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32 Geo. Mason U. C.R. L.J. 261 (2021-2022)
Pronoun Policies in Public Schools: The Case against First Amendment Exceptions for K-12 Teachers

handle is hein.journals/gmcvr32 and id is 269 raw text is: PRONOUN POLICIES IN PUBLIC SCHOOLS: THE CASE AGAINST FIRST AMENDMENT EXCEPTIONS FOR K-12 TEACHERS Caitlin Ring Carlson & Emma Hansen* INTRODUCTION School is not always a safe place for transgender and gender non- conforming students.1 Recent research shows that many transgender students feel unsafe at school.2 These students are likely to have lower GPAs and miss more school days because of concerns for their safety.3 In certain parts of the country, schools have enacted policies designed to respect students' gender identities by requiring teachers and staff to use gender nonconforming students' chosen names, pro- nouns, and honorifics.4 However, some teachers have resisted these mandates, even though the U.S. Departments of Education and Jus- tice have said that under Title IX, transgender and other gender non- conforming students have the right to be treated according to their gender identity.5 Chosen name use is also linked to reduced depres- sive symptoms, suicidal ideation, and suicidal behavior among trans- gender youth.6 * Caitlin Ring Carlson is an Associate Professor in the Department of Communication and Media at Seattle University. Her research focuses on communication law, policy and ethics, with an emphasis on hate speech. Emma Hansen is a senior in the Department of Communication and Media at Seattle University. 1 Youth & Student Issues, NAT'L CTR. FOR TRANSGENDER EQUAL., https://transequal- ity.org/issues/youth-students (last visited Oct. 19, 2021). 2 Joseph G. Kosciw et al., The 2019 National School Climate Survey, GLESN 1, 16-17 (2019), https://www.glsen.org/sites/default/files/2020-10/NSCS-2019-Full-Report_O.pdf. 3 Youth & Student Issues, supra note 1. 4 Policy Map, GLSEN, https://www.glsen.org/policy-maps (last visited Sept. 12, 2021). 5 Fact Sheet on U.S. Department of Education Policy Letter on Transgender Students, NAT'L CTR. FOR TRANSGEND3ER EQUAL., https://transequality.org/sites/default/files/ED-DCL-Fact- Sheet.pdf (last visited Dec. 15, 2021). 6 Amanda M. Pollitt, Salvatore Loverno & Stephen T. Russell, Predictors and Mental Health Benefits of Chosen Name Use Among Transgender Youth, 53 YOUTH & Soc'y 320, 330-36 (2019). 261