"We were fighting and it was for our lives," said Miss Major Griffin-Gracy, of the moment when police stormed the Stonewall Inn on June 28th, 1969, and with these nine short words, she summed up the long history of the struggle for queer legal liberation. This blog post will take us through how the UK, and the world, moved from the medieval criminalisation of homosexuality to the current state of legislated equality, and a look towards the future of the next steps in the story of LGBTQ+ rights.
The first time in law that male homosexuality was targeted for persecution in the UK came under the Tudor monarch Henry VIII, whose Buggery Act of 1533 outlawed sodomy in England with the penalty of death. The preamble to the Act cited the absence of "sufficient and condign punishment" in law to deal with the "detestable and abominable vice" of homosexuality as the core reason for the bill's passage, though modern scholars, including Johnson and Lafitte, attribute the Act to Henry VIII's agenda to bring religious law under his own authority after his break from the Pope in Rome. Technically, the Act only lasted until the end of the next Parliament - a common provision in historical legislation - but was re-enacted three times before being enacted to continue in force "for ever" in 1541. Edward VI, Henry's heir, repealed and then re-enacted the legislation, and when Mary I repealed it, Elizabeth I, the final Tudor in the dynasty, reintroduced it, and the Buggery Act remained in force for over four centuries.
The first same-sex annulment curiously came long before the enactment of equal marriage laws - when Arabella Hunt married James Howard, she found out two years later her 'husband' was actually a woman named Amy Poulter, and, given the fact two women could not legally marry, the union was annulled in 1682, a century before Jeremy Bentham argued in his essay Offences Against One's Self for the decriminalisation of sodomy in England, with the surprisingly liberal attitude that homosexual acts did not weaken men, nor threaten the population or the concept of marriage. However, given the outrage these views would have caused in Georgian England, the essay was never published until after he died.
France became one of the first countries in the world to decriminalise homosexuality in 1791 with the passage of the French Penal Code, and the subsequent conquest of much of Europe by Napoleon, and the growth of the French Empire, spread this decriminalisation across much of the world, just as in China, the Westernisation efforts of the late Qing Dynasty led to legal opposition to homosexuality - evidencing the impact of Western Christian theology on the spread of homophobia around the globe. The early 1800s in Britain also saw the case of Woods and Pirie v Dame Cumming Gordon, where two female teachers were accused of having a lesbian relationship, leading the judge in the case to write that sex between women - which has never been criminalised in the UK - was "equally imaginary with witchcraft, sorcery or carnal copulation with the devil" - in essence: so absurd an idea that it could never happen. This half-century also saw the executions of the last two men to be executed in Britain for sodomy - James Pratt and John Smith. The men were spied upon while having sex in a private room, and were hung weeks later on November 27th, 1835. The magistrate in the case, who had committed the men to trial, argued against the death penalty and for a commutation of their sentences, though not because of his liberal attitudes towards homosexuality - he described the men in letters he wrote as "degraded creatures" - but because of his belief, supported by evidence, that only poor men were prosecuted for the crime.
The second half of the 19th century was similarly bloody in the fight for legal equality for LGBTQ+ peoples. The Offences Against The Person Act 1861 was a brief light with the repeal of the death penalty, substituted for a minimum of ten years in prison, ending the Buggery Act which had overseen the executions of over 50 men, and the prosecutions of thousands more, though this Act also spread the British's homophobic agenda throughout the British Empire, in order to "protect local Christians from 'corruption' and correct and Christianise 'native' custom," according to Han and Mahoney. Now much of the world was under the rule of the British, and the passage of this Act, the first to explicitly outlaw homosexuality, spread the toxic morality to native cultures that were far more accepting of homosexuality and queer individuals. Despite the clear evidence of the harm this Act caused, Han and Mahoney also believe that the residual effects of the British Empire's homophobia have not caused current progress towards decriminalisation and liberation to be any slower than in other former colonies of European powers, suggesting that "the 'stickiness' of repressive institutions is relatively consistent across different countries and histories, and not specific to a particular type of colonialism." These arguments, refuting the scholarship of others such as Tielman and Hammelburg, claim that the pervasiveness of European homophobic legislation and institutions is no different across former colonial countries. Back in Britain, the polygamy case of Hyde v Hyde and Woodmansee was the first to deal, indirectly, with same-sex marriage, with Lord Penzance writing that "marriage, as understood in Christendom, is the voluntary union of one man and one woman, to the exclusion of all others."
