Case 1:20-cv-10015-DJC Document 30 Filed 07/20/20 Page 1 of 98
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS
EQUAL MEANS EQUAL, | THE YELLOW ROSES, | KATHERINE WEITBRECHT, | Plaintiffs, | | | v. | | Civil Action No. 20-cv-10015-DJC | DAVID S. FERRIERO, in his official | Capacity as Archivist of the United States, | Defendant. | ______|
AMENDED BRIEF OF AMICI CURIAE INCLUDING THE ALICE PAUL INSTITUTE, ELIZABETH CADY STANTON TRUST, NATIONAL WOMEN’S POLITICAL CAUCUS, NATIONAL CONGRESS OF BLACK WOMEN, MOMS IN OFFICE, MADMOMS, HUMAN RIGHTS AND DIVERSITY COMMISSION OF THE INTERNATIONAL BROTHERHOOD OF TEAMSTERS, SCREEN ACTORS GUILD - AMERICAN FEDERATION OF TELEVISION AND RADIO ARTISTS (SAG-AFTRA), UNITED CHURCH OF CHRIST, TURNING POINT SUFFRAGIST MEMORIAL ORGANIZATION, WOMEN’S NATIONAL HISTORY ALLIANCE, SEVERAL NOW CHAPTERS AND ERA COALITIONS AND MANY OTHERS IN SUPPORT OF PLAINTIFFS’ AMENDED COMPLAINT Case 1:20-cv-10015-DJC Document 30 Filed 07/20/20 Page 2 of 98
TABLE OF CONTENTS
INTEREST OF AMICI CURIAE ...... 2
ARGUMENT ...... 3 I. THE EQUALITY OF ALL CITIZENS IS ESSENTIAL TO AMERICAN DEMOCRACY ...... 3 A. American Democracy Is a Form of Liberal Democracy, Based in Large Measure on the Equality of Citizens, Purportedly Enshrined in the Constitution...... 3 B. Under the Common Law, Married Women Were Legal Non-entities...... 7 C. The First Women’s Rights Convention at Seneca Falls, New York, in 1848, Declared That Women and Men Were Equal and Listed Discriminatory Laws and Practices to Be Rectified in Their Declaration of Sentiments...... 9 D. For the First Time, the ERA Will Provide Women the Right to Have Equal Treatment under Law in Our Constitution...... 15 II. WOMEN ARE DEPRIVED OF FULL CITIZENSHIP UNDER THE CONSTITUTION WITHOUT THE ERA...... 16 A. Poverty Rates of Women and Children Will Be Ameliorated by the ERA...... 18 B. The ERA Will Help Equalize Access to Education for Women...... 22 C. Sex-based Discrimination Has a Deleterious Effect on Women’s Health...... 23 D. The ERA Will Help Curb Violence Against Women by Placing Equal Value on Women and Rectifying Discriminatory Laws...... 24
CONCLUSION...... 25
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CERTIFICATE OF COMPLIANCE ...... 27
CERTIFICATE OF SERVICE...... 27
ADDENDUM Amici Curiae...... 28 Activism Caucus of The Association For Women In Psychology ...... 28 Albuquerque Center for Peace and Justice ...... 29 Alice Paul Institute...... 30 Allies Reaching for Equality ...... 30 American Association of University Women of Florida ...... 32 American Association of University Women – Michigan Chapter...... 33 Campus Safety Advocacy Group ...... 34 Coalition to Abolish Slavery and Trafficking (CAST) ...... 35 CODEPINK ...... 35 Dr. Bronner’s Family Foundation ...... 37 Elizabeth Cady Stanton Trust ...... 38 ERA Minnesota ...... 39 ERA-NC Alliance ...... 39 Fairfax County Commission for Women ...... 40 Flora's Refuge and Resource ...... 41 FOR FREEDOMS ...... 42 Fuerza Mundial Global ...... 42 Fund for Women Artists, Inc. dba WomenArts...... 43 Houston Women's March On...... 43 Human Rights and Diversity Commission International Brotherhood of Teamsters ...... 44 Indivisible Worcester Maryland ...... 46 Institute on Violence, Abuse and Trauma ...... 46 Isle Of Wight County Humane Society ...... 47 L.I.N.D.A Organization ...... 48 MadMoms Fight For Justice ...... 48 Michigan ERAMerica ...... 50 Michigan Woman Forward ...... 51 Mid County Psychological Associates ...... 51 Moms in Office ...... 52 National Coalition Against Violent Athletes...... 52
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National Congress of Black Women, Inc...... 53 National Equal Rights Amendment Alliance...... 54 National Girls Health and Justice Institute ...... 55 National Women’s Political Caucus ...... 56 New Jersey Crime Victims' Law Center ...... 57 National Organization for Women - Seattle Chapter ...... 59 ERA Task Force Albuquerque Chapter of NOW ...... 59 Florida NOW ...... 60 Northern New Jersey NOW ...... 60 Santa Fe NOW ...... 61 Nurtured Parent ...... 62 Organic Consumers Association ...... 62 Rethinking Eve LLC ...... 63 SAG-AFTRA ...... 64 Senior Care Options, Inc...... 65 Turning Point Suffragist Memorial Organization ...... 66 The Women's Coalition ...... 66 Trafficking in America Task Force ...... 67 TransLatin@ Coalition...... 68 United Church of Christ...... 68 Virginia Sexual and Domestic Violence Action Alliance ...... 69 The Woman’s Club of Olympia...... 70 Women NC...... 70 Women’s Equal Rights Legal Defense and Education Fund ...... 71 Women’s National History Alliance ...... 72 Zonta Club of Kenmore ...... 72
SUPPLEMENTAL ADDENDUM...... 73 Additional Amici Curiae ...... 73 Culture Reframed ...... 73 Democrats Abroad ...... 74 Driftwood Kitchen Design...... 76 Fiduciary Trust International ...... 76 Global Indigenous Council ...... 77 Hollywood NOW ...... 79 Kuta Intellectual Property Law, LLC ...... 79 Moms Fight Back ...... 80
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Picture Social Justice ...... 82 Real Estate Advisors Group...... 82 Sustainable Marin...... 83 Veterans For Peace...... 85 Wisdom Lotus Foundation Inc...... 86
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TABLE OF AUTHORITIES
Cases
Commonwealth v. King, 374 Mass. 5, 21 (1977) ...... 16
Craig v. Boren, 429 U.S. 190, 197 (1976)...... 15
United States v. Virginia, 518 U.S. 515, 532 (1996)...... 15
United States v. Yazell, 382 U.S. 341, 361, 86 S.Ct. 500, 15 L.Ed.2d 404 (1966)...... 8
United States Constitution
U.S. Const. amend. XIV, § 1 ...... 15
U.S. Const. art. V ...... 6
Statutes
86 STAT. 1523 (1972), NATIONAL ARCHIVES AND RECORDS ADMINISTRATION: JOINT RESOLUTION OF MARCH 22, 1972, 86 STAT 1523, PROPOSING AN AMENDMENT TO THE CONSTITUTION OF THE UNITED STATES RELATIVE TO EQUAL RIGHTS FOR MEN AND WOMEN (copy of original available at https://catalog.archives.gov/id/7455549)...... 7, 13
MODEL PENAL CODE § 213.1 (1962), ...... 8
N.C. GEN.STAT. § 14-27.34 (2019)...... 8
OKLA. STAT. Tit. 21 § 1111(B) (2019)...... 8
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Other Authorities
Alaa Elassar, What You Need to Know About Today’s Women’s March, CNN, Jan. 18, 2020 (available at https://www.cnn.com/2020/01/18/us/national-womens-march-explainer-trnd/index .html)...... 15
Alice Paul Institute, The Equal Rights Amendment: A Brief History, (available at https://www.alicepaul.org/wpcontent/ uploads/2019/05/ERA-A-History.pdf)...... 13
Ariane Hegewisch, Women Gain Jobs in Construction Trades but Remain Underrepresented in the Field, INSTITUTE ON WOMEN’S POLICY RESEARCH, Mar. 28, 2019, (available at https://iwpr.org/publications/women-jobs-construction-underrepresented/) . . . . 22
BACHELORS DEGREE ONLINE: FEMALE ENGINEERS WHO HELPED PAVE THE WAY, (2012) (available at https://www.bachelorsdegreeonline.com/blog/2012/10-female-engineers-who-help ed-pave-the-way/) ...... 22
Carissa R. Showden, Domestic Violence, in SOCIAL ISSUES IN AMERICA: AN ENCYCLOPEDIA, (James Ciment, ed.), 2006, 548-561, 551 (available at https://books.google.com/books/about/Social_Issues_in_America.html?id=ru3qBg AAQBAJ)...... 8
Carliner, Sarvet, Gordon, and Hasin, Gender Discrimination, Educational Attainment, and Illicit Drug Use Among U.S. Women, 52 SOCIAL PSYCHIATRY AND PSYCHIATRIC EPIDEMIOLOGY, 3, 279–89 (2017)...... 23, 24
Causes, Protective and Risk Factors, in Ending Violence Against Women and Girls: Progamming Essentials, pp. 8-9, UN WOMEN VIRTUAL KNOWLEDGE CENTRE TO END VIOLENCE AGAINST WOMEN AND GIRLS, June, 2013 (available at https://www.endvawnow.org/en/articles/300-causes-protective-and-risk-factors-.ht ml)...... 25
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CENTER FOR AMERICAN WOMEN IN POLITICS: CURRENT NUMBERS, State Legislature (2020) (available at https://cawp.rutgers.edu/state-by-state) ...... 17
CENTER FOR AMERICAN WOMEN IN POLITICS: CURRENT NUMBERS, Women in the U.S. Congress (2020) (available at https://cawp.rutgers.edu/current-numbers) . . 17
CONSTITUTIONFACTS.COM: DRAFTING THE DECLARATION OF INDEPENDENCE, (Declaration of Independence was drafted from June 11 to July 5, 1776)...... 5
Courtney Connley, The Coronavirus Pandemic Further Highlights Why Women Workers Need Equal Pay, CNBC, (Mar. 31, 2020), (available at https://www.cnbc.com/2020/03/31/how-the-pay-gap-hurts-low-wage-women-wor kers-impacted-by-the-coronavirus.html) ...... 20, 24
ELIZABETH CADY STANTON, EIGHTY YEARS AND MORE REMINISCENCES 1815- 1897 (1898), Kindle edition ...... 9
Francis Fukuyama, Poverty, Inequality, and Democracy: Dealing with Inequality, 22 JOURNAL OF DEMOCRACY, 3, (July 2011), 79-89 (available at https://muse.jhu.edu/article/444760/pdf) ...... 16
H.J.Res. 75, 68th Cong. (1923) (unenacted), NATIONAL ARCHIVES AND RECORDS ADMINISTRATION: H.J. Res. 75, Proposing an Equal Rights Amendment to the Constitution, (available at https://catalog.archives.gov/id/7452156) ...... 13, 13
HISTORY OF WOMAN SUFFRAGE VOL I, (Elizabeth Cady Stanton, Susan B. Anthony, & Matilda Joslyn Gage, eds., 1881), Kindle e-book,...... 10, 11
HISTORY OF WOMAN SUFFRAGE VOL II, (Elizabeth Cady Stanton, Susan B. Anthony, & Matilda Joslyn Gage, eds., 1881), Kindle e-book ...... 12
HISTORY OF WOMAN SUFFRAGE VOLS I-VI, (Elizabeth Cady Stanton, Susan B. Anthony, Matilda Joslyn Gage, Ida Husted Harper, Jane Addams, Anna Howard Shaw, Harriot Stanton Blatch, & Alice Stone Blackwell eds., 1881-1922), Kindle e-books...... 11
HISTORY: SENECA FALLS CONVENTION BEGINS, (available at
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https://www.history.com/this-day-in-history/seneca-falls-convention-begins) . . 10
INSTITUTE ON WOMEN’S POLICY RESEARCH: CENTER ON EQUITY IN HIGHER EDUCATION BLOG (available at https://iwpr.org/issue/employment-education-economic-change/center-equity-high er-education/) ...... 22
INSTITUTE ON WOMEN’S POLICY RESEARCH: INVESTING IN SINGLE MOTHERS’ HIGHER EDUCATION (available at https://iwpr.org/issue/employment-education-economic-change/center-equity-high er-education/investing-single-mothers-higher-education/) ...... 23
INSTITUTE ON WOMEN’S POLICY RESEARCH: PAY EQUITY & DISCRIMINATION (available at https://iwpr.org/issue/employment-education-economic-change/pay-equity-discrim ination/)...... 19, 20
INSTITUTE ON WOMEN’S POLICY RESEARCH: STILL A MAN'S LABOR MARKET: THE SLOWLY NARROWING GENDER WAGE GAP (available at https://iwpr.org/publications/still-mans-labor-market/)...... 20, 21
INSTITUTE ON WOMEN’S POLICY RESEARCH: STEM INNOVATION (available at https://iwpr.org/issue/employment-education-economic-change/stem-innovation/)...... 22
Jena McGregor, After Years of ‘Glacial’ Change, Women Now Hold More than 1 in 4 Corporate Board Seats, THE WASHINGTON POST, July 17, 2019, (available at https://www.washingtonpost.com/business/2019/07/17/after-years-glacial-change- women-now-hold-more-than-corporate-board-seats/) ...... 18
Kaveh Waddell, The Exhausting Work of Tallying America’s Largest Protest, THE ATLANTIC, Jan. 23, 2017 (available at https://www.theatlantic.com/technology/archive/2017/01/womens-march-protest-c ount/514166/)...... 14
