Publication Title

Washington University Journal of Law & Policy


Sexual orientation change efforts contains two forms, “talk therapy” and “aversion therapy.” The Third and Ninth Circuits upheld states’ bans on conversion therapy for minors based on two different reasonings, as a permissible regulation of speech and of conduct. However, the Supreme Court decision in National Institute of Family and Life Advocates v. Becerra, abrogated the reasoning of both circuits. This Note argues that conversion therapy does not fall under the protections of the First Amendment.