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This paper discusses the case of Bowers v. Hardwick (1986). Petitioner, Bowers, appealed a lower court ruling which found that Georgia's statutory prohibition against sodomy interfered with the Respondent's constitutional right to not be subjected to imminent arrest. In a 5:4 ruling, the Court found in favour of the Petitioner and overturned the lower court ruling. The majority argument was that the Constitution makes no explicit mention of a fundamental right to engage in what the Court called "homosexual sodomy". Drawing on sociopsychological research, the author argues that fear of sexual activities that are unfamiliar, mysterious, or ambiguous foster cognitive distortions that interfere with judicial decision-making. It is argued that in Bowers, the compensatory desire to categorise the world, subjugate ambiguous behaviours to oppressive rules, and condemn these behaviours by invocation of religious doctrine interfere with a rational evaluation of the constitutionality of the Georgia sodomy statute. In place of adequately evaluating the general legal merits of the case, the Court focussed disproportionately—and fruitlessly—on the supposedly exclusive homosexual nature of sodomy per se, even though such conduct was not explicitly mentioned in Georgia's statute.
Until 19981, the State of Georgia held that:
- A person commits the offense of sodomy when he performs or submits to any sexual act involving the sex organs of one person and the mouth or anus of another.
- A person convicted of the offense of sodomy shall be punished by imprisonment for not less than one nor more than 20 years (Georgia Code Ann., 1984).
In 1982, the accused, Hardwick, was charged with violating the Georgia statute by committing the act of sodomy in his own home. Even though the District Attorney at the time elected not to try the case, the accused decided to challenge the constitutionality of the statute. The case was eventually referred to the Supreme Court, which subsequently ruled that the statute did not violate any of the accused's constitutional rights (Bowers v. Hardwick, 1986).
A reading of both the statute and the Supreme Court's decision reveals two concerns:
- The act of sodomy is considered a specific sexual activity that distinctively differs from other forms of sexual behaviour (i.e., penetrative penile-vaginal intercourse).
- The need to label sodomy as such reveals a need to categorise and impose a sense of "order" and "coherence" upon a group of behaviours because they are relatively unfamiliar to many people. The impetus for this is the sense of confusion and fear individuals feel when they are confronted with behaviours that are different, ambiguous, strange, or mysterious to them.
Drawing on sociopsychological literature, this paper will attempt to demonstrate how discourse and the need for imposition of order on the world created specific cognitive distortions that made it difficult for the Court to logically analyse the constitutionality of the Georgia statute. It should be noted that this paper takes no position one way or another as to the moral nature of homosexual conduct. Rather, it focusses exclusively on the psychological processes that influence the extent to which judges meet the rigorous standards for evaluating legal soundness of state statutes.
This matter first appeared before the Federal District Court. Hardwick argued that because he was a practising homosexual, the sodomy statute "placed him in imminent danger of arrest" (Bowers v. Hardwick, 1986, p. 188). The District Court disagreed. On appeal, the Court of Appeals of the Eleventh Circuit reversed the decision, holding that the statute was, indeed, unconstitutional. However, instead of affirming Hardwick's own argument that the Georgia statute violated his constitutional right to be free of "imminent danger of arrest", the Court of Appeals held that the statute was unconstitutional because it prohibited behaviours that are fundamentally private and intimate. The District Attorney appealed to the Supreme Court, which reversed the Court of Appeal's ruling. The Supreme Court focussed on the applicability of Hardwick's citation of previous Supreme Court rulings upholding individuals' constitutional right to make their own decisions in private matters of family and procreation. Essentially, the Court asserted that "homosexual" (p. 190) behaviours such as sodomy have nothing to do with family and procreation and, thus, there is no reasonable basis for arguing that the Constitution fundamentally sanctions sodomy. The Court did not base its ruling on danger of imminent arrest or invasion of privacy.