Kira Sanbonmatsu, Women’s Underrepresentation in the U.S. Congress, DAEDALUS, (Winter 2020), 40-55, at 40...... 18
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Lauren Sudeall Lucas, Identity as Proxy, 115 COLUM. L. REV. 1605 (2015). . . . 16
Letter from Abigail Adams to John Adams, from Braintree, Massachusetts, March 31, 1776, p. 2. (See entire letter and a copy of the original) (available at https://www.masshist.org/digitaladams/archive/doc?id=L17760331aa) ...... 5
Letter from David S. Ferriero, Archivist of the United States, to the Hon. Carolyn Maloney (October 25, 2012), (available at https://www.congress.gov/116/meeting/house/109330/documents/HHRG-116-JU1 0-20190430-SD007.pdf)...... 14
Matthew Hale, THE HISTORY OF THE PLEAS OF THE CROWN, 628 (1736)...... 8
Max Fisher, Scalia says Constitution Doesn’t Protect Women From Gender Discrimination, THE ATLANTIC, Jan. 1, 2011 (available at https://www.theatlantic.com/politics/archive/2011/01/scalia-says-constitution-doe sn-t-protect-women-from-gender-discrimination/342789/)...... 15
NATIONAL ARCHIVES AND RECORDS ADMINISTRATION: HOW DID WOMEN WIN THE 19TH AMENDMENT? A STRATEGY FOR SUFFRAGE, (45th Cong. 2nd Session, Congressional Record entry January 10, 1878...... 12
NATIONAL ARCHIVES AND RECORDS ADMINISTRATION: THE CONSTITUTION OF THE UNITED STATES: A TRANSCRIPTION (available at https://www.archives.gov/founding-docs/constitution-transcript)...... 6, 7
NATIONAL WOMEN’S LAW CENTER: NWLC RESOURCES ON POVERTY, INCOME, AND HEALTH INSURANCE IN 2017 (available at https://nwlc.org/resources/nwlc-resources-on-poverty-income-and-health-insuranc e-in-2017/) ...... 19
NATIONAL WOMEN’S LAW CENTER: WOMEN IN LOW-PAID JOBS (available at https://nwlc.org/resources/when-hard-work-is-not-enough-women-in-low-paid-job s/) ...... 19
Paula J. Caplan, Balancing Career and Family, THE PORTABLE MENTOR: EXPERT GUIDE TO A SUCCESSFUL CAREER IN PSYCHOLOGY. Mitchell Prinstein and Marcus
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Patterson, eds.), Cambridge, UK: Cambridge University Press, (scheduled for 2020 publication)...... 18
Pippa Norris and Ronald Inglehart, Women and Democracy: Cultural Obstacles to Equal Representation, 12 JOURNAL OF DEMOCRACY, 3, (July 2001), 126-40.. . . 17
Plaintiffs’ Amended Complaint for Equitable and Injunctive Relief and for Relief under the All Writs Act, Doc. 5, filed February 29, 2020...... 14, 24
Plaintiffs’ Memorandum of Points and Authorities in Opposition to Defendant’s Motion to Dismiss, Doc. 13, filed June 1, 2020, pp. 27-31, n.28-35 ...... 14, 24
Plaintiffs’ Surreply Doc. 22, filed June 17, 2020, at 4, n.5...... 25
Sarah Jane Glynn, Breadwinning Mothers Continue To Be the U.S. Norm, CENTER FOR AMERICAN PROGRESS, (May 10, 2019). (available at https://www.americanprogress.org/issues/women/reports/2019/05/10/469739/brea dwinning-mothers-continue-u-s-norm/)...... 21
Sharun W. Mukand & Dani Rodrik, The Political Economy of Liberal Democracy, THE ECONOMIC JOURNAL, April 2020, pp. 765–792, (available at https://drodrik.scholar.harvard.edu/files/dani-rodrik/files/the_political_economy_o f_liberal_democracy_ej.pdf) ...... 3, 4, 25
THE AMERICAN ASSOCIATION OF UNIVERSITY WOMEN: BARRIERS AND BIAS - THE STATUS OF WOMEN IN LEADERSHIP, 2016 (Report available at https://www.aauw.org/app/uploads/2020/03/Barriers-and-Bias-nsa.pdf) ...... 18
THE COMPLETE HISTORY OF THE WOMEN'S SUFFRAGE MOVEMENT IN U.S., Musaicum Books 2018) Kindle Edition...... 11
THE WORLD BANK: UNREALIZED POTENTIAL: THE HIGH COST OF GENDER INEQUALITY IN EARNINGS, May 30, 2018. (available at https://www.worldbank.org/en/topic/gender/publication/unrealized-potential-the-h igh-cost-of-gender-inequality-in-earnings) ...... 20
Thomas G.West, Jaffa versus Mansfield: Does America Have a Constitutional or
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a “Declaration of Independence” Soul? 31 PERSPECTIVES ON POLITICAL SCIENCE 4 (Fall 2002), 237-40...... 6
UNITED STATES CENSUS BUREAU: QUICK FACTS, Population estimates as of July 1, 2019...... 3, 4, 17
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INTEREST OF AMICI CURIAE1
The Amici Curiae are sixty-nine mostly non-profit organizations and associations, representing millions of members from across the United States, including The Alice Paul Institute and the Elizabeth Cady Stanton Trust, which both promote the legacies of two pivotal suffragists and women’s rights activists in American history.
Although Amici have otherwise diverse views, they all work to promote equality for women in the law, society, education, workplace, and / or family.
They collectively believe that the “Equal Rights Amendment” (“ERA”) is critical to bring women to full equality in our country. It is a notion, a value, and a right that is 244 years overdue.
The listing of the initial fifty-six Amici Curiae appears in the Addendum and the listing of the additional thirteen Amici Curiae appears in the Supplemental
Addendum, with their respective interest statements.
1All parties assented to filing this Brief of Amici Curiae. No party or party’s counsel authored this brief in whole or in part, and no person other than Amici or counsel for Amici contributed money that was intended to or did fund the preparation or submission of this brief. The only substantive changes in this Amended Brief of Amici Curiae are in this section, the Supplemental Addendum and footnote 68.
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ARGUMENT
I. THE EQUALITY OF ALL CITIZENS IS ESSENTIAL TO AMERICAN DEMOCRACY
A. American Democracy Is a Form of Liberal Democracy, Based in Large Measure on the Equality of Citizens, Purportedly Enshrined in the Constitution.
Equality is a bedrock principle of American Democracy. The United States
is a “liberal democracy,”2 which can be defined as a government where citizens have property rights, political rights, and civil rights.3 “‘Political rights’ refer to free and fair elections; ‘civil rights’ combine measures of independent judiciary, rule of law, and equal treatment.”4 “The truly distinctive nature of liberal democracy is the protection of civil rights (equal treatment by the state for all groups) in addition to the other two.”5 In a liberal democracy, the “elected government cannot discriminate against specific individuals or groups when it administers justice, protects basic rights such as freedom of assembly and free
2Sharun W. Mukand & Dani Rodrik, The Political Economy of Liberal Democracy, THE ECONOMIC JOURNAL, April 2020, pp. 765–792, (available at https://drodrik.scholar.harvard.edu/files/dani-rodrik/files/the_political_economy_o f_liberal_democracy_ej.pdf) (accessed 6/16/20).
3Id. at 770.
4Id. at 786 (emphasis supplied and parentheticals omitted).
5Id. at 765.
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speech, provides for collective security, or distributes economic and social benefits.”6
[I]t required the civil rights movement in the United States for this peculiarly British conception to get transformed into our current understanding of liberal democracy. Historically, subordinated groups across the world were “profoundly influenced by American ideas of civil rights liberalism and its commitment to defend equality.”7
Thus, equality of all citizens is essential to American Democracy. Yet, half our
population, the women,8 are Constitutionally excluded from equal treatment as a
fundamental protection. Without the Equal Rights Amendment (“ERA”), equal
treatment of women is dependent on elected lawmakers. Despite substantial
progress that has been made in reducing inequality, 244 years of unequal treatment
has shown that depending on political cycles results in continued unequal
treatment.
The belief in the need for equality of men and women in order for
6Id. at 770.
7Id. at 785, (internal citation omitted).
8UNITED STATES CENSUS BUREAU: QUICK FACTS, Population estimates as of July 1, 2019. (Women make up 50.8% of the United States population), (available at https://www.census.gov/quickfacts/fact/table/US/PST045219#PST045219) (accessed 6/15/20).
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democracy to reach its full potential is not one born in modern times. Abigail
Adams wrote her husband, John Adams, a Founding Father and later our second
President, after the Revolutionary War had begun and prior to the drafting of the
Declaration of Independence.9 The future First Lady admonished her husband, who was shortly thereafter put on the drafting committee for the Declaration of
Independence:
[I]n the new Code of Laws which I suppose it will be necessary for you to make I desire you would Remember the Ladies, and be more generous and favourable to them than your ancestors. Do not put such unlimited power into the hands of the Husbands. Remember all Men would be tyrants if they could. If perticuliar (sic) care and attention is not paid to the Laidies (sic) we are determined to foment a Rebelion (sic), and will not hold ourselves bound by any Laws in which we have no voice, or Representation.10
Neither the Declaration of Independence nor the United States Constitution remembered the ladies. In fact, women were not provided any rights at all. The
9CONSTITUTIONFACTS.COM: DRAFTING THE DECLARATION OF INDEPENDENCE, (Declaration of Independence was drafted from June 11 to July 5, 1776), (available at https://www.constitutionfacts.com/us-declaration-of-independence/drafting-the-de claration/), (accessed 6/18/20).
10Letter from Abigail Adams to John Adams, from Braintree, Massachusetts, March 31, 1776, p. 2. (See entire letter and a copy of the original) (available at https://www.masshist.org/digitaladams/archive/doc?id=L17760331aa) (accessed 6/16/20).
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Declaration of Independence was based upon the belief that all men had “natural rights”11 that made them equal, as opposed to some being born noble, like kings,
and others not, like peasants. The Constitution, adopted in 1787, should be
understood within the scheme of the Declaration of Independence.12 Despite the
Constitution’s inherent flaws and at least two glaring omissions when it came to equality, slaves and women, it set out a remarkable document that provided the
United States with three equal branches of government protected with checks and balances.
Moreover, in Article V,13 with forethought and self-evident humility, the
Founders included a method to amend the Constitution. Article V allows the improvement of the foundational basis of American Democracy, including the addition of the 28th Amendment,14 known as the “Equal Rights Amendment.”
11Thomas G.West, Jaffa versus Mansfield: Does America Have a Constitutional or a “Declaration of Independence” Soul? 31 PERSPECTIVES ON POLITICAL SCIENCE 4 (Fall 2002), 237-40.
12Id. at 244.
13U.S. Const. art. V; NATIONAL ARCHIVES AND RECORDS ADMINISTRATION: THE CONSTITUTION OF THE UNITED STATES: A TRANSCRIPTION (available at https://www.archives.gov/founding-docs/constitution-transcript) (accessed 6-15- 20).