The Criminal Law Amendment Act 1885, s.11 made any male homosexual act illegal - whether a witness was present or not - meaning that acts committed in private could be prosecuted, whereas before a witness was necessary to secure a conviction. This provision became known as the Blackmailer's Charter (or the Labouchere Amendment), and often a letter expressing terms of affection between two men was sufficient for a conviction, leading to the arrest and jailing of Oscar Wilde in 1895, ten years after the law's passage. In 1897, the first homosexual rights group was founded in England by George Cecil Ives, called the Order of Chaeronea. Ives, who founded the organisation after meeting Oscar Wilde, was a cynic (or a realist, depending on your perspective) who believed that homosexuality would never be decriminalised, and thus used the Order of Chaeronea to act as an underground support network for gay and lesbian people in England, and named his group after the location where the Sacred Band of Thebes, an elite group of homosexual soldiers in Ancient Greece, were finally annihilated. Ives wrote: "We believe in the glory of passion. We believe in the inspiration of emotion. We believe in the holiness of love."
The end of the Victorian Era in 1901 was perhaps, then, a cause for celebration among early LGBTQ+ rights advocates: in 1913, the British Society for the Study of Sex Psychology was founded by a group of theorists and activists with the aim of combating legal discrimination against homosexuality with scientific understanding, but their hope was short-lived, when the Criminal Law Amendment Bill 1921 became the first proposed statute to mention female homosexuality. The bill ultimately failed in the House of Lords, however, as they feared it would draw attention to and encourage women to explore homosexuality. The Roaring Twenties may have been some solace, with increased sexual liberation for all meaning that the LGBT community were enjoying "the radical
responses which established notions of identity were
provoking in the opening decades of the twentieth
century," as Taylor writes, but there was no legal liberation, despite the cultural renaissance. In fact, during this time, the political force that was Gandhi was speaking out against same-sex relationships and other 'unnatural vices.'
Legislatively speaking, the next few decades passed without incident, but the 1950s, in the middle of the post-war boom, saw great progress towards gay rights, with the crime of sexual assault between women being recognised in the Sexual Offences Act 1956 and the landmark Wolfenden Report, published in 1957, which formally recommended to the Parliament of the United Kingdom that homosexuality should be decriminalised. The report, noteworthy for a number of reasons, was commissioned in response to evidence that homosexuality could not legitimately be regarded as a disease. Central to the report's findings was the notion that the State should focus on protecting the public, rather than scrutinising people's private lives, and said that the law should not be based on feelings of "revulsion against what is regarded as unnatural, sinful or disgusting." Following the Wolfenden Report, and sensing revolution in the air, the Homosexual Law Reform Society was founded in 1968 to begin a campaign to make homosexuality legal in the UK. Across the pond, the US Supreme Court case of One, inc v Olesen in 1958, the first case before the Court to deal with LGBT rights, decided that pro-homosexual writing is not, in itself, obscene.
Though the Wolfenden Report was a historic step forward, and in 1962 Illinois made history as the first US state to legalise same-sex consensual activity, the law in the UK had still not changed. Lord Arran's proposal to decriminalise male homosexual acts was roundly rejected in 1965, and a further slap in the face was felt when a poll at the time found 93% of the public saw homosexuality as a form of illness requiring medical treatment. A bill proposed by the Conservative MP Humphry Berkeley to legalise male homosexual relations fell, despite being given a second reading by 164 votes to 107, when Parliament was dissolved, and Berkeley lost his seat - an event he attributed to his support for gay rights. But all was not lost - a year later, the Sexual Offences Bill was introduced by Labour MP Roy Jenkins, the then-Home Secretary, and passed with bipartisan support, even from future right-wing figureheads Margaret Thatcher and Enoch Powell. The Act partially legalised same-sex acts in the UK between men over the age of 21 conducted in private, though the privacy restrictions meant that a third person could not be present, and even that men could not have sex in a hotel. In the same year, New York decided it could no longer forbid bars from serving gay men and women after activists staged a 'sip-in' in a bar, and two years later, in 1969, the fight for LGBTQ+ equality was about to change dramatically.
