Page:Adams ex rel. Kasper v. School Board of St. Johns County, Florida (2020).pdf/68

 biological indicators of male and female (understood in the context of reproductive capacity) … .”).

That “sex” did not mean gender identity is unsurprising. When Congress enacted Title IX in 1972, psychiatric literature conflated sexual orientation with gender identity. See Jack Drescher, Transsexualism, Gender Identity Disorder and the DSM, 14 J. Gay & Lesbian Mental Health 109, 111 (2010). And as with homosexuality, a common belief among psychiatrists was that “trans people [were] severely mentally disturbed.” See id. at 114, 116–17. Indeed, the American Psychiatric Association first classified “Gender Identity Disorders” as psychosexual disorders in which a person’s internal sense of gender did not align with his or her anatomy. See Am. Psychiatric Ass’n, Diagnostic and Statistical Manual of Mental Disorders 261 (3d ed. 1980). Consistent with this view, “[m]ainstream medical thinking” when Title IX became law was firmly opposed to sex-reassignment surgery. Drescher, supra, at 111–12. Even among its proponents, “[s]ex reassignment was … considered not a cure, but a palliative treatment.” Dallas Denny, A Selective Bibliography of Transsexualism, 6 J. Gay & Lesbian Psychotherapy 35, 38 (2002). It is untenable to construe transgender status, which even the medical community saw as a departure from the norm, as altering the norm itself among the general public.