14The Amici concur with the legal arguments put forth by the Plaintiffs; thus, once this case is properly resolved, it will be held that the 28th Amendment was duly ratified on January 27, 2020 when the Commonwealth of Virginia became the
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Section 1 reads: “Equality of rights under the law shall not be denied or abridged by the United States or by any state on account of sex.”15
Article V allows the United States to ever work to become “a more perfect
Union.”16 However, it is infuriating to many that our Founders did not find all people created equal at the birth of our country. Perhaps their lapse of judgment and fortitude, resulting in their failure to provide equality for women at the outset, can be understood by looking at the laws and norms that were so ingrained in their society in the late 18th century.
B. Under the Common Law, Married Women Were Legal Non- entities.
thirty-eighth state to ratify it.
1586 STAT. 1523 (1972), NATIONAL ARCHIVES AND RECORDS ADMINISTRATION: JOINT RESOLUTION OF MARCH 22, 1972, 86 STAT 1523, PROPOSING AN AMENDMENT TO THE CONSTITUTION OF THE UNITED STATES RELATIVE TO EQUAL RIGHTS FOR MEN AND WOMEN (copy of original available at https://catalog.archives.gov/id/7455549) (accessed 6-15-20).
16From the Preamble to the Constitution, which reads: “We the People of the United States, in Order to form a more perfect Union, establish Justice, insure domestic Tranquility, provide for the common defence (sic), promote the general Welfare, and secure the Blessings of Liberty to ourselves and our Posterity, do ordain and establish this Constitution for the United States of America.” NATIONAL ARCHIVES AND RECORDS ADMINISTRATION: THE CONSTITUTION OF THE UNITED STATES: A TRANSCRIPTION (available at https://www.archives.gov/founding-docs/constitution-transcript) (accessed 6/15/20).
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The basis of law in the United States was the Common Law of England.
While unmarried women were allowed to own property, married women were not legally considered individuals. When a man and a woman married, they became one person, and that one person was the husband.17 The woman legally ceased to exist. She could not own property, not even her own wages, did not have the right to sue, and did not have bodily autonomy, or the right to custody of her children should the couple separate. Domestic Violence18 and Marital Rape were legal.19
C. The First Women’s Rights Convention at Seneca Falls, New York, in 1848, Declared That Women and Men Were Equal and Listed Discriminatory Laws and Practices to Be Rectified in Their
17United States v. Yazell, 382 U.S. 341, 361, 86 S.Ct. 500, 15 L.Ed.2d 404 (1966). (J. Black dissenting, discussing the Common Law of coverture).
18Carissa R. Showden, Domestic Violence, in SOCIAL ISSUES IN AMERICA: AN ENCYCLOPEDIA, (James Ciment, ed.), 2006, 548-561, 551 (available at https://books.google.com/books/about/Social_Issues_in_America.html?id=ru3qBg AAQBAJ) (accessed 6/16/20).
19Matthew Hale, THE HISTORY OF THE PLEAS OF THE CROWN, 628 (1736). The Marital Rape Exemption was a complete bar to prosecution for rape for husbands who raped their wives. The 1962 Model Penal Code in the United States included the marital rape exemption by defining rape as “A male who has sexual intercourse with a female not his wife is guilty of rape....” MODEL PENAL CODE § 213.1 (1962), [emphasis supplied]. North Carolina and Oklahoma were the last states to abolish the Marital Rape Exemption when the spouses were still living together, but not until 1993. N.C. GEN.STAT. § 14-27.34 (2019). However, Oklahoma now requires threatened or actual force or violence for spousal rape, as do some other states. OKLA. STAT. Tit. 21 § 1111(B) (2019).
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Declaration of Sentiments.
By 1840, the plea voiced by Abigail Adams still had not been heeded. That year, the spirited and brilliant Elizabeth Cady Stanton, who had read law in her father’s law office, married a prominent abolitionist who agreed to leave the promise to obey him out of their wedding vows. For the Stantons’ honeymoon, they went to London to the first World Anti-Slavery Convention, to which her husband was a delegate. There, Stanton met Quaker Lucretia Mott, another
American abolitionist, who was also a delegate. Unfortunately, the male abolitionists refused to allow women delegates to be seated or speak. Women were relegated to a segregated women’s area. Stanton was infuriated that men who fought to end slavery did not care about the rights of women.20
After seeing the many problems women had that Stanton recognized as sex- based discrimination, and after she had her first three children, Stanton finally felt it was time to do something to help the plight of women. So, she, Mott and a few other women, convened the first Woman’s Rights Convention in 1848. In preparation, they wrote a list of grievances and demands in a Declaration of
Sentiments. The only disagreement concerned the right to vote: Mott thought it
20ELIZABETH CADY STANTON, EIGHTY YEARS AND MORE REMINISCENCES 1815-1897 (1898), Kindle edition at Locations 857-96.
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was too much to ask for the right to vote, but Stanton believed the vote would give them the political power to fix many other wrongs.21
Approximately 250 people, mostly women but also men, attended the convention in Seneca Falls, New York.22 It was radical at the time for women even to speak in public, but the speakers were mostly women. However, their friend Frederick Douglass spoke in support of women seeking the right to vote.
The convention adopted the Declaration of Sentiments, which declared that women and men were created equal and set forth a multitude of inequalities to be rectified, the first of which was the right to vote.23 Unfortunately, even today, women still suffer many of the types of discrimination that they demanded to be cured in the Declaration of Sentiments, including these areas:
1. [A]n equal participation with men in the various trades, professions and commerce. [At the time, men] had close[d] against [women] all
21HISTORY OF WOMAN SUFFRAGE VOL I, (Elizabeth Cady Stanton, Susan B. Anthony, & Matilda Joslyn Gage, eds., 1881), Kindle e-book, Locations 1223- 1284.
22HISTORY: SENECA FALLS CONVENTION BEGINS, (available at https://www.history.com/this-day-in-history/seneca-falls-convention-begins) (accessed 6/18/20).
23HISTORY OF WOMAN SUFFRAGE VOL I, (Elizabeth Cady Stanton, Susan B. Anthony, & Matilda Joslyn Gage, eds., 1881), Kindle e-book, Locations 1223- 1284.
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the avenues to wealth and distinction, [and in the few jobs open to women, they] receive[d] but a scanty remuneration. 2. [I]mmediate admission to all the rights and privileges which belong to them as citizens of these United States. 3. [O]btaining a thorough education. 4. [To be free from the] power [a husband had] to deprive [his wife] of her liberty, and to administer chastisement.24
In essence, the second demand above is seeking equal rights regardless of sex.
Here is the seed of the ERA, 172 years ago.
For over fifty years, Elizabeth Cady Stanton and Susan B. Anthony led the women’s rights movement. They traveled all over the country and abroad, spoke to state legislatures and Congress, held many more women’s rights conventions, pressed for the right to vote, pushed for changes to other laws to benefit women, and wrote the history of the movement.25 Many other prominent activists worked with them, including Sojourner Truth. In 1867, she talked about an issue that the
ERA can hopefully cure – equal pay. Truth said women do as much work as men,
24Id., (emphasis supplied).
25HISTORY OF WOMAN SUFFRAGE VOLS I-VI, (Elizabeth Cady Stanton, Susan B. Anthony, Matilda Joslyn Gage, Ida Husted Harper, Jane Addams, Anna Howard Shaw, Harriot Stanton Blatch, & Alice Stone Blackwell eds., 1881-1922), Kindle e-books. (Also available in one compilation, THE COMPLETE HISTORY OF THE WOMEN'S SUFFRAGE MOVEMENT IN U.S., Musaicum Books 2018) Kindle Edition.
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so they should get paid as much.26 The failure to acknowledge women as full and equal citizens has continued to allow for the legal failure to recognize women’s work as equal in value to those of men. In 1878, after petitioning Congress,
Stanton and Anthony had a Senator introduce the first Amendment in Congress to grant women the right to vote.27 Sadly, neither lived to see the 19th Amendment ratified, which gave women the right to vote, in 1920 – 100 years ago.
Thankfully, a new generation of suffragists, Stanton’s daughter and granddaughter among them, continued to fight for women’s rights. The suffragists protested, were arrested, and even went on hunger strikes in jail, before they finally succeeded in obtaining the right to vote. With women finally able to be heard and demand a response from elected lawmakers, it was only three years after the right to vote had been won that the first ERA, chiefly written by Alice Paul, a
26HISTORY OF WOMAN SUFFRAGE VOL II, (Elizabeth Cady Stanton, Susan B. Anthony, & Matilda Joslyn Gage, eds., 1881), Kindle e-book, Locations 4607-17.
27 NATIONAL ARCHIVES AND RECORDS ADMINISTRATION: HOW DID WOMEN WIN THE 19TH AMENDMENT? A STRATEGY FOR SUFFRAGE, (45th Cong. 2nd Session, Congressional Record entry January 10, 1878, notes that California Senator Aaron Sargent introduced a woman suffrage amendment, which was identical to future 19th Amendment of 1920), (available at https://artsandculture.google.com/exhibit/AgKih1D2BEbpIg?hl=en) (accessed 6/18/20).
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leader in the right to vote movement,28 was introduced in Congress29 on December
13, 1923, by Representative Daniel R. Anthony, the nephew of Susan B. Anthony.
It stated that “Men an (sic) women shall have equal rights throughout the United
States and every place subject to its jurisdiction.”30
The ERA was introduced in Congress every year for 49 years. After a new wave of women activists spurred it on, the proposed ERA passed as a joint resolution by a supermajority, as a bi-partisan measure, of the House and the
Senate on March 22, 1972. The first section read, “Equality of rights under the law shall not be denied or abridged by the United States or by any State on account of sex.”31 The ERA was officially sent out to the states for ratification in
1972, with a preamble, outside the text of the proposed Amendment, that set a seven-year deadline for ratification. Thirty-five states ratified it; only three more were needed. The deadline was extended to 1982. The instant case will be
28Alice Paul Institute, The Equal Rights Amendment: A Brief History, (available at https://www.alicepaul.org/wpcontent/ uploads/2019/05/ERA-A-History.pdf) (accessed 6/17/20).
29H.J.Res. 75, 68th Cong. (1923) (unenacted), NATIONAL ARCHIVES AND RECORDS ADMINISTRATION: H.J. Res. 75, Proposing an Equal Rights Amendment to the Constitution, (available at https://catalog.archives.gov/id/7452156) (accessed 6/17/20).
30Id.
3186 STAT. 1523 (1972).
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deciding whether those deadlines were unconstitutional prohibitions on the States’ powers.32
The Defendant in the instant case wrote a letter to a Congresswoman in
2012, stating that he would publish the ERA, as a duly ratified Amendment to the
Constitution, after thirty-eight states ratified it.33 Relying on that assurance, yet a new tide of women activists, including one of the Plaintiffs in the instant case,
Equal Means Equal, successfully led the push to accomplish that goal.
Since 1972, women’s rights groups have multiplied, especially after the
2016 presidential election. The day after the last Presidential Inauguration, in
January 2017, millions of women and men marched all over the United States, and around the world in solidarity, demanding women’s rights.34 Those Women’s
32Plaintiffs’ Amended Complaint for Equitable and Injunctive Relief and for Relief under the All Writs Act, Doc. 5, filed February 29, 2020.
33Letter from David S. Ferriero, Archivist of the United States, to the Hon. Carolyn Maloney (October 25, 2012), (available at https://www.congress.gov/116/meeting/house/109330/documents/HHRG-116-JU1 0-20190430-SD007.pdf) (accessed 6/18/20); See a copy of the Defendant’s letter at Exhibit A of the Plaintiffs’ Memorandum of Points and Authorities in Opposition to Defendant’s Motion to Dismiss, Doc. 13, filed on June 1, 2020, in the instant case.
34Kaveh Waddell, The Exhausting Work of Tallying America’s Largest Protest, THE ATLANTIC, Jan. 23, 2017 (available at https://www.theatlantic.com/technology/archive/2017/01/womens-march-protest-c ount/514166/) (accessed 6/18/20).
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Marches have become an annual event.35 Yet, the problems of insidious sex discrimination have continued to hold women back in many of the same arenas that the 1848 Declaration of Sentiments identified.
D. For the First Time, the ERA Will Provide Women the Right to Have Equal Treatment under Law in Our Constitution.
The late Justice Antonin Scalia unequivocally stated in 2011 that the
Constitution does not prohibit discrimination on the basis of sex.36 The 14th
Amendment does not explicitly grant any level of equal protection for sex-based discrimination. The Supreme Court allowed for a heightened middle-tier scrutiny to address sex-based discrimination under the Equal Protection Clause.37 But, the
Supreme Court’s refusal to protect women as a suspect class with strict scrutiny is
35Alaa Elassar, What You Need to Know About Today’s Women’s March, CNN, Jan. 18, 2020 (available at https://www.cnn.com/2020/01/18/us/national-womens-march-explainer-trnd/index .html) (accessed 6/18/20).