The four dissenting justices argued that this case is not about a fundamental right to engage in sodomy—or even about a fundamental right to privacy per se. Rather, it is about a fundamental "right to be let alone" (p. 199). They also took issue with the Court's almost "obsessive" (p. 200) focus on sodomy as an apparently "homosexual" activity, arguing that the Georgia statute makes no distinction between homosexual or heterosexual sodomy. Homosexual or not, we all have a fundamental right to determine what goes on in our bedrooms (provided we are not violating others' rights). These justices also wrote that it is a well-settled principle of law that a "complaint should not be dismissed merely because a plaintiff's allegations do not support the particular legal theory he advances, for the court is under a duty to examine the complaint to determine if the allegations provide for relief of any possible theory" (p. 201).
A few psychological analyses of cases similar to Bowers have been made (e.g., American Psychological Association et al., 1986, 1995). They have tended to focus on clinical literature that argues against the pathologisation of homosexual activity. Although very interesting, these are, unfortunately, analyses of assumptions that are not explicitly referred to by the statutes that were brought before the courts. For instance, the question of whether or not homosexuality contributes to poor mental health outcomes is not particularly relevant because, textually, statutes such as Georgia's do not even remotely hint towards a homosexual bias (even though they probably were tabled in the spirit of homophobia). If psychology is to offer anything of use to the judicial process in such matters, it would do best to focus on more relevant issues, such as the over all role of assumptions and cognitive distortions in decision-making. In Bowers, these distortions made it unlikely that the Court's concurring justices would even fathom analysis of the complete constitutionality of the Georgia statute—the task with which they were initially charged.
Before proceeding, it should be noted that the arguments raised in this paper will actually draw from literature on attitudes towards homosexuals. This may seem contradictory to the paper's de-emphasis on homosexual issues. However, this literature is very instructive because it focusses strongly on sociopsychological principles generally. Indeed, the studies and arguments explicated in this literature can be equally applied to attitudes towards any people.
When we use the word "sex" in everyday discourse, we usually do not stop to question the specific types of sexual activity that are being referred to. Even when we specifically mention "sexual intercourse" (or, to draw on a legal example, "sexual assault"), we usually do not care whether the reference is specifically to penile-vaginal sex, anal contact, fellatio, or cunnilingus. Even if the reference is specifically to anal contact, we still lump the specific activity into a broader, general category—that of "eccentricity" or (incorrectly) "paraphilia". We rarely stop to think about the significance of the specific act of anal contact itself, unless it is the very specific focus of conversation (as in talks about safe sex behaviour). In both the Georgia statute and Bowers, however, very specific mention was made of "sodomy". Why did this happen and what were the implications for cognitive process and effective decision-making?
Statistically, sodomy appears to be fairly rare (Michael et al., 1994)2. Although most people know what it is (indeed, it is described explicitly in Georgia's statute), it may seem ambiguous, foreign, or unknown to some of us because we do not practice it regularly. That which is foreign or unknown is often frightening (Cicirelli, 2001, 1999; Graham & Gaffan, 1997; Fullerton, McCarroll, & Ursano, 1992; Powell, 1992; King, Gullone, Ollendick, 1990; Mitchell & Mudd, 1957; Grinberg & Grinberg, 1984). In fact, Nomberg-Silver (2001) showed that individuals who themselves were sexually ambiguous ("inconsistent in sexual identity and sexual behaviours", p. 6188) scored high on tests of annihilation anxiety (i.e., fear that they would cease to exist). Weinberg (cited in Nichols, 1997) describes the nature of this fear: "I realised when I went to Washington D.C., a woman I met there was terrified about being alone in a room with me. As soon as her male friends left the room she began to tremble and almost couldn't speak and I realized she thought I was a homosexual and she was extremely phobic about me" (p. 1). Relevant in Bowers is how this fear of the unknown was mediated by maladaptive cognitive mechanisms.
One potent way to reduce fear of the unknown is, obviously, to gain "information" about that which is unknown. A fast and convenient source of information (which we think is reliable) is a label. Macrae, Milne, and Bodenhausen (1994) had a group of subjects monitor an audio-taped prose passage. At the same time, the subjects were asked to form impressions of targets who also had pre-assigned stereotype labels (e.g., "skinhead"). These students did better on the prose monitoring task than the students who were not presented with stereotype labels. The investigators proposed that the stereotype labels gave the subjects enough handy information that they did not have to waste cognitive resources on searching for other information that would help them with the task of forming impressions of the targets.