On June 28th, 1969, police raided the Stonewall Inn, a popular gay bar in New York. Eight police officers marched through the doors, shut off the lights and the music, and announced "We're taking the place!" Panic ensued, with veterans of the raids running for the doors, and newcomers confused and dazed by the commotion. The police barred the exits, and began to carry out what had then become custom: they would line up the patrons, check ID, and anyone claiming to be a woman was taken to the bathrooms for their genitalia to be examined and verified; biological men dressed as women would be arrested. But things didn't go to plan. Men refused to produce their identifications, and those dressed as women refused to be taken to the bathroom. Concerned, the police decided to take all those they suspected to be transvestites to the police station, and released everyone else - but instead of running away, as usual, the patrons gathered by the doors of the Stonewall Inn, and within minutes a crowd of over 100 had amassed while the police waited for transport vans. Police officers began to sexually assault lesbians under the guise of frisking them, and bystanders mockingly saluted and curtseyed for police, but when the police turned violent, pushing a transvestite roughly, the pushed transvestite hitting the police officer with her purse to the applause of hundreds.
When a woman, identified by some to be Storme DeLarverie, was hit by police with a baton after resisting her arrest, she yelled to the onlookers as she was thrown into the van "Why don't you guys do something?" The crowd exploded.
The picture above - the only known photograph of the first night of the Stonewall Riots - shows the homeless youth of the area struggling with police officers, with the Mattachine Society newsletter writing that "the Stonewall became home to these kids. When it was raided, they fought for it. That, and the fact that they had nothing to lose other than the most tolerant and broadminded gay place in town."
The police were wholly unprepared for the night's events - they didn't think that the queer community would fight back, particularly the most outcast of the LGBTQ+ community: the transgender and the homeless. The riots lasted several nights, with vandalism, brutality, and impromptu chorus lines, and the Stonewall Inn's name was carved into queer history.
Over the next weeks and months, queer organisations began forming at an ever-growing pace, with the Gay Liberation Front founded in the UK in 1970 to fight for the rights of LGBT people, and to urge them to question the mainstream institutions in the UK with led to their oppression. This organisation organised the very first UK Pride March in 1972, when 1,000 people marched from Trafalgar Square to Hyde Park in London.
As monumental as Stonewall was, the law, as ever, took time to follow through. The 1970 case of Ashley v Corbett in the UK set the precedent that the birth certificates of transgender and intersex individuals couldn't be changed, and when Maureen Colquhoun, a Labour MP, came out in 1974, she lost the backing of her party and was deselected at the next election, which she lost in the Thatcher wave. Bright spots shone through, however, when the Liberal Party passed a conference resolutionin support of equality for gay people, including an equal age of consent, in 1975, and in the USA, gay politicians made several historic firsts with the election of Elaine Noble as the first openly gay person elected to a state legislature and Harvey Milk, who became the first openly gay male non-incumbent elected in the US when he was elected to the San Francisco Board of Supervisors in 1976. Milk, a figurehead of the gay rights movement in San Francisco, was assassinated two years later by a former colleague, and in response to the lenient sentencing of his assassin in 1979, the gay community rioted, leading to the election of progressive Democrat Dianne Feinstein to Mayor, where she appointed the city's first pro-gay Chief of Police.
In Scotland, the Criminal Justice (Scotland) Act of 1980 decriminalised homosexual acts between two men over the age of 21 in private, and a year later the European Court of Human Rights (ECtHR) struck down Northern Ireland's criminalisation of homosexual acts between consenting adults in the case of Dudgeon v UK. That same year, in 1980, the first UK case of AIDS was reported, leading to the start of blood donation inequality in Britain.
In 1982, Wisconsin became the first state in the US to make it unlawful for private businesses to discriminate based on sexual orientation in employment and housing, and in 1983 Gerry Studds became the first openly gay member of Congress, a year before the election of Chris Smith as the first openly gay MP in the UK. But the 1980s was going to become one of the hardest challenges for gay rights yet, with the raging AIDS pandemic, which led Health Minister Kenneth Clarke to enact powers to detain people with AIDS in hospital against their will, preventing people coming forward for treatment, and, likely swayed by the homophobic response of the West to the crisis, the US Supreme Court upheld a Georgia law criminalising oral and anal sex in private between consenting adults, on the basis that the law did not differentiate between homosexual and heterosexual acts, and so was not considered discriminatory.