36Max Fisher, Scalia says Constitution Doesn’t Protect Women From Gender Discrimination, THE ATLANTIC, Jan. 1, 2011 (available at https://www.theatlantic.com/politics/archive/2011/01/scalia-says-constitution-doe sn-t-protect-women-from-gender-discrimination/342789/) (accessed 6/18/20).
37U.S. Const. amend. XIV, § 1 ("No State shall . . . deny to any person within its jurisdiction the equal protection of the laws."); Craig v. Boren, 429 U.S. 190, 197 (1976). (The intermediate test was used for a sex-based classification. To be constitutional, the challenged law must serve an important governmental objective and be substantially related to that objective); United States v. Virginia, 518 U.S. 515, 532 (1996).
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prima facie evidence that women are not equal citizens. The ERA gives women and men the right to be free from sex-based discrimination and would grant sex- based discrimination the highest strict scrutiny level, as is already used for other suspect classes based on race, religion, or national origin.38
II. WOMEN ARE DEPRIVED OF FULL CITIZENSHIP UNDER THE CONSTITUTION WITHOUT THE ERA.
The pervasive de facto social inequality of women hurts their ability to
achieve real political equality,”39 and without political equality, including women not having parity in our state legislatures and in Congress, it is a massive struggle for women to achieve equality in society. The Amici hope the ERA will cure much of the social inequality faced by women because the ERA is a tool that gives people the ability to challenge discriminatory laws and that gives states and the federal government two years to review and possibly amend or repeal sexist laws.
38See generally, Lauren Sudeall Lucas, Identity as Proxy, 115 COLUM. L. REV. 1605 (2015). Further, some states have added equal rights amendments to their state constitutions. For example, in 1976, the Massachusetts Constitution added art. 106, which includes sex. Commonwealth v. King, 374 Mass. 5, 21 (1977) (The Supreme Judicial Court of Massachusetts found that “[t]he classifications set forth in art. 106 [sex, race, color, creed, or national origin]...are subjected to the strictest judicial scrutiny.”).
39See Francis Fukuyama, Poverty, Inequality, and Democracy: Dealing with Inequality, 22 JOURNAL OF DEMOCRACY, 3, (July 2011), 79-89 (available at https://muse.jhu.edu/article/444760/pdf) (accessed 6/15/20).
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Without the benefit of the ERA, half our population are not equal citizens.40
Despite constituting half the population, women are woefully outnumbered by men in the halls of power:41 In the current Congress, women comprise 23.2% of
the House of Representatives and 26% of the Senate,42 and women comprise approximately 25-35% of the state legislatures.43 There was an historic outcome in the Nevada state legislature in the 2018 election. For the first time in United
40UNITED STATES CENSUS BUREAU: QUICK FACTS, Population estimates as of July 1, 2019. (Women made up 50.8% of the U.S. population in 2019) (available at https://www.census.gov/quickfacts/fact/table/US/PST045219#PST045219) (accessed 6/15/20).
41Pippa Norris and Ronald Inglehart, Women and Democracy: Cultural Obstacles to Equal Representation, 12 JOURNAL OF DEMOCRACY, 3, (July 2001), 126-40.
42CENTER FOR AMERICAN WOMEN IN POLITICS: CURRENT NUMBERS, Women in the U.S. Congress (2020) (available at https://cawp.rutgers.edu/current-numbers) (accessed 6/16/20).
43CENTER FOR AMERICAN WOMEN IN POLITICS: CURRENT NUMBERS, State Legislature (2020) (available at https://cawp.rutgers.edu/state-by-state) (accessed 6/16/20) (Women make up roughly 25-35% average of the state legislatures now in 2020: AL 15.7%; AK 36.7%; AZ 38.9%; AR 25.2%; CA 31.7%; CO 44.0%; CT 32.1%; DE 24.2%; FL 29.4%; GA 30.5%; HI 31.6%; ID 31.4%; IL 36.2; IN 25.3%; IA 29.3%; KS 28.5%; KY 23.9%; LA 18.1%; ME 37.6%; MD 39.9%; MA 29%; MI 36.5%; MN 31.8%; MS 16.1%; MO 24.4%; MT 30.7%; NE 28.6%; NV 52.4%; NH 34.0%; NJ 30.8%; NM 36.6%; NY 31.5%; NC 25.9%; ND 22.0%; OH 27.3%; OK 21.5%; OR 42.2%; PA 26.9%; RI 37.2%; SC 16.5%; SD 24.8%; TN 15.2%; TX 24.3%; UT 26.0%; VT 40.6%; VA 29.3; WA 40.8%; WV 13.4%; WI 26.5%; WY 15.6%) (emphasis supplied).
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States history, women constituted a state legislative majority.44
A. Poverty Rates of Women and Children Will Be Ameliorated by the ERA.
The continuing relegation of women to a lesser status than fully equal has contributed to women being overwhelmingly over-represented among the poor and the less educated, while under-represented in the board rooms and as top executives in most industries and leadership positions, including most universities, schools, and the professions.45 For example, women still hold a minority of tenure-track and high-level faculty positions in higher education.46 It is hoped that the ERA will be a means to end the truly institutionalized sexism that has faced
44Kira Sanbonmatsu, Women’s Underrepresentation in the U.S. Congress, DAEDALUS, (Winter 2020), 40-55, at 40.
45THE AMERICAN ASSOCIATION OF UNIVERSITY WOMEN: BARRIERS AND BIAS - THE STATUS OF WOMEN IN LEADERSHIP, 2016 (Report available at https://www.aauw.org/app/uploads/2020/03/Barriers-and-Bias-nsa.pdf) (accessed 6/18/20), Jena McGregor, After Years of ‘Glacial’ Change, Women Now Hold More than 1 in 4 Corporate Board Seats, THE WASHINGTON POST, July 17, 2019, (available at https://www.washingtonpost.com/business/2019/07/17/after-years-glacial-change- women-now-hold-more-than-corporate-board-seats/) (accessed 6/18/20).
46Paula J. Caplan, Balancing Career and Family, THE PORTABLE MENTOR: EXPERT GUIDE TO A SUCCESSFUL CAREER IN PSYCHOLOGY. Mitchell Prinstein and Marcus Patterson, eds.), Cambridge, UK: Cambridge University Press, (scheduled for 2020 publication).
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women throughout our country’s history.
Women have a higher poverty rate than men.47 Many factors contribute to poverty, but some can be addressed by the ERA. Women still earn only about 82% of what men earn for equal work.48 “In middle-skill occupations, workers in jobs mainly done by women earn only 66% of [what] workers [earn] in jobs mainly done by men.”49 Current laws are not sufficient, or this disparity would not exist.
“Women represent nearly two-thirds of the workforce in low-paid jobs.”50 Studies show that if women had equal pay for equal work with men, women’s poverty rate would decrease by more than half for women and their families, and it would add
47NATIONAL WOMEN’S LAW CENTER: NWLC RESOURCES ON POVERTY, INCOME, AND HEALTH INSURANCE IN 2017 (available at https://nwlc.org/resources/nwlc-resources-on-poverty-income-and-health-insuranc e-in-2017/) (accessed 6/16/20).
48INSTITUTE ON WOMEN’S POLICY RESEARCH: PAY EQUITY & DISCRIMINATION (available at https://iwpr.org/issue/employment-education-economic-change/pay-equity-discrim ination/) (accessed 6/16/20).
49Id.
50NATIONAL WOMEN’S LAW CENTER: WOMEN IN LOW-PAID JOBS (available at https://nwlc.org/resources/when-hard-work-is-not-enough-women-in-low-paid-job s/) (accessed 6/16/20).
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billions of dollars to the economy.51
Over a woman’s lifetime, this can amount to a loss of hundreds of thousands of dollars. As a result of an analysis of women’s and men’s earnings over time, in this instance from 2001 through 2015, it was found that women made only 49% of what men made.52 Inequality due to discrimination based on sex can significantly impair women’s ability to acquire wealth, hurting them in terms of their retirement and social security distributions and their ability to gain wealth by other means, such as purchasing a home rather than renting.53 The lower earnings compared to men also affect the ability of women-led households to save, making women more vulnerable to personal and economic crises.54 Equal pay for men and women will
51INSTITUTE ON WOMEN’S POLICY RESEARCH: PAY EQUITY & DISCRIMINATION, supra.
52INSTITUTE ON WOMEN’S POLICY RESEARCH: STILL A MAN'S LABOR MARKET: THE SLOWLY NARROWING GENDER WAGE GAP (available at https://iwpr.org/publications/still-mans-labor-market/) (accessed 6/17/20)
53THE WORLD BANK: UNREALIZED POTENTIAL: THE HIGH COST OF GENDER INEQUALITY IN EARNINGS, May 30, 2018. (available at https://www.worldbank.org/en/topic/gender/publication/unrealized-potential-the-h igh-cost-of-gender-inequality-in-earnings) (accessed 6/18/20).
54Courtney Connley, The Coronavirus Pandemic Further Highlights Why Women Workers Need Equal Pay, CNBC, (Mar. 31, 2020), (available at https://www.cnbc.com/2020/03/31/how-the-pay-gap-hurts-low-wage-women-wor kers-impacted-by-the-coronavirus.html) (accessed 6/18/20).
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likely not be achieved at the current rate of improvement until 2059.55 Inequality due to discrimination based on sex means massive dollars in lost earning potential resulting in women (particularly single mothers) stuck in poverty simply because they are female.
Women’s lower pay rates also hurt two-parent families. Two salaries are often necessary to keep a family in the middle class. Further, family roles and structures have changed such that equality for women in earning capacity is more important now than ever. Women alone are sometimes the breadwinner while fathers stay home to care for children. There are less rigid roles for husbands and wives, fathers and mothers, which require equality regardless of who does what in a family.56
Statistics show that women have not achieved parity in numerous professions and fields of employment. Further progress is needed in integrating women into professions and industries done primarily by men, for example
55INSTITUTE ON WOMEN’S POLICY RESEARCH: PAY EQUITY & DISCRIMINATION, supra.
56Sarah Jane Glynn, Breadwinning Mothers Continue To Be the U.S. Norm, CENTER FOR AMERICAN PROGRESS, (May 10, 2019). (available at https://www.americanprogress.org/issues/women/reports/2019/05/10/469739/brea dwinning-mothers-continue-u-s-norm/) (accessed 6/18/20).
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construction57 and STEM jobs58 (Science, Technology, Engineering,59 and
Mathematics).
B. The ERA Will Help Equalize Access to Education for Women.
A college education increases a woman’s earning capacity. For example, a woman with a four-year degree earns twice as much as a woman without a high school diploma. But women still make less than men with the same level of education.60 The reality is that today, many female college students have children,
57Ariane Hegewisch, Women Gain Jobs in Construction Trades but Remain Underrepresented in the Field, INSTITUTE ON WOMEN’S POLICY RESEARCH, Mar. 28, 2019, (available at https://iwpr.org/publications/women-jobs-construction-underrepresented/) (accessed 6/18/20).
58INSTITUTE ON WOMEN’S POLICY RESEARCH: STEM INNOVATION (available at https://iwpr.org/issue/employment-education-economic-change/stem-innovation/) (accessed 6/16/20).
59Nora Stanton Blatch, granddaughter of Elizabeth Cady Stanton, was the first female Civil Engineer. She was the first woman to receive her degree in civil engineering, from Cornell in 1905, and was the first woman accepted in the American Society of Civil Engineers. BACHELORS DEGREE ONLINE: FEMALE ENGINEERS WHO HELPED PAVE THE WAY, (2012) (available at https://www.bachelorsdegreeonline.com/blog/2012/10-female-engineers-who-help ed-pave-the-way/) (accessed 6/15/20).
60INSTITUTE ON WOMEN’S POLICY RESEARCH: CENTER ON EQUITY IN HIGHER EDUCATION BLOG (available at https://iwpr.org/issue/employment-education-economic-change/center-equity-high er-education/) (accessed 6/16/20).
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requiring daycare, family planning, and other support to help them graduate.61 An increase in women holding elected positions in state and federal government likely will improve the recognition and response to those issues and result in better access to education for women.