In Bowers, labelling anal contact gave the judges "information" about such contact, thus reducing any latent anxieties or fear of the unknown (in this case, an unknown form of sexual activity). Yet the labelling came at a price to Hardwick. First, the labelling sharply focussed the Court on the deviant nature of the act itself, thus distracting the judges from the actual legal question with which it was initially charged—to determine whether criminalising sodomy put the defendant in danger of imminent arrest or invaded his privacy. The Court became obsessed with the theme of deviance, with Justice Burger prefacing his arguments by citing the historical nature of this most "heinous act"—"the infamous crime against nature" (p. 197). The distracting quality of labels is quite apparent when we consider that the labels themselves are what often cause this distraction in the first place:
Social groups create deviance by making the rules whose infraction constitutes deviance, and by applying those rules to particular people and labeling them as outsiders. From this point of view, deviance is not a quality of the act the person commits, but rather a consequence of the application by others of rules and sanctions to an "offender" (emphasis in original). The deviant is one to whom the label has successfully been applied; deviant behavior is behavior that people so label (Becker, 1963, quoted in Adler & Adler, 1996; see also Goffman, 1963).
More detrimental to Hardwick, however, was the use of labelling in invoking another mechanism of fear-reduction: categorisation. Indeed, if labelling is to give us new fear-reducing "information", it must go beyond a labelling of behaviours themselves; it must extend also to those who perform those behaviours. When we say that certain people perform certain labelled acts, we are engaging in categorisation. Fiske and Neuberg (1990, cited in Macrae, Milne, & Bodenhausen, 1994) write of the utility of categorisation: "[We] are exposed to so much information that we must in some manner simplify our social environment. . .for reasons of cognitive economy, we categorize others as members of particular groups—groups about which we often have a great deal of generalized, or stereotypic, knowledge" (p. 37). It might follow that people with a low tolerance for ambiguity or mystery (i.e., ambiguous sexual activity such as sodomy) have a greater need than others to categorise the world coherently. As Herek (1984) writes:
Some people feel the need for categorization so strongly that they increase their liking for a person simply because she or he labels another as homosexual. [In fact], homosexual persons who violate stereotypical expectations (e.g., masculine gay men and feminine lesbians) may actually be disliked (emphasis in original, p. 2).
Categorisation also assuages fear because it gives order to—and hence subjects to human control—an otherwise unknown and uncontrollable area of life. Young-Bruehl (1996) suggests the following:
When the differences between [homophobics] and certain types of homosexuals are clear [i.e., when they have "information"], homophobes are less strident about categories. They can go to Mardi Gras in New Orleans and enjoy being photographed with the drag queens. But when homosexuals are too close to home—when they hold hands or kiss in public like heterosexuals—the line of difference, the categorization, is threatened and homophobes are enraged (p. 144).
In Bowers, the labelled act "sodomy" was considered to be performed by the labelled group "homosexuals". The Court felt that "no connection between family, marriage, or procreation on the one hand and homosexual activity on the other has been demonstrated" (p. 191). The assumption was that family and procreation is the exclusive domain of another labelled group—"heterosexuals". In essence, because sodomy has nothing to do with procreation (a domain in which individuals are given a fundamental right to make their own choices), the judges could not fathom why its prohibition might be unconstitutional. Furthermore, because sodomy was given a label, it became, in essence, part of the "public sphere". The consequence was an inability to appreciate Hardwick's argument that prohibitions against sodomy are unconstitutional because they interfere with one's fundamental right to maintain the privacy of one's intimate relations. Yet to the Court, sodomy had nothing to do with intimacy because sodomy is just as much a "public" act (by virtue of its being publicly labelled, in the public sphere of a court of law) as an intimate, private act. In both cases, strident categorisation created a cognitive set that prevented consideration of any alternative legal implications of the sodomy statute (e.g., that the statute places practising homosexuals in imminent danger of arrest).