The final blow of the decade came in the form of s.28 of the Local Government Act 1988, which prohibited local authorities from 'promoting homosexuality' or 'pretended family relationships' - in essence, ensuring that an entire generation of students would not learn about the existence of their queer friends and neighbours until adulthood, when their prejudices had been formed. The law also prohibited councils from funding educational materials and projects perceived to 'promote homosexuality' and prevented the discussion of LGBT issues, stopping children from getting the support that every queer child needs.
In India, activist and lawyer Siddhartha Gautam founded the ABVA to raise awareness about HIV and protest discriminatory policies in India, including s.377 of the India Penal Code, which criminalised homosexuality. In California, John Stout won a court case against his landlords who tried to prevent him from displaying the rainbow Pride Flag from his balcony, and in the UK, Stonewall UK was founded to oppose the discriminatory s.28 and other barriers to equality.
The pain of the 80s had ended, and the 1990s was about to turn the tide for queer legal liberation.
Tory MP Edwina Currie introduced an amendment in 1994 to lower the age of consent for homosexual acts from 21 to 16, to equalise it with the heterosexual age of consent, but the amendment was defeated and the gay male age of consent was lowered instead to 18; no age of consent was set for lesbians. In the US, President Clinton, perhaps to ward off the growing calls for a complete ban on gay military service, signed into law the Don't Ask Don't Tell policy, which allowed out LGBTQ+ individuals to be dismissed from the armed forces, but permitted closeted ones to do so - what Clinton described as a "major step forward" from the complete ban that had existed prior.
The ECtHR case of Morris and Sutherland v UK in 1996 challenged the homosexual inequality in divided ages of consent under UK law, and the government stated its intention to legislate for equality (despite having rejected the Currie amendment two years prior), and so the Court put the cases on hold. In the US, the case of Romer v Evans saw the Supreme Court strike down a state constitutional amendment in Colorado which prevented anti-discrimination protections for homosexuality and bisexuality, with the Court stating that it violated the equal protection clause of the 14th amendment, and the state lacked a legitimate interest, aside from bigotry. In 1997, China legalised male homosexual sex.
The 21st Century got off to an excellent start with the Armed Forces Order of 2000 ending the ban on queer military service in the UK after the ECtHR ruled it unlawful, and the India National Human Rights Commission formally recommended the repeal of s.377 of the India Penal Code to legalise sexual activity between consenting adults. A year later, the first public gay wedding was held in India.
The UK finally delivered on age of consent equality in 2001, using the provisions of the Parliament Acts of 1911 and 1949 to override the House of Lords, who had rejected the amendment to the Crime and Disorder Bill three times. Under the Act, consensual group sex for gay men was also decriminalised, and a year later, in 2002, same-sex couples were granted equal adoption rights. 2003 saw the repeal of s.28 of the Local Government Act, ending the 15-year prohibition on inclusive education, and the US case of Lawrence v Texas struck down a Texas statute on sodomy, making same-sex sexual activity legal in every US state.
The first legislation passed to protect transgender individuals passed in 2004 with the Gender Recognition Act of 2004, which gave trans people full legal recognition of their gender, allowing them to acquire a new birth certificate and ending the 34 year inequality, and the Civil Partnership Act 2004 allowed same-sex couples to legally enter into marriage-like binding partnerships, with the first civil partnership taking place between Matthew Roche and Christopher Cramp. This was described by Jaspal as "the most significant development in LGB rights since the decriminalisation of homosexuality." Two years later, in 2006, the Equality Act made discrimination against lesbians and gay men in the provision of goods and services illegal, and a 2008 statute allowed lesbians and their partners equal access to legal presumptions of parentage in cases of IVF from the moment the child is born.
The UK Criminal Justice and Immigration Act of 2008 created the new offence of incitement to homophobic hatred, and the murder of Angie Zapata, a transgender woman, saw the first conviction for a hate crime involving a transgender woman in the US. 2009 saw apologies from the Prime Minister Gordon Brown for the treatment of Alan Turing, the WWII code-breaker who was chemically castrated and driven to suicide after police found out he was gay, and then-Leader of the Opposition David Cameron for the introduction of s.28 by his party 20 years prior.