C. Sex-based Discrimination Has a Deleterious Effect on Women’s Health.
With the ERA reducing the pervasive sex-based discrimination in our society, women’s health should improve in a number of areas, including substance abuse, mental health, and physical health. Researchers have tested the effects on women's health of many types of sex-based discrimination, for instance in employment, in the public, with regard to various institutions, and being degraded with derogatory sexist names. “[W]omen’s exposure to [sex] discrimination, sexist events, and sexual harassment is associated with elevated psychological distress, depressive and anxious symptoms, and poorer physical health.”62
61INSTITUTE ON WOMEN’S POLICY RESEARCH: INVESTING IN SINGLE MOTHERS’ HIGHER EDUCATION (available at https://iwpr.org/issue/employment-education-economic-change/center-equity-high er-education/investing-single-mothers-higher-education/) (accessed 6/16/20).
62Carliner, Sarvet, Gordon, and Hasin, Gender Discrimination, Educational Attainment, and Illicit Drug Use Among U.S. Women, 52 SOCIAL PSYCHIATRY AND PSYCHIATRIC EPIDEMIOLOGY, 3, 279–89 (2017).
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For example, substance use is a coping mechanism for acute and chronic stressors. A recent study showed that sex-based “discrimination is consistently and strongly associated with illicit drug use and drug use disorders among United
States women, with significantly higher odds for drug use among women with less than a high school education.”63
With the current Coronavirus pandemic taxing our healthcare system and the health and economy of our nation, it is unclear how long the pandemic’s effects will be felt,64 but with the ERA mandating equal treatment by federal and state governments, women likely will not be at risk of falling even further behind in their health outcomes relative to men.
D. The ERA Will Help Curb Violence Against Women by Placing Equal Value on Women and Rectifying Discriminatory Laws.
The Amici refer this Honorable Court to the Plaintiffs’ Amended Complaint that did an excellent job of outlining and explaining how violence against women is a critical reason why women need the ERA.65 It is such a vast subject that it
63Id.
64Connley, Supra.
65Plaintiffs’ Amended Complaint for Equitable and Injunctive Relief and for Relief under the All Writs Act, Doc. 5, filed February 29, 2020, at pp. 14-16, ¶¶51-57. See also, Plaintiffs’ Memorandum of Points and Authorities in
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would take the length of this entire brief to do it justice.
Higher rates of violence against women are caused by inequality, discriminatory laws, and the lower value placed on women. Lingering societal discrimination against women leaves them frequently without the economic, societal, legal, and familial support resources to escape domestic violence.66
CONCLUSION
The United States will reap the benefits of full equality of women by increasing the resources the country has to draw on for collective security and economic and social benefits.67 With the ERA, women will finally be valued as full citizens, and their protection and rights will not be subject to political cycles, nor the pendulum of judicial philosophies. Women should have equal protection of the laws enshrined in the Constitution with the ERA. Women should have equal opportunities based on their abilities and talents and not be held back because of
Opposition to Defendant’s Motion to Dismiss, Doc. 13, filed June 1, 2020, pp. 27- 31, n.28-35, and Plaintiffs’ Surreply Doc. 22, filed June 17, 2020, at 4, n.5.
66Causes, Protective and Risk Factors, in Ending Violence Against Women and Girls: Progamming Essentials, pp. 8-9, UN WOMEN VIRTUAL KNOWLEDGE CENTRE TO END VIOLENCE AGAINST WOMEN AND GIRLS, June, 2013 (available at https://www.endvawnow.org/en/articles/300-causes-protective-and-risk-factors-.ht ml) (accessed 6/17/20).
67Mukand & Rodri, supra.
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their sex and lack of protection under our Constitution and laws.
The ERA has been ratified by thirty-eight states, ninety-seven years after it was first introduced in Congress. Women should not have had to wait this long, nor wait a minute longer, to have equal rights. Our country loses potential leaders in science, medicine, education, entrepreneurship, and government every day we limit opportunities based on sex. With the strength of the ERA, it is likely that many of the lingering insidious social inequalities women still face, vestiges from the British Common Law, will more swiftly be changed for the generations currently alive, instead of having to wait another century. The time for making women equal citizens is now.
Thus, the Amici Curiae respectfully ask this Honorable Court to grant the
relief sought by the Plaintiffs.
Dated: July 20, 2020. Respectfully submitted:
For the Amici Curiae
/s/ Arlaine Rockey ARLAINE ROCKEY, ESQ. Attorney at Law Pro Hac Vice Counsel (Admitted in North Carolina & Florida) PO Box 656 Marshall, NC 28753 ArlaineRockey.com Attorney-Author.com/ecs
26 Case 1:20-cv-10015-DJC Document 30 Filed 07/20/20 Page 38 of 98
Cell: (828) 279-6735 Fax: (866) 202-5977 [email protected]
/s/ Laura D. Mangini LAURA D. MANGINI, ESQ. BBO#: 684620 Alekman DiTusa, LLC 1550 Main Street, Suite 401 Springfield, MA 01103 (413)781-0000 (413)827-0266 fax [email protected]
CERTIFICATE OF COMPLIANCE
I HEREBY CERTIFY that the foregoing brief complies with the type- volume limitation, and according to the word-processing system used, the word count is 5,457.
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the above document was served upon the attorneys of record for each party by the ECF filing system.
/s/ Arlaine Rockey
Dated: July 20, 2020
27 Case 1:20-cv-10015-DJC Document 30 Filed 07/20/20 Page 39 of 98
ADDENDUM Amici Curiae68
1. Activism Caucus of The Association For Women In Psychology
Dr Joan Chrisler
Milford, CT
Email: [email protected]
Mission Statement:
Our primary public mission is to bring psychological research and clinical
experiences to bear on attempts to understand social issues and to encourage
AWP members and the general public to work for the betterment of society.
AWP is a 501(c)(3) organization. We can give expert testimony and take
public stands on topics related to our expertise in psychology and
women’s/gender issues.
68With the exception of the Amici with an asterisk next to their name, all certify that each is a non-profit corporation or organization; it does not offer stock; and it has no parent corporation. The Amici with an asterisk (*) next to their name, all certify that, although each is not a non-profit corporation, each does not offer stock and does not have a parent corporation. The Amicus with two asterisks (**) next to their name, certify that it is a non-profit corporation; it does not offer stock; and it does have a publicly-traded parent corporation. The Amicus with three astericks (***) certify that it is a for-profit corporation and it does have a publicly-traded parent corporation.
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2. Albuquerque Center for Peace and Justice
Jim Harvey
Executive Director,
Albuquerque Center for Peace and Justice
Albuquerque, NM
Mission Statement:
The Albuquerque Center for Peace and Justice provides resources and space
for organizations and individuals working on peace and justice issues to
network with one another and share information. Through our programs and
collaborations, we work locally to support regional and global justice.
ACPJ strives to create a world where our collective needs are met
sustainably and nonviolently. We value the interconnectedness of all life. We
emphasize cooperation and respect for diversity. We are committed to
nonviolent conflict resolution. We strive for peace within ourselves while we
work towards creating peace in our community and in our world. Nonprofit
501(c)(3).
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3. Alice Paul Institute
Lucienne Beard
Executive Director, Alice Paul Institute
Mt. Laurel, NJ
www.alicepaul.org
Mission Statement:
The mission of the Alice Paul Institute is to honor the legacy of Alice Paul’s
work for gender equality through education and leadership development.
The Alice Paul Institute educates the public about the life and work of Alice
Stokes Paul (1885-1977), and offers heritage and girls’ leadership
development programs at Paulsdale, her home and a National Historic
Landmark. Alice Paul led the final fight to get women the vote and wrote the
Equal Rights Amendment. We honor her legacy as a role model of leadership
in the continuing quest for equality. The Alice Paul Institute is a 501(c)(3)
organization.
4. Allies Reaching for Equality
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Susan Daria Landino [email protected]
Mission Statement:
Allies Reaching for Equality (A.R.E.) was formed in 2017 to address the significant issue of university practices that allow hostile environments to go unchecked and places the achievement of women and other intersectional populations in jeopardy. A.R.E. is serving as advocate for university community members navigating discrimination and retaliation. A.R.E. will also provide effective training, resources, and empowerment for university staff to uphold civil rights law, including Title IX, Title VII, and 1964 civil rights laws to stop the uneven playing field and ensure equal access to education. The corporatization of higher education and the competitive environment to attract students has provoked a disincentive for universities to allocate resources to point to institutional problems dealing with gender and intersectional harassment. A.R.E.’s mission is to partner with university leadership, faculty, staff, and students to create a community prioritizing and upholding gender, race, and intersectionality equity at our universities. The
United States government is not equipped to guarantee compliance with civil rights laws and attempts to 2 enforce have historically caused a reaction with
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little effort to prevent the significant harms experienced by survivors of
sexual assault, harassment, and retaliation. With its programs, A.R.E. is
working to close the gap caused by lack of government oversight with
research-driven information and guided resources. A.R.E.’s mission is to
advocate for the equal treatment of women, including equal treatment of civil
rights laws. Allies Reaching for Equality (A.R.E.) is a 501(c)(3).
5. American Association of University Women of Florida that includes
branches in:
Melbourne; Greater Naples; Miami; Orlando/Winter Park; Vero Beach,
Patricia Ross, Pres., and Pat Dewitt, President Elect
Email: [email protected]
Mission Statement:
AAUW advances equity for women and girls through advocacy, education,
philanthropy, and research. We’ve led the fight for fair pay and economic
opportunity for women — and the battle continues: Women still get just 82
cents for every dollar paid to a man, and men continue to dominate the top
roles and highest-paying professions. Though we are nonpartisan, we are not
values-neutral: We fight to remove the barriers and biases that stand in the
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way of gender equity. We train women to negotiate for pay and benefits and
to pursue leadership roles. And we advocate for federal, state and local laws
and policies to ensure equity and end discrimination. The American
Association of University Women is a 501(c)(3).
6. American Association of University Women – Michigan Chapter
Janice Van Gasse
Kingsford, MI
Email: [email protected]
Mission Statement:
AAUW advances equity for women and girls through advocacy, education,
philanthropy, and research.
We’ve led the fight for fair pay and economic opportunity for women — and
the battle continues: Women still get just 82 cents for every dollar paid to a
man, and men continue to dominate the top roles and highest-paying professions.
Though we are nonpartisan, we are not values-neutral: We fight to remove
the barriers and biases that stand in the way of gender equity. We train
women to negotiate for pay and benefits and to pursue leadership roles. And
we advocate for federal, state and local laws and policies to ensure equity
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and end discrimination. American Association of University Women: Non-
profit Tax Code Designation: 501(c)(4). American Association of University
Women. Inc: Nonprofit Tax Code Designation: 501(c)(3).
7. Campus Safety Advocacy Group *
S. Daniel Carter
Thomson, GA
Email: [email protected]
Mission Statement:
Safety Advisors for Educational Campuses, LLC’s mission is to provide
multidisciplinary expert services to educational communities to foster safe
learning environments.
Led by S. Daniel Carter, who has been at the forefront of advancing campus
safety and victims’ rights for over 25 years, and a multidisciplinary team of
experts Safety Advisors for Educational Campuses, LLC (SAFE Campuses,
LLC) provides K-12 as well as higher education, both in the United States,
and abroad high quality subject matter expertise on a broad range of campus
security issues including sexual violence, trauma-informed response to
sexual assault and dating violence, alcohol and other drugs, and emergency management.
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SAFE Campuses, LLC was founded in 2017, and also provides virtual and
in-person training on campus safety issues for higher education
professionals, including Title IX as it relates to campus sexual violence, the
Jeanne Clery Act, and campus climate surveys.
Privately owned partnership LLC.
8. Coalition to Abolish Slavery and Trafficking (CAST)
Stephanie Richard
Los Angeles, CA
Email: [email protected]
Mission Statement:
Our Mission The Coalition to Abolish Slavery and Trafficking (CAST) is a
Los Angeles–based nonprofit organization that is working to put an end to
modern slavery and human trafficking through comprehensive, life-
transforming services to survivors and a platform to advocate for
groundbreaking policies and legislation.
Nonprofit Tax Code Designation: 501(c)(3)
9. CODEPINK
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Mark Folkman
Venice, CA
Email: [email protected] www.codepink.org
Mission Statement:
CODEPINK is a women-led grassroots organization working to end U.S. wars and militarism, support peace and human rights initiatives, and redirect our tax dollars into healthcare, education, green jobs and other lifeaffirming programs. Join us! Founded in fall 2002 as a grassroots effort to prevent the
US war on Iraq, we continue to organize for justice for Iraqis and to hold war criminals accountable. We actively oppose the continuing U.S. war in
Afghanistan, torture, the detention center at Guantanamo, weaponized and spy drones, the prosecution of whistleblowers, U.S. support for the Israeli occupation of Palestine and repressive regimes.