Is there support for the idea that those with a low tolerance for ambiguity are more likely than others to engage in this sort of categorisation? A study by Michael and Gordon (1998) does seem to provide some support. The Personal Need for Structure (PNS) questionnaire, along with the Attitudes Toward Lesbians and Gays Scale (ATLG) was given to 539 undergraduate students. Results showed that those with a high, as opposed to low, need for personal structure held more negative attitudes towards homosexuals. Relevant to Bowers, two conclusions can be suggested. First, fear of the unknown led to labelling, which led to categorising, which in turn veered the Court from the legal issues at hand. Second, the legal profession and the judiciary revolve around laws, which themselves are categorically ordered. It might be reasonable to suggest that those who work in the field have accepted the structured, categorical nature of the law. Therefore, they would be more likely than others to endorse the kind of (dangerous) stereotypical categorisation that this paper highlights.
Indeed, when Patel & Long (1995) administered the Minnesota Multiphasic Personality Inventory—a widely-used test that measures the relationship between personality traits and personal and social adjustment—to male college students, they found that those with high scores on Scale 5 (masculinity, practical orientation to life, and narrow range of interests) tended to have more homonegative attitudes than those scoring lower on the scale. If fear of the unknown leads to categorisation (a behaviour reasonably ascribed to those with a practical life orientation), and members of the judiciary are practically-oriented, then we can suggest that it is not unlikely that categorisation played a significant role in Bowers. (Of course, there is one caveat: Patel administered the MMPI to students at two coastal military bases. Students at such institutions might generally have more negative feelings towards homosexuals—which include fear—and, therefore, might not be representative of the judiciary as a whole.)
This leads naturally to discussion of another ambiguity- and fear-reducing mechanism used by the Court: impulsive, excessive, and tenuous invocation of legal precedent. Such invocation is a convenient way to manage ambiguous feelings—if something is strange (scary) to us, we can demystify it by subjugating it to authority. The reasoning is that if the law says something is bad, then we "know" something about it. Even if what we know is merely that something is "bad", some "knowledge" is better than none. In Bowers, the Court "knew" much about sodomy because it was informed by old case law. As Justice Burger proclaimed, "proscriptions against sodomy have very 'ancient roots'. Decisions of individuals relating to homosexual conduct have been subject to state intervention throughout the history of Western civilization. . .Homosexual sodomy was a capital crime under Roman law" (p. 194). Yet in its efforts to make sense of the world, the Court got caught up in Greco-Roman prohibitions against the "infamous crime against nature" (p. 194) and did not consider such reasoned—although less dramatic and less authoritative—legal arguments as those concerning danger of imminent arrest.
Not surprisingly, it has been shown that those who rely on authority to make decisions (i.e., those who have a so-called authoritarian personality) often demonstrate significant homonegativity (e.g., Whitley, 2000a, 2000b; Basow, 2000) and its related cognitive distortions. Interestingly, it has also been shown that those who feel that homosexuality is biologically determined are less likely than others to harbor condemning attitudes. Hegarty (2001) gave 116 undergraduates a questionnaire to assess their attitudes towards homosexuality. They were then asked to read a false news story that claimed that a relationship exists between homosexuality and birth order. Those who believed the story endorsed more positive attitudes towards homosexuality when the questionnaire was administered a second time. Again, we might conclude that when people come to believe that something has a reason, it is no longer mysterious (and hence fearful) to them. In the absence of mystery, negative attitudes stemming from fear-reducing stereotypes are less likely to persist.