The Matthew Shepard and James Byrd Jr Hate Crimes Prevention Act of 2009 in America expanded federal hate crime law to include crimes motivated by a victim's actual or perceived gender, sexual orientation, gender identity or disability, and gave federal authorities and state agencies additional powers and funding to investigate hate crimes. The Act was named after Matthew Shepard, a gay university student who was tortured to death in Wyoming, and James Byrd Jr, a Black man lynched by white supremacists in Texas.
In India, the New Delhi High Court ruled that homosexual conduct should not be deemed a criminal offence, challenging more than a century of criminalisation in India since the British introduced the India Penal Code in 1860. The court wrote "if there is one constitutional tenet that can be said to be the underlying theme of the Indian Constitution, it is that of 'inclusiveness'... In our view, Indian Constitutional law does not permit the statutory criminal law to be held captive by the popular misconceptions of who the LGBTs are." While the ruling was later overturned in the Supreme Court, s.377 of the India Penal Code was finally abandoned in 2017 on the basis of respect for privacy, a judicial decision that Jain says led to a rise in the level of social acceptance and self-acceptance of homosexuality in India.
Equality legislation continued in the UK with the introduction of the Equality Act 2010, which gave LGBTQ+ employees protections from discrimination, harassment and victimisation at work, and a 2010 asylum case extended judicial protections to gay men from Iran and Cameroon, with Lord Hope writing "to compel a homosexual person to pretend that his sexuality does not exist or suppress the behaviour by which to manifest itself is to deny him the fundamental right to be who he is." In the same year, Phyllis Frye became the first openly transgender judge appointed in the US, and Taiwan introduced LGBT-inclusive education curriculums, in order to "root out discrimination" since students should be able "to grow up happily in an environment of tolerance and respect."
In 2011, alongside the Cypriot decriminalisation of homosexuality (the last European country to do so), and the repeal of Don't Ask Don't Tell in the USA, men who have sex with men were permitted to donate blood after a one-year deferral period, closing the inequality that had existed since the AIDS-era. A year later, Tammy Baldwin of Wisconsin became the first openly gay US Senator, and Kyrsten Sinema became the first openly bisexual person elected to Congress, and later the Senate in 2018.
In 2013, the Defence of Marriage Act was ruled unconstitutional by the US Supreme Court, with Justice Kennedy writing that "the federal statute is invalid, for no legitimate purpose overcomes the purpose and effect to disparage and injure those whom the State, by its marriage laws, sought to protect in personhood and dignity." In the UK, the Marriage (Same-Sex Couples) Act 2013 extended marriage equality, and a year later to Scotland, too.
The US followed suit, legalising same-sex marriage in all 50 states in the case of Obergefell v Hodges, where Justice Kennedy wrote "no union is more profound than marriage, for it embodies the highest ideals of love, fidelity, devotion, sacrifice, and family. In forming a marital union, two people become something greater than once they were. As some of the petitioners in these cases demonstrate, marriage embodies a love that may endure even past death. It would misunderstand these men and women to say they disrespect the idea of marriage. Their plea is that they do respect it, respect it so deeply that they seek to find its fulfillment for themselves. Their hope is not to be condemned to live in loneliness, excluded from one of civilization's oldest institutions. They ask for equal dignity in the eyes of the law. The Constitution grants them that right." That same year, Uganda's Anti-Homosexual Act was nullified, and Kenyan LGBT groups were able to register, thanks to a case brought by activist Eric Gitari, whose six attempts to register his National Gay and Lesbian Human Rights Commission were rejected.
In 2017, legislation passed in the UK pardoning people convicted of, or cautioned for, certain abolished sexual offences in England and Wales, including buggery and sodomy, extending back over five centuries, and 2018 saw the decriminalisation of homosexuality in Trinidad and Tobago, with British Prime Minister Theresa May expressing her deep regret at the role of the British Empire in introducing laws that led to discrimination, violence and death that persists today. Marriage equality was extended to Northern Ireland in 2019, and the 2020 US Supreme Court case of Bostock v Clayton County ruled that the Civil Rights Act 1964 prohibited employment discrimination against LGBTQ+ people.