Rooted in a network of local organizers, online supporters and generous donors, with an emphasis on joy and humor, our tactics include satire, street theatre, creative visuals, civil resistance, and directly challenging powerful decision-makers in government and corporations. And of course, wearing pink!
CODEPINK is not exclusively women — we invite non-binary, gender-non-
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conforming people, and men to join us. We are particularly eager to see
mothers, grandmothers, sisters, and daughters, female workers, students,
teachers, healers, artists, writers, singers, poets and all outraged women rise
up and oppose global militarism.
Nonprofit Tax Code Designation: 501(c)(3)
10. Dr. Bronner’s Family Foundation **
David Bronner
Vista, CA
Email: [email protected]
Mission Statement:
Dr. Bronner’s has always been an activist company, dating back to when
Emanuel Bronner was calling on the human race to unite from street corners
and auditoriums, selling his peppermint castile soap on the side. Carrying
forward that same activist spirit, it is our mission to continue to use the
company today to fight for and financially support causes we believe in:
regenerative agriculture, fair trade, animal advocacy, industrial hemp and
drug policy reform, and living wages among others. We call ourselves the
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“fighting soap company,” and are committed and strategic in the causes we
fight for. Nonprofit Tax Code Designation: 501(c)(3).
11. Elizabeth Cady Stanton Trust
Coline Jenkins
Greenwich, CT United States
www.elizabethcadystanton.org
Mission Statement:
By standing on the strong shoulders of women activists who have come
before us, treasuring their contributions and using their imagery and
language, we shall continue to inspire people to action in promoting
democracy, equality and justice.
Goals:
• To preserve the history of women’s rights movement in the United
States and the world
• To advance the understanding of how the women’s rights movement
greatly expended democracy
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• To educate the public, especially girls, about the significance of this history
• To recognize and value the integral contributions women continue to
make throughout the nation and the world
Elizabeth Cady Stanton Trust is a 501(c)(3).
12. ERA Minnesota
Betty Folliard, Founder
www.eramn.org
Mission Statement:
ERA Minnesota, founded in 2014, is an organization of thousands of
advocates and many organizations across the state of Minnesota dedicated to
passing an Equal Rights Amendment into our state & national constitutions.
To that end, we educate, agitate & organize through direct action, social
media, events, and presentations throughout the state and nation to ensure
justice & equality for all.
13. ERA-NC Alliance
Lori Bunton & Jimmie Cochran Pratt, Co-Presidents
www.era-nc.org
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Winston-Salem, NC
Mission Statement:
We are a lead organization of the national ERA Coalition and a nonpartisan,
non-profit alliance of thirteen women’s organizations united by a common
goal: to ratify the ERA in North Carolina. “The mission of the Equal Rights
Amendment North Carolina Alliance is the ratification by North Carolina of
the Equal Rights Amendment to the U.S. Constitution. The Alliance
welcomes the broadest collaboration with individuals and organizations at all
levels in reaching this goal. The Alliance operates in direct collaboration
with the national ERA Coalition.”
The ERA-NC Alliance is a non-partisan, non-profit 501(c)(4).
14. Fairfax County Commission for Women
https://www.fairfaxcounty.gov/familyservices/boards-authorities-
commissions/commission-for-women/what-is-the-commission-for-women
(County Government)
Lisa Sales
Fairfax, VA
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Mission Statement:
The Fairfax County Commission for Women (CFW) advises the Fairfax
County Board of Supervisors on policies and initiatives to promote gender
equality, eliminate violence against women, and honor women and girls in
Fairfax County. The Fairfax County Commission for Women advises the
Board of Supervisors on ways to promote the full equality of women and
girls in Fairfax County. Established in 1971, the Commission has been an
active voice for women in areas such as domestic violence, educational
equality, and progress in the workplace. The Commission is part of a
national network of state and local Commissions for Women.
15. Flora's Refuge and Resource
Kristina Anderson, CFO
Arlington, VA
Mission Statement:
Informing community & sustaining international and domestic students of
science, technology, engineering, arts, math (STEAM), environment, the
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world's wild & domestic life, so much more.
Flora's Refuge and Resource is a 501(c)(3).
16. FOR FREEDOMS
Hank Willis Thomas
Brooklyn, NY
Email: [email protected]
Mission Statement:
We believe citizenship is defined by participation, not by ideology. Through
non-partisan nationwide programming, we use art as a vehicle for
participation to deepen public discussions on civic issues and core values.
We are a hub for artists, arts institutions, and citizens who want to be more
engaged in public life.
17. Fuerza Mundial Global
Dorinda Moreno
Email: [email protected]
Mission Statement:
The Mission of Fuerza Mundial is to connect Grass Roots Communities,
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Protecting and Preserving, World Cultures, Fauna and Flora, All Our Relations.
Nonprofit Tax Code Designation: 501(c)(3)
18. Fund for Women Artists, Inc. dba WomenArts
Martha Richards, President and Executive Director
Berkeley, CA
Email: [email protected]
www.WomenArts.org
Mission Statement :
Our mission is to increase the visibility and employment opportunities for
women working in all art forms. The Fund for Women Artists is a 501(c)(3)
non-profit organization incorporated in Massachusetts.
19. Houston Women's March On
Sanjanetta Barnes
Robin Paoli, President
www.HoustonWomenMarchOn.org
Mission Statement:
Houston Women March On is a non-profit 501(c)(3) located in Texas. We
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are a grassroots organization that mobilizes marchers for many issues and
events to include protecting Voting Rights, Census, Get Out The Vote
(GOTV), Climate Action, Healthcare, the 100th anniversary of the 19th
Amendment to the Constitution, the 4th Annual January March, and other
crucial issues and actions for justice and equality. The American Bar
Association says: "The year 2020 marks the 100th anniversary of the passage
of the 19th Amendment, guaranteeing and protecting women's constitutional
right to vote. The passage marked the largest expansion of democracy in the
history of our country.”
Houston Women March On has national reach and believes that the ERA
will greatly advance its objectives.
20. Human Rights and Diversity Commission
International Brotherhood of Teamsters
Marcus King, Director
Washington, D.C.
https://teamster.org/about/human-rights-commission/
Mission Statement:
The Teamsters are America’s largest, most diverse union. In 1903, the
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Teamsters started as a merger of the two leading team driver associations.
These drivers were the backbone of America’s robust economic growth, but they needed to organize to wrest their fair share from greedy corporations.
Today, the Union’s task is exactly the same. The Teamsters are known as the champion of freight drivers and warehouse workers, but have organized workers in virtually every occupation imaginable, both professional and non- professional, private sector and public sector. Our 1.4 million members are public defenders in Minnesota; vegetable workers in California; sanitation workers in New York; brewers in St. Louis; newspaper workers in Seattle; construction workers in Las Vegas; zoo keepers in Pennsylvania; healthcare workers in Rhode Island; bakery workers in Maine; airline pilots, secretaries and police officers. Name the occupation and chances are we represent those workers somewhere. Teamsters stand ready to organize workers who want to bargain collectively. Once a contract is negotiated and signed, the Union works to enforce it—holding management’s feet to the fire and invoking contract grievance procedures if management chooses not to. Wages and benefits under Teamster contracts are markedly better than those of non- union employees in similar jobs. Teamster contracts are the guarantors of decent wages, fair promotion, health coverage, job security, paid time-off
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and retirement income. The Teamsters Union also performs vital tasks in
such areas as pension management, safety & health, community outreach,
governmental affairs and communications. For more than a century, the
Teamsters have been a public voice for the rights and aspirations of working
men and women and a key player in securing them. The Teamsters Union is
a 501(c)(5).
21. Indivisible Worcester Maryland
Susan Buyer and Toby Perkins, Coordinators
Mission Statement:
Indivisible Worcester Maryland is one of 5,000 Indivisible groups across the
United States who work peaceably to stop Trump's racist, misogynistic,
authoritarian, and corrupt agenda. Our principles are patriotic, nonpartisan,
constitutional, peaceable assembly for the redress of grievances. Our
primary method is to petition our three Members of the U. S. Congress.
We are a local chapter of the Indivisible Project, a 501(c)(a) organization.
22. Institute on Violence, Abuse and Trauma
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Bob Geffner
San Diego, CA
Email: [email protected]
Mission Statement:
Our Mission is to promote violence-free living by improving the quality of
life for individuals on local, national and international levels by sharing and
disseminating vital information, improving cross-discipline collaborations,
conducting research and trainings, and providing direct professional
services, program evaluation, and consulting. The Institute on Violence,
Abuse and Trauma (IVAT) is a 501(c)(3) organization that condemns
violence and oppression in all its forms
23. Isle Of Wight County Humane Society
Debbie Lee
Smithfield, VA
www.iowchs.org
Email: [email protected]
Mission Statement:
The Isle of Wight County Humane society is an all volunteer organization
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that promotes responsible pet care and the humane treatment of animals in
our local community. Humane Society members take in homeless and
unwanted animals and provide them with foster care and medical treatment.
When the animals are healthy and socialized, they are adopted out to
permanent homes. Our pet adoption program is very successful and we find
homes for hundreds of dogs and cats each year. To promote our concern for
animal welfare the Humane Society participates in local activities such as
parades, festivals and fairs. Nonprofit Tax Code Designation: 501(c)(3)
24. L.I.N.D.A Organization
Beth Adubato
Oviedo, FL
Email: [email protected]
Mission Statement:
We bridge the gap between post-incarcerated women and victims of
domestic abuse to their newly found freedom.
25. MadMoms Fight For Justice
Charlotte, NC
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[email protected] www.MadMomsFightForJustice.com
Mission Statement:
We will help you learn how to communicate to the court, using their terminology, and their rules. We will help you present your case in a way the court will accept, and the other parent cannot twist to their advantage. We provide the tools and information you need, to successfully fight false allegations of “Parental Alienation”, custodial interference, enmeshment,
Munchausen's by proxy, mental instability etc., that the other parent may use in order to discredit you. We here at MadMoms discovered that we are not alone and what happens to good parents in family court is not a fluke, or a horrible mistake. Children are being removed from their primary attachment figure throughout the country. MadMoms knows the best way to help combat the problem is information, and the tools needed to survive the rogue family court system. We want to help others now, so that they don’t have to learn the hard way, as we did. Let our experience work for you. Let us help you navigate a system designed for you to fail. Let us help you, and your children. Let our passion strengthen your position, before you walk back in the doors of family court. MadMoms is a non-profit 501(c)(3) corporation,
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located in North Carolina, that works to advance legal and systemic change
that addresses violence and discrimination against women and children.
MadMoms is not affiliated, associated, authorized, endorsed by, or in any
way officially connected with any other company, agency or government
agency.
26. Michigan ERAMerica
Judith Dabanian, Chair
Northville, MI
Mission Statement:
Michigan ERAmerica is a 501(c)(4), all-volunteer coalition of organizations
and individuals in this State. It was founded in 1976 following the first of
three attempts to rescind Michigan’s ratification of the Equal Rights
Amendment (ERA). The sole purpose is to protect Michigan’s ratification,
educate the public on the benefits of constitutional equality, and aid ERA
ratification efforts in non-ratified states. In the last two years, Michigan
ERAmerica has contributed to ratification efforts in Arizona, Illinois, North
Carolina, and Virginia. Michigan ERAmerica is a 501(c)(4).
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27. Michigan Woman Forward
Laura Carter Callow
Detroit, MI
www.miwf.org
Mission Statement:
To accelerate Michigan progress by Advancing equality and opportunity for
womens and girls.
28. Mid County Psychological Associates
Kimberly Haverly
St. Louis,, MO
Email: [email protected]
Mission Statement:
Psychotherapy for Children, Adolescents, and Adults (Individual, Marital
and Family).
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29. Moms in Office
Simona Grace
Sherman Oaks, CA
www.momsinoffice.org
Mission Statement:
Moms in Office is a Political Action Committee (527 Federal PAC)
dedicated to supporting and electing moms up and down the ballot. Moms in
Office is a leading national organization fighting to remove the barriers that
keep women from becoming the lawmakers we need today and we firmly
believe that the ERA will greatly advance our cause.