If historical precedent were insufficient to dismiss Hardwick's case, Justice Burger took additional steps and started to invoke religious prohibitions against sodomy: "To hold that the act of homosexual sodomy is somehow protected as a fundamental right would be to cast aside a millennia of moral teaching" (p. 197). This is little surprising because research has shown a consistent association between religiosity and negative attitudes towards non-traditional sexuality. This is not to say, of course, that religiosity causes such attitudes or that such attitudes lead to religiosity. However, the excessive invocation of religion in Bowers is suspect and does seem to fit in with the over all thesis that fear of the ambiguous can lead to ineffective cognitive sets. Fulton, Maynard, and Gorsuch (1999) gave 257 students from a conservative Christian college a Bogardus Social Distance Scale (a measure of negative attitudes towards specific groups) and the Attitudes Toward Lesbians (ATL) and Attitudes Toward Gay Men (ATG) questionnaires. Results showed that there was, indeed, a relationship between fundamentalism and homonegativism, but that the latter was "in excess of what is required by. . .[a given] ideology" (p. 14). Here we have some support for the idea that when ambiguous people or behaviours are considered (i.e., gays), religious doctrine might be invoked for reasons other than ideology. These reasons might very well be self-protective, especially considering that Plugge-Fousst (2000) found an association between religious ideology and irrational beliefs as measured by Ellis's Irrational Beliefs Scale. In any event, invocation of religious doctrine fully detracts from the general legal merits of a case.
If cognitive distortions based upon fear are common in the courtroom, where does this leave us? First, it is suggested that judges test the integrity of the categories they impose on litigants by applying their judgments to members of other categories. In Bowers, the absurdity of the Court's rigid categorisations might have become more apparent if the justices had tried applying their judgment against Hardwick (a homosexual) to heterosexuals. As one of the dissenting justices mused, one could only imagine the uproar that would ensue if the Court's opinion made it explicitly clear that references to "sodomy" apply equally to heterosexuals as to homosexuals. The general public would surely condemn a judiciary that explicitly prohibits certain consenting, heterosexual behaviours. It is also suggested that judges attempt to play "devil's advocate" amongst themselves, actively testing the rationality of their judgments by considering opposite judgments. This method is particularly effective in reducing irrational "groupthink" behaviours (see Janis, 1982), which are quite likely to occur in a group of nine decision-makers.
Most importantly, however, is the need for judges to critically and honestly evaluate their own emotional responses—feelings of ambiguity, apprehension, and fear. They should remind themselves that these feelings are, indeed, acceptable; they are, after all, human feelings. A true acceptance of the nature of these affective responses will help judges bring them more fully into consciousness. There, they can be more critically evaluated. The longer that these affective responses remain unconscious, the greater the likelihood that they will be dealt with through the kinds of maladaptive cognitive mechanisms that have been explored in this paper.
To return to a caveat mentioned earlier, the thrust of this paper has not been to investigate the nature and morality of homosexual conduct. Indeed, the Georgia statute in question made no explicit mention of differences between heterosexual and homosexual sodomy. The focus has been on the kinds of cognitive mechanisms that can strangle legal evaluations of any case or statute. The research studies referred to have, indeed, focussed on attitudes towards homosexuality, but this should not be taken to mean that this paper is concerned primarily with this area of sexuality. The studies were useful because they seem to illustrate most cogently the powerful influence of cognitive mechanisms which interfere with rational thinking in all areas of life. I think that a critical study of fear of the unknown and the attendant responses to it is one of the best ways in which psychology can contribute to the improvement of the judicial system—and to the respect that all litigants deserve. Indeed, as Michael Kirby of the High Court of Australia has written, "Those who cause [mistreatment of litigants], and not those whom they target, are the ones who need the assistance of scientific psychology and psychiatry and. . .those who are their targets need the strong assistance, protection and equal justice of the law" (Kirby, 2000, p. 139; see also Hill, 2000).
[1.] In 1998 the Georgia Supreme Court eventually struck down the state's sodomy statute (see Powell v. The State, 1998 and Lambda Legal Defense and Education Fund, 1998).
[2.] In one of the largest studies on sexual behaviours and preferences ever conducted, Michael et al. (1994) found that among heterosexuals (who comprise the majority in our society), only about 20-30% have ever engaged in anal intercourse and, even though most had engaged in oral sex at some point in their lives, less than half found it "significantly appealing". To this author, this suggests that anal sex (and to some extent, oral sex) are somewhat outside the "norm" (in terms of prevalence, preference, or both).
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Copyright © 2002, by Eddy M. Elmer
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