundly different to me,” he says. “The model of sexuality as an inborn thing has become so prevalent that people want to say ‘this is how I feel, so perhaps I will constitute myself in a particular way and understand this as an identity’,” he adds.

In the 1970s and 80s there was a proliferation of sexual groups and interests similar to what we’ve seen over the past five to 10 years, notes Wilkerson. The identities that originated in earlier decades—such as bears, leather daddies, and femme and butch women—are deeply influenced by lifestyle and appearance. It’s difficult to be a butch woman without looking butch, for example. Contemporary identities, such as gynosexual or pansexual, suggest nothing about appearance or lifestyle, but are entirely defined by intrinsic sexual desire.

Dissatisfaction with existing labels doesn’t necessarily have to lead to creating new ones. Wilkerson notes that the queer movement in earlier decades was focused on anti-identity and refusing to define yourself. “It’s interesting that now, it’s like, ‘We really want to define ourselves,’” says Wilkerson.

The trend reflects an impulse to cut the legs out from under religious invectives against non-heteronormative sexualities. If you’re “born this way,” it’s impossible for your sexuality to be sinful because it’s natural, made of biological desires rather than a conscious choice. More recently, this line of thinking has been criticized by those who argue all sexualities should be accepted regardless of any link to biology; that sexuality is socially constructed, and the reason no given sexuality is “sinful” is simply because any consenting sexual choice is perfectly moral.

Though it may sound ideal to be utterly undefined and beyond categories, Proust says it’s impossible. “We have to use categories. It’s sad, it’s tragic. But that’s how it is.” Constructs aren’t simply necessary for sexual identity or gender; they’re an essential feature of language, she adds. We cannot comprehend the world without this “tag-fixing process.”

The proliferation of specific sexual identities today may seem at odds with the anti-identity values of queer culture, but Dembroff suggests that both work towards the same ultimate goal of eroding the impact and importance of the old-fashioned binary sexual identities. “Social change always happens in non-ideal increments,” Dembroff notes. So while today we may have dozens of sexual identities, they may become so individualized and specific that they lose any significance for group identities, and the entire concept of a fixed sexual identity is eroded.

“We demand that sex speak the truth,” wrote Foucault in The History of Sexuality. “We demand that it tell us our truth, or rather, the deeply buried truth of that truth about ourselves which we think we possess in our immediate consciousness.” We still believe sex reveals an inner truth; now, however, we are more readily able to recognize that the process of discovering and identifying that truth is always ongoing.

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You’re probably not ‘totally straight,’ according to new research

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Society tends to be less accepting of men who are sexually fluid.

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  • There is a new type of sexual orientation called “mostly straight,” according to new research.
  • This sexuality entails identifying as straight but occasionally experiencing same-sex attraction and arousal.
  • Men have a harder time coming out as mostly straight because society is less forgiving of male sexual fluidity.

If there is anything to be gleaned from the past thousand years of human interaction, it is that human sexuality has never been simple.

And now, we have more scientific literature to back up the claim. According to recent research from Ritch Savin-Williams, a psychology professor of human development at Cornell University, there is a spot on the sexual spectrum that is not straight, gay, or bisexual — it’s called being “mostly straight.”

Savin-Williams’ conclusion stems from research on sexuality that he conducted and published in a book titled “Mostly Straight: Sexual Fluidity Among Young Men“.

In one study Savin-Williams worked on, participants who identified as men or women were shown pornography. By measuring the dilation of their pupils — an indicator of sexual arousal, as proven by a previous study of his published in the Journal of Personality and Social Psychology, Savin-Williams and his team were able to conclude that women were aroused by pornography featuring women with men and women with women. Men had similar results, which Savin-Williams calls being “mostly straight.”

This is not to say that no one is straight. “I wouldn’t say that [no one is totally straight] and I never have, despite press reports,” Savin-Williams told INSIDER. “I believe the vast majority of men are exclusively straight.”

Sexuality is a spectrum, but society doesn’t always allow room for male transgressions.

Savin-Williams is not the first scientist to deal with the idea that sexual preference isn’t quite as rigid as was previously believed. Many people already know about the Kinsey scale, the near-ubiquitous system that allows people to gauge their sexuality on a sliding scale, which revealed that people do not always fit exclusively into heterosexual or homosexual categories. In fact, according to Savin-Williams, the Kinsey scale allows space for people who might identify as mostly straight.

The Kinsey scale.

“Because the seven-point Kinsey Scale was a continuum from exclusively straight to exclusively gay/lesbian, there was an obvious place between exclusively straight and bisexual leaning straight — Kinsey 1s or mostly straight,” Savin-Williams told INSIDER.

But men have largely been excluded from the sexual fluidity narrative.

“Very few researchers seemed to notice these [sexually fluid or mostly straight] individuals, except with women,” Savin-Williams told INSIDER. “Then, while interviewing straight men for a study, I discovered that a number of them said that they were not exclusively straight, but mostly straight. These self-reports were confirmed by their confidential surveys and by their physiological reactions to watching porn: their pupils dilated to men masturbating, not as much as their pupils dilated to women masturbating, but an elevation nevertheless.”

This exclusion is due to the fact that, as Savin-Williams said, conventional society doesn’t allow much room for variance or growth in male sexuality.

“Men are affected by the belief that any level of same-sex attraction must mean you’re gay. Our culture likes our men simple — gay or straight,” Savin-Williams told INSIDER. “We give women greater freedom to be flexible, to be affected by the environment; they can act ‘masculine’ and not be labeled lesbian but men can’t act ‘feminine’ without being thought gay.”

Women have sexually fluid representation, but men don’t get as much.

This is certainly true in popular culture. It’s hard to come across a movie or TV show these days that doesn’t feature a complex, sexually fluid female character, like Eleanor Shellstrop on “The Good Place” or Petra Solano on “Jane The Virgin.”

Male characters have some sexually fluid representation “Jane The Virgin,” for example, has a male character, Adam, who is bisexual) but, generally, male figures in popular culture are relegated to one of two binaries: 100% straight or 100% gay.

Savin-Williams believes that the answer to helping men and women becoming more comfortable with mostly straight men relies, in part, upon “more famous people coming out as mostly straight,” he told INSIDER. “Josh Hutcherson began this years ago, but few have followed. I would love to see more young men come out as mostly straight to their friends and families.”

More pop culture representation wouldn’t hurt, either.

“There are more mostly straights among the millennial generation than in previous generations, largely because there’s an incredible acceptance and celebration of sexual, romantic, and gender diversity. Young people believe in the spectrum of sexuality and romance,” Savin-Williams told INSIDER. “There are already more mostly straight women and men than bisexual and gay/lesbian individuals combined. Mostly straights need to be freed from their closets — how about a movie or two?”

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