In the present day, the struggle for queer legal liberation is far from over. A 2020 British court ruled that children under 16 couldn't consent to hormone blocker treatments for gender dysphoria, halting all referrals of under 18s for any form of treatment. Finn has written about the pervasiveness of Evangelical Christian homophobia in Africa, left over from colonial times, asking "since when are human rights supposed to depend on culture? Since when is it OK to hurt people because they're different?" Godfrey attributes the current criminalisation of homosexuality in 34 of Africa's 56 states to be a "direct result of colonialism" and Chen has argued for de-imperialisation in Asia to embrace queer culture and equality, writing that this process "does not mean being completely different from the West, since virtues and features, such as care, rights, flourishing and justice can be shared by every culture." Quinn, a family rights scholar, believes we need to introduce clear parentage rights for LGBT families and continue the fight for marriage equality around the world.
One date from this story is missing, and arguably this is the most important date of all: the date you came out as lesbian, gay, bisexual, transgender, queer, or any other sexuality that deviates from the societal norm of 'straight', or the date your child, your parent, your friend or neighbour came out to you, and entrusted you with their identity. When we come out, we step into a world, a community, and a culture we have not known before; we stand on the shoulders of giants like Marsha P Johnson, the Stonewall hero, and we have to learn the intricate, bloody, and heartbreaking struggle that persists to this day, from activists like Munroe Bergdorf to educators like Olly Pike, and we take our place in a history we did not inherit from our parents, but inherit as our own, and while the law may be slow, and change may be painful, we must remember the words of Harvey Milk: "Burst down those closet doors once and for all, and stand up and start to fight." There is nothing else we can do.
The opinions of this article are solely those of the author and are not intended to provide accurate legal advice for anyone to rely on. While the content is intended to be factually correct, the author does not accept any responsibility or liability arising from the use or misuse of this article or any loss/inconvenience/damage stemming from this. Legal advice should be sought from a qualified professional, not this blog. The opinions represented in this blog are personal and belong solely to the blog owner, and do not represent those of the people, institutions, or organisations that the owner may or may not be associated with in a professional or personal capacity, unless explicitly stated. The views expressed by any podcast guest are their own entirely, and do not necessarily reflect those of the blog owner. The blog owner is not responsible and liable for any discrepancy, if any. Any content provided by this blog or its companion podcast is not intended to malign any religion, ethnic group, club, organisation, company, individual, or anyone or anything.
Sources:
- Steven Dryden, 'A short history of LGBT rights in the UK' (British Library) <https://www.bl.uk/lgbtq-histories/articles/a-short-history-of-lgbt-rights-in-the-uk#>
- Enze Han and Joseph O'Mahoney, 'How Britain's colonial legacy still affects LGBT policies around the world' (The Conversation, 15 May 2018) <https://theconversation.com/how-britains-colonial-legacy-still-affects-lgbt-politics-around-the-world-95799>
- Enze Han and Joseph O'Mahoney, 'British colonialism and the criminalisation of homosexuality' (2014) 27 Cambridge Review of International Affairs 2
- James Finn, 'Fighting for LGBTQ rights is not colonialism' (Medium, 15 May 2020) <https://medium.com/james-finn/fighting-for-lgbtq-rights-is-not-colonialism-b60a1bd6d586>
- Chris Godfrey, 'How the British Empire's gay rights legacy is still killing people to this day' (The Independent, 1 February 2016) <https://www.independent.co.uk/news/world/africa/freedom-expression-fight-lgbt-rights-across-africa-a6834781.html>
- Po-Han Lee 'LGBT rights versus Asian values: de/re-constructing the universality of human rights' (2016) The International Journal of Human Rights 7
- Paul Johnson, 'Buggery and Parliament 1533-2017' (2019) Parliamentary History <https://onlinelibrary.wiley.com/doi/full/10.1111/1750-0206.12463casa_token=dvBOWfcJRYcAAAAA%3AkNetNZOul4LARUZm0HD6H2EJuSLD0fwlBTVp3VqCQd15csUTBvErDTOsZQoEsdW475HRhok3gSz0Ss>
- Rusi Jaspal, 'Why a social psychology of gay men?' (2019) The Psychology of Gay Men <https://link.springer.com/chapter/10.1007/978-3-030-27057-5_1>
- Francois Lafitte, 'Homosexuality and the Law' (1958) 9 Brit J Delinq 8
- Colleen Marea Quinn, 'Riding the storm out after the Stonewall Riots: Subsequent waves of LGBT rights in family formation and reproduction' (2020) 54 U Rich L Rev 733
- Melanie Taylor, Changing Subjects: Transgender Consciousness and the 1920s (2000) <http://etheses.whiterose.ac.uk/10886/1/325697.pdf>
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