30. National Coalition Against Violent Athletes
Kathy Redmond
Littleton, CO
Email: [email protected]
www.ncava.org
Mission Statement:
Public education on a variety of issues regarding athletes and violent
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behavior. Also provides advocacy, referrals and research for victims of
violence by athletes. Promotes positive athlete development through
education, support and accountability. Nonprofit Tax Code Designation:
501(c)(3).
31. National Congress of Black Women, Inc.
Dr. Faye Williams, President
Washington, DC
www.nationalcongressbw.org
Mission Statement:
The National Congress of Black Women, Inc. (NCBW) is a non-profit
organization dedicated to the educational, political, economic and cultural
development of African American women and their families. The National
Congress of Black Women, Inc. (NCBW) is a 501(c)(3) nonprofit
organization whose purpose is to:
• Serve as a member unit of national non-partisan, independent, political
organization to provide for participation of African American women in the
political process.
• Encourage African American women to engage in political activities
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beginning with registering to vote.
• Confront forces in the cultural, economic and community environment
that threaten the physical, mental and moral well-being of African American
youth, especially those most at risk.
• Develop and encourage African American women to run for office at
all levels.
• Develop and advocate public policy positions, which advance the
political, social, educational and economic interests of African American
women, their families and communities.
• Encourage the appointment of African American women at all levels
of government and political parties.
• Empower African American women to act as role models for the next
generation of leaders.
32. National Equal Rights Amendment Alliance
Sandy Oestrich, Founder / President
Email: [email protected]
www.2passera.org
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Mission Statement:
To add the Equal Rights Amendment (ERA) into the US Constitution where
it will make most sex discrimination, male AND female, a violation of the
Constitution. To include all women and girls in the Nation's contract with its
People beyond that of The Vote; men are mentioned 39 times. This is
501(c)(3) non-profit organization.
33. National Girls Health and Justice Institute
Leslie Acoca
Los Angeles, CA
Email: [email protected]
www.girlshealthandjustice.org
Mission Statement:
The National Girls Health and Justice Institute’s mission is to measurably
improve the physical and mental health of girls in the juvenile justice system.
National Girls Health and Justice Institute (NGHJI), which works to advance
the health, legal, and human rights of all women and girls, and focuses on
creating access to health care for the 278,000 young girls who arrested each
year in the United States vigorously supports the Equal Right Amendment to
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the United States Constitution.
Equal protection under the law is a half century overdue, and has been
granted to virtually every other class of human being in the United States.
NGHJI supports the brief submitted by Equal Means Equal, the ERA, and
equal rights for women and girls. We demand that all barriers to passage of
the ERA be immediately and finally removed. There can be no legal or
human excuse for further delay in granting health and justice for women and
girls under established law.
34. National Women’s Political Caucus
Washington, DC
www.nwpc.org
Mission Statement:
NWPC is a national, pro-choice, multi-partisan, grassroots membership
organization dedicated to identifying, recruiting, training and supporting
women candidates for elected and appointed office. The National Women's
Political Caucus is a multi-partisan grassroots organization dedicated to
increasing women’s participation in the political process. NWPC recruits,
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trains and supports pro-choice women candidates for elected and appointed
offices at all levels of government. In addition to financial donations, the
Caucus offers campaign training for candidates and campaign managers, as
well as technical assistance and advice. State and local chapters provide
support to candidates running at state and local levels by helping raise
money and providing crucial hands-on volunteer assistance.
The NWPC Foundation has a nonprofit, 501(C)3 tax status. The National
Caucus has two basic components for tax purposes: NWPC, Inc., a 501(c)(4)
organization, and the NWPC Leadership Development, Education and
Research Fund (LDERF), a 501(c)(3) organization.
35. New Jersey Crime Victims' Law Center
Richard D. Pompelio, Esq
New Jersey Crime Victims' Law Center
1 Professional Quadrangle - Suite 3
Sparta, NJ 07871
Mission Statement:
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When someone is murdered, there is created a river of grief that will continue to flow until everyone who ever knew that person is dead. When a person is raped or beaten, the wounds never fully heal. It is only the victim’s courage which continues to fight submission to the effects of the violence.
OUR MISSION is a simple one – to assure that the innocent crime victim has a face, a voice and a significant meaning in our system of social justice.
WE ARE the first and the oldest pro bono crime victims’ law center in the nation.
SINCE 1992, NJCVLC has continually and comprehensively provided the following services on behalf of crime victims:
Pro bono legal assistance to crime victims, including direct representation in the criminal justice system;
Amicus Curiae advocacy in all federal and state courts throughout the nation in issues affecting victims’ rights;
Informational and technical assistance to attorneys, service providers and legislators on crime victims’ rights laws;
Training, lecturing and consultation on victims’ rights and remedies in the criminal and civil justice systems;
Direct representation of victims and assistance to attorneys in issues
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involving victim compensation.
36. National Organization for Women - Seattle Chapter
Linda Tosti-Lane
Legislative Coordinator
Seattle, WA
Mission Statement:
The purpose of Seattle NOW is to bring women into full participation in
American society, exercising all privileges and responsibilities thereof in
truly equal partnership with men. This purpose includes, but is not limited
to, equal rights and responsibilities in all aspects of citizenship, employment,
education and family life. This includes freedom from discrimination
because of sex, age, disability, economic status, marital status, parenthood,
race or sexual orientation. NOW Seattle is a 501(c)(4).
37. ERA Task Force Albuquerque Chapter of NOW
Sylvia M. Ramos
Albuquerque, NM
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Email: [email protected]
Mission Statement:
ERA Task Force promotes passage of the Equal Rights Amendment.
38. Florida NOW
Kim Porteous
New Port Richey, FL
Email: [email protected]
Mission Statement:
NOW’s purpose is to take action through intersectional grassroots activism
to promote feminist ideals, lead societal change, eliminate discrimination,
and achieve and protect the equal rights of all women and girls in all aspects
of social, political, and economic life.
Florida Now Education Fund Incorporated is a 501(c)(3).
39. Northern New Jersey NOW
Diane Scarangella, President
Chapter Mission statement:
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The purpose of the Northern New Jersey chapter is to take action to bring
women into full participation in the mainstream of American society now,
exercising all privileges and responsibilities thereof in truly equal
partnership with men. This purpose includes, but is not limited to, equal
rights and responsibilities in all aspects of citizenship, public service,
employment, education, and family life, and it includes freedom from
discrimination because of race, ethnic origin, age, marital status, sexual or
affectional preference/orientation or parenthood.
Northern New Jersey NOW is a 501(c)(4).
40. Santa Fe NOW
Sheila Lewis
Santa Fe, NM
Email: [email protected]
Mission Statement:
Santa Fe NOW is a longtime, active member of the New Mexico Coalition
for Choice. We engage in citizen lobbying on reproductive justice bills
during each year’s New Mexico legislative session and participate in
monthly Coalition meetings to develop policies and strategies for further
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access to abortion and the full range of reproductive health services for the
women of New Mexico. Independent of the Coalition – but in keeping with
its Mission – Santa Fe NOW fundraises to support the Alumbra Cares and
the Pro-Choice Safety Network Fund, which provides vital financial
assistance for non-medical expenses like transportation, food, and childcare
for low-income women having abortions in New Mexico.
Nonprofit Tax Code Designation: 501(c)(4).
41. Nurtured Parent
Patrice Lenowitz
Email: [email protected]
www.nuturedparent.org
Mission Statement:
Protecting children. Educating the public. Empowering survivors of
domestic violence and child sexual abuse. The Nurtured Parent is a
501(c)(3). Started out as a small support group in 2008. We have over 5,000
members from twenty-one counties in New Jersey.
42. Organic Consumers Association
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Alexis Baden-Meyer
Finland, MN
Email: [email protected]
Mission Statement:
To protect and advocate for consumers' right to safe, healthful food and other
consumer products, a just food and farming system and an environment rich
in biodiversity and free of pollutants.
Nonprofit Tax Code Designation: 501(c)(3)
43. Rethinking Eve LLC *
Jean Sweeney
Twitter: @RethinkingEve
Mission Statement:
Rethinking Eve, with its iconic symbol, inspires people to rethink the
mythologies, legal foundations and language used to deem women second
class citizens and helps them to create societies of peace.
Organization: Rethinking Eve LLC was created in 2014 to elevate women to
being equal with men. The initial focus has been on getting the Equal Rights
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Amendment added to the US Constitution through activism on various
platforms. The second phase is to bring awareness to how the system is
gamed to dishonor and disrespect women and the feminine. The third phase
is to help re-imagine societies where the masculine and feminine are in
balance.
44. SAG-AFTRA
Los Angeles, California
www.sagaftra.org
Mission Statement:
Screen Actors Guild-American Federation of Television and Radio Artists
(“SAG-AFTRA”) is the nation’s largest labor union representing working
media artists. SAG-AFTRA represents more than 160,000 actors,
announcers, broadcasters, journalists, dancers, DJs, news writers, news
editors, program hosts, puppeteers, recording artists, singers, stunt
performers, voiceover artists and other media professionals. In 2012, SAG-
AFTRA was formed through the merger of two labor unions: Screen Actors
Guild, Inc. (“SAG”) and the American Federation of Television and Radio
Artists (“AFTRA”). SAG-AFTRA members are the faces and voices that
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entertain and inform America and the world. SAG-AFTRA exists to secure
strong protections for media artists. Screen Actors Guild-American
Federation of Television and Radio Artists certifies that it is a non-profit
corporation; it does not offer stock; and it has no parent corporation.
45. Senior Care Options, Inc. *
Sharon J. Miles, LCSW, CASWCM, CASWG
Albuquerque, NM
Mission Statement :
Senior Care Options specializes in guiding, supporting and assisting families
and their aging loved ones in accessing community-based services. Aging
Life Care Management services provide support and information to families
and their aging parents in negotiating through the maze of senior care services.
Our ultimate goal is to allow aging loved ones to remain at home safely as
long as possible while maintaining their quality of life. We provide
comprehensive services including in-home assessment, care plan
development, arrangement of services and monitoring care as needed.
Senior Care Options, Inc. is a S-Corporation.
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46. Turning Point Suffragist Memorial Organization
Coline Jenkins
Fairfax Station, VA
https://suffragistmemorial.org
Mission Statement:
Turning Point Suffragist Memorial Association (TPSM) is building a
national memorial to American suffragists – with a special focus on those
imprisoned at Occoquan, VA, who endured harsh conditions and abuse to
win voting rights for American women. The memorial will honor these brave
women and provide awareness and education about how their courage,
methods and commitment led to the passing of the 19th Amendment to the
Constitution. We owe these women the honor of a Memorial. Join, donate
and get involved! To educate, inspire, and empower present and future
generations to remain vigilant in the quest for equal rights.
The Turning Point Suffragist Memorial Association is a 501 (c) (3) non-
profit Virginia Corporation.
47. The Women's Coalition
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P.O. Box 501956
San Diego, CA 92129
www.womenscoalitioninternational.org
Mission Statement :
The mission of The Women's Coalition is to empower women to maintain
custody and protect their children after divorce or separation and to end
systemic discrimination against women in contested custody cases.
The Women's Coalition is a 501(c)(3) non-profit organization.
48. Trafficking in America Task Force
Jerome Elam
Mission Statement :
Trafficking in America Task Force, along with its global partners are
working to bring an end to human trafficking. We work together with local,
state and congressional lawmakers and train law enforcement, medical and
mental health professionals to help bring an end to the scourge of human
trafficking. Helping Create a Culture Free of Modern Day Slavery
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Trafficking in America Task Force – a 501(c)3 non-profit charitable
organization.
49. TransLatin@ Coalition
Los Angeles, CA
Email: [email protected]
https://www.translatinacoalition.org
Mission Statement:
The TransLatin@ Coalition is an organization form by Trans Latin@ leaders
who have come together in 2009 to organize and advocate for the needs of
Trans Latin@s who are immigrants and reside in the US.
Since its inception The TransLatin@ Coalition has done advocacy work
across the US to ensure the voices of Trans Latin@s are heard. The
TransLatin@ Coalition’s sole purpose is to address the unique and specific
challenges and needs of Trans Latin@s who live in the United States.
Working with policy makers and supporting organizations we find solutions
to our unique needs and create structural changes to better our quality of life.
50. United Church of Christ
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Cleveland, OH
https://www.ucc.org/
Mission Statement:
United in Spirit and inspired by God's grace, we welcome all, love all, and
seek justice for all. The United Church of Christ is a federally recognized,
tax exempt organization pursuant to section 501(c)(3).
51. Virginia Sexual and Domestic Violence Action Alliance
Richmond, VA
www.vsdvalliance.org
Mission Statement:
The Action Alliance, a 501(c)(3) non-profit organization, is a diverse group
of individuals and organizations who believe that ALL people have the right
to a life free of sexual and domestic violence. We will use our diverse and
collective voice to create a Virginia free from sexual and domestic
violence—inspiring others to join and support values of equality, respect and
shared power. We recognize that sexual and domestic violence are linked to
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other forms of oppression, which disproportionately affect women, children,
and marginalized people. Understanding the great harm racism has created
for individuals, families and our communities in Virginia, we commit to
building within the coalition an anti-racist framework from which to address
sexual and domestic violence
52. The Woman’s Club of Olympia
Sandra M. Groves
www.WomansClubofOlympia.org
Mission Statement:
The Woman’s Club of Olympia supports the ratification of the Equal Rights
Amendment and a woman’s right to equality under the law codified by
amendment to the U.S. Constitution. We are a nonprofit 501c3 organization
and our founding members were among the earliest suffragists in
Washington state working to secure voting rights for women.
53. Women NC
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Maria Murray Riemann, Ph.D.
Executive Director
www.womennc.org
Mission Statement :
Leading North Carolina’s young adults in the elimination of injustice against
women and girls. We are a 501(c)(3) organization.
54. Women’s Equal Rights Legal Defense and Education Fund
Diane Aldrich
Executive Assistant to Gloria Allred, Esq.
Los Angeles, CA
www.amglaw.com
Mission Statement:
The Women’s Equal Rights Legal Defense and Education Fund is dedicated
to educating women about their legal rights and assisting them in vindicating
their rights by providing access to the courts. Our mission is to help bring
women into equal partnership with men in each and everyaspect of life and
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to improve the condition and status of women. Our goal is equal rights for
women under the law. The Women’s Equal Rights Legal Defense and
Education Fund is a California 501(c)(3) non-profit incorporated in 1978.
55. Women’s National History Alliance
Ellen Snortland
Santa Rosa, CA
www.nationalwomenshistoryalliance.org
Mission Statement:
The National Women’s History Alliance is an educational nonprofit
organization, founded in 1980, whose mission is to recognize and celebrate
the diverse and historic accomplishments of women by providing
information and educational materials and programs.
56. Zonta Club of Kenmore
Jeanne Phillips
www.ZontaClubofKenmore.org
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Mission Statement:
Founded in 1925, the Zonta Club of Kenmore, is committed to serve in a
leadership role in order to carry forth the vision and mission of Zonta
International and the District 4 Board – advancing the status of women
worldwide. The organization strives to be relevant by addressing and
supporting the changing needs of women locally and throughout the world.
This will be accomplished by engaging members in service, advocacy,
education and resource development. Zonta Club of Kenmore is a 501(c)(3)
organization.
SUPPLEMENTAL ADDENDUM
Additional Amici Curiae
57. Culture Reframed
Gail Dines, PHD
President
P.O Box 443
Sterling, MA 01564
646.856.9284
www.culturereframed.org
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Mission Statement:
Raising awareness and providing educational tools and resources to build
resilience and resistance in young people to hypersexualized media and porn.
Culture Reframed is a tax-exempt, 501(c)(3) non-profit organization.
58. Democrats Abroad
Salli Anne Swartz
Attorney at Law, Partner
Counseillère Jurdique de Democrats Abroad France
Democrats Abroad DPCA
PO Box 15130
Washington, DC 20003
www.democratsabroad.org
Mission Statement:
Democrats Abroad is the official Democratic Party arm for the millions of
Americans living outside the United States. We strive to provide Americans
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abroad a Democratic voice in our government and elect Democratic candidates by mobilizing the overseas vote. Democrats Abroad has 44 country committees throughout Europe, the Americas, the Middle East,
Africa and Asia. These country committees keep Americans abroad informed of their rights and help them participate in the U.S. political process. Our members live in more than 190 countries around the globe and vote in every state and Congressional district in the U.S.
We:
• Help Americans abroad vote in U.S. elections.
• Protect the right to vote for Americans abroad.
• Work with US government officials and elected representatives to
advocate for issues that concern Americans abroad
• Work with the broader Democratic Party to achieve our goals.
• Build communities of like-minded Americans around the world.
• Help elect Democrats in every congressional district in the U.S.
We are a non-profit association organized and operating under the Uniform
Unincorporated Nonprofit Association Act of 2010, D.C. Code § 29-1101 et seq.
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Democrats Abroad’s principal place of business is the District of Columbia,
and its current Chair is Julia Bryan.
59. Driftwood Kitchen Design*
Tammy Keithley
617-852-1184
driftwoodkitchens.wixsite.com/website
Mission Statement:
Support Equal Rights for all.
Driftwood Kitchen Design is a S corp.
60. Fiduciary Trust International***
280 Park Avenue, New York, New York 10017
781.274.9300
www.fiduciarytrust.com
Mission Statement:
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Fiduciary Trust International, a wholly owned subsidiary of Franklin
Templeton (ticker BEN), has a sustainable investing and impact investing
practice that partners with clients to have positive social and environmental
impact while achieving financial objectives. We support clients that desire to
align their investment portfolios with their personal values and social
priorities, including improving gender equality through gender lens
investing. We believe that the “Equal Rights Amendment” (“ERA”) is
critical to bring women to full equality in our country. On behalf of our
organization and our clients who support gender equality, we support this
amicus brief.
Our corporate structure is an LLC and we are a wholly owned subsidiary of
Franklin Templeton Investments, a publicly-traded company formally known
as Franklin Resources, Inc (ticker BEN).
61. Global Indigenous Council
Tom Rodgers
Acting President
Wakpa Sica Fort Pierre
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Great Sioux Nation, SD 57532 [email protected] www.globalindigenouscouncil.com
Mission Statement:
GIC’s mission includes membership, representation and participation for all tribal nations in the four hemispheres. The challenges, crises, and legacy of colonial conquest are not unique to the Americas. Throughout Europe,
Africa, Asia, Australasia and Oceania, the experience of indigenous peoples replicates ours. A purpose of GIC is to bring unity, reestablish ancient relationships, develop new alliances, exchange knowledge, and find commonality in our shared purpose of vision and strength for our future generations.
GIC believes that with Virginia's ratification earlier this year, the ERA should have automatically been added as the 28th Amendment to the
Constitution of the United States. Validating ERA and including it in the
Constitution would be an immediate and significant remedy to many of the injustices that Native Americans face.
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62. Hollywood NOW
John Ericson
hollywoodnow.org
7540 Fountain Ave., Apt. 2
West Hollywood, CA 90046
Mission Statement:
The Hollywood Chapter (Hollywood NOW) addresses today's pressing
issues facing women in Hollywood and West Hollywood - both the
geographical community and the industry. We're working to see more
equitable treatment and representation of women in our community and
industry. In our never-ending efforts to creating a defiant sisterhood and a
movement towards empowering women and young girls to be extraordinary
leaders, Hollywood NOW also carries the mission to bring advocacy and
awareness to the social justice issues that Trans women face in our society.
Hollywood NOW is a 501(c)(4) non-profit corporation.
63. Kuta Intellectual Property Law, LLC*
Christine Kuta,
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PO Box 380808
Cambridge, MA 02238
www.kutaiplaw.com
Mission Statement:
Support Equal Rights for all. Active limited liability company formed in the
Commonwealth of Massachusetts to provide legal services.
64. Moms Fight Back
Maralee McLean
MomFightBack.org
Mission Statement:
Moms Fight Back’s mission as a 501(c)(4) is focused on the common good
we can accomplish as women and moms. Currently, we are focusing our
efforts on four vital issues: teen sexual assault, school safety, family court
reform and the impact of marijuana on youth.
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Through our project work, we will address each issue in the context of how it impacts a child’s life at home, at school as well as in the legislative and judicial systems.
Moms Fight Back is committed to building a community of 100,000
Colorado moms. We believe it’s paramount to give moms the opportunity, and forum, to learn and discuss how our legislators, community leaders, and local non-profits can come together to best support Colorado moms as they care for their families.
Furthermore, it is the policy and commitment of Moms Fight Back that it does not discriminate on the basis of race, age, color, sex, national origin, physical or mental disability, or religion. Moms Fight Back takes seriously it’s moral and legal commitment to a policy of equal opportunity and non- discrimination in employment and all personnel, grant making, training, volunteer opportunities (including Board membership) and all other programs and activities and to recruit, hire, train, and promote at all levels the most qualified individual without regard to race, ethnicity, age, color, religion, sex, gender identity, national origin, sexual orientation,
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transgender/transsexual identity, economic class, educational background,
physical or mental disability, medical condition, or marital status.
65. Picture Social Justice
Paula J. Caplan, Ph.D.
Executive Director
Mission Statement:
The Corporation’s primary purpose shall be to promote social justice
primarily through production and distribution of documentary films, which
will be intended to raise awareness, educate, and advocate for those
adversely impacted by social justice issues. Primary issues that the
Corporation will focus on include eliminating prejudice and discrimination.
Picture Social Justice is a 501(c)(3).
66. Real Estate Advisors Group*
Maria Papadopoulos
195 Mt Auburn St, Watertown, MA 02472
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617-571-8883
http://m.theadvisorsre.com/m/
Corporation
Mission Statement:
Support Equal Rights for all.
67. Sustainable Marin
Peter Waring
board member
P.O. Box 1822
Ross, CA 94957
www.sustainablemarin.org
Mission Statement:
working for a future that works for everyone.
Sustainable Marin is a non-profit organization of volunteers who advocate
and educate about sustainability at the County level in Marin.
The mission of Sustainable Marin is to advance sustainable principles in the
County of Marin in the State of California with the goal to transform the
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region in the areas of environment, economics, and society into a sustainable community by the year 2040 and beyond.
Sustainable Marin promotes policies and practices in Marin County to:
• Sustain our natural capital and environmental assets
• Bolster localized economic strength and independence
• Expand locally-owned green businesses and clean-tech jobs
• Encourage community cooperation and social justice
OUR VISION
We do this through advocacy and outreach to community leaders and the public, and by educational events and community forums that inspire sustainability in Marin and its region. To us, “Sustainability" means staying the course, surviving over the long term, maintaining our capacity to live well and improve our quality of life, not only today but for generations to come. We are an all-volunteer, non-profit corporation, and we invite all
Marinites to join our efforts.
We are a non-profit, umbrella group supporting a number of local City &
Town Sustainable organizations throughout Marin County, CA. We encourage sustainability through education, events, lobbying, and community organizing. Our Board members are involved in a variety of
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projects, including alternative transportation, “Resilient Neighborhoods”
guided self-education groups working to reduce energy & resource
consumption, www.GreenChange.net climate action network, wildfire
mitigation, solar energy & Green Building.
68. Veterans For Peace
Albuquerque Chapter #63
202 Harvard SE
Albuquerque, NM 87106
Chaia Ross, Treasurer
www.vfp-abq.com
Mission Statement:
Veterans For Peace is an international organization made up of military
veterans, military family members, and allies. We accept veteran members from
all branches of service. We are dedicated to building a culture of peace,
exposing the true costs of war, and healing the wounds of war. Our networks
are made up of over 140 chapters across the United States and abroad.
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We, as military veterans, do hereby affirm our greater responsibility to serve the
cause of world peace. To this end we will work, with others both nationally and
internationally
• To increase public awareness of the causes and costs of war;
• To restrain our governments from intervening, overtly and covertly, in
the internal affairs of other nations;
• To end the arms race and to reduce and eventually eliminate nuclear
weapons;
• To seek justice for veterans and victims of war;
• To abolish war as an instrument of national policy.
To achieve these goals, members of Veterans For Peace pledge to use non-
violent means and to maintain an organization that is both democratic and open
with the understanding that all members are trusted to act in the best interests
of the group for the larger purpose of world peace.
69. Wisdom Lotus Foundation Inc
5 Longmeadow Rd.
Lincoln, MA 01773
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781-975-0521 www.wisdomlotusfoundation.org
Mission Statement:
As an organization part of our core mission is the goal of fostering and supporting the well-being of women and children. We strongly believe that adding the ERA to the US Constitution is long overdue and is in alignment with our mission.
Wisdom Lotus Foundation is a 501(c)(3) charitable foundation.
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