On April 27, 2023, Kansas became the first state in the country to institute a statewide definition of sex. “A ‘female’ is an individual whose biological reproductive system is developed to produce ova,” the law declared, “and a ‘male’ is an individual whose biological reproductive system is developed to fertilize the ova of a female.” Since then dozens of state legislatures have introduced similar bills; sixteen have passed. In Indiana and Nebraska governors have issued executive orders to the same end. Each of these measures effectively strips transgender people of legal recognition.
The language of these policies usually distinguishes men from women by their reproductive capacity, which is assumed to be determined at birth or even at conception. Each statute mandates that its definitions of “sex,” “female,” and “male” be used whenever those words appear in any part of the state code. Some purport to be establishing a “women’s bill of rights,” as the titles of Kansas’s and Oklahoma’s bills suggest; Louisiana’s is titled “The Women’s Safety and Protection Act.” (On the other hand, the name of North Dakota’s bill—into which legislators slipped another term they wanted to define—captures the arbitrariness involved: “The Definition of Female, Male, Sex, and Scrap Metal Dealer.”)
This legislation is part of a broader onslaught. In the past few years Republican-controlled state legislatures have introduced thousands of bills targeting trans people, with measures to ban puberty blockers and hormones for trans youth, bar trans girls and women from sports, mandate that bathroom access be based on birth sex, outlaw drag performances, and more. So far more than two hundred of these laws have passed, with grave, often life-changing consequences for the trans residents of red states across the country.
On the first day of his second term, President Donald Trump issued an executive order titled “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government.” It called for the adoption of its definitions of male and female in everything the government does or pays others to do, from maintaining sex-segregated spaces such as bathrooms in federal parks, prisons, and homeless shelters to enforcing Title IX in schools, funding research, and issuing passports. Sex, it stipulates, is determined at conception based on the size of the reproductive cell: females have larger ones.
Major women’s organizations—groups founded at various points over the past century to protect women from discrimination and harm—condemned the order, from the National Organization for Women to the National Women’s Law Center. But for some the government’s defense of “sex-based” rights is long overdue. Among the order’s most effusive admirers was the Women’s Liberation Front (WoLF), a self-described radical feminist organization founded in 2013 that calls for abortion on demand. Over the past few years WoLF has collaborated with Independent Women’s Voice—a conservative outfit that grew out of a group called “Women for Judge Thomas,” opposes the Equal Rights Amendment, and dismisses the “alleged” gender pay gap—to draft model legislation for a “Women’s Bill of Rights.” (The Heritage Foundation has its own, similar model legislation, the “Defining SEX Act.”) WoLF and its supporters often describe themselves as defending nothing less than “biological reality” itself: Kara Dansky, president of the US chapter of Women’s Declaration International (and a former WoLF board member), applauded the order on the grounds that “‘gender identity’ ideology robs women and girls of female-only spaces and denies the material reality of sex.”
This alliance has dangerous implications. By campaigning to make birth sex the sole basis for legal distinctions between men and women, advocates of a “gender critical” feminism evidently hope to cordon off trans women from the rest of womanhood without jeopardizing cisgender women’s access to the rights and freedoms that feminism won. But the logic of this position in fact aligns with—and ultimately serves—the desire to roll back feminism itself. That trans and nonbinary people have been able to move beyond their birth sex classifications is due precisely to the successes of the women’s liberation movement. And that movement’s most influential social victory, the decoupling of ideas about biology from ideas about how women ought to be, is precisely the achievement under threat today.
The immediate aim of the laws defining sex in biological terms is to exclude trans people from places where sex difference still matters—any place one has to present ID (upon accepting a job, at the polls in many states, at airport security, at borders) or be segregated according to sex (in athletics, in bathrooms, in locker rooms, in college dormitories, in homeless shelters, and in prisons). This is itself a grave injustice. A civilian employee of the Illinois National Guard told Time that she’s been “walking on eggshells” ever since Trump’s executive order prohibited trans federal workers from using the bathroom matching the sex to which they had transitioned: “Life can be very dangerous for trans people.” But these laws ultimately insist that what Dansky called the “material reality” of sex ought to be the basis of all norms and expectations about how one should live—that biology is in fact destiny. This is exactly the constraint that feminism has long fought to undo.
There is no single sound definition of “biological sex.” Even if you know the chromosomes of a fertilized egg, you can’t definitively determine which type of reproductive cells will develop.1 Perhaps it was in deference to this fact that in February the Department of Health and Human Services issued guidance that revised the definition in Trump’s executive order, defining sex as “a person’s immutable biological classification as either male or female” without reference to conception.
But that definition, too, flies in the face of current knowledge. Biomedical researchers have come to recognize that sex is not a single thing but an umbrella term for a number of things, including sex chromosomes, internal reproductive structures (prostate, uterus), gonads (testes, ovaries), and external genitalia. For most people, these characteristics generally align in a single direction, male or female. But they won’t for everyone. At birth some people, often labeled intersex, don’t fall neatly into the male or female column. (The HHS revision, like many of the statewide sex definition bills, includes a carve-out for “disruption or congenital anomaly,” but the policies resulting from Trump’s order don’t spare intersex people who live in a sex different from the one they were assigned at birth.) For cis, trans, and intersex people alike, many of the elements of sex vary over the course of a life: secondary sex characteristics like facial hair and breasts don’t develop until puberty, reproductive structures such as the uterus can be surgically removed, hormone levels fluctuate over time, and many people—cis and trans—take exogenous hormones.2
A decade ago it would have been hard to imagine legislators in state after state rising from their seats to debate the biological basis of sex, governor after governor signing into law definitions of “male” and “female,” or the president of the United States issuing pronouncements about large reproductive cells in an executive order on the first day of his term. Sex classification was beneath legislative notice, an administrative matter left to bureaucrats at various agencies and, when a policy was challenged, to the occasional judge. Those bureaucrats, as I have argued in these pages, have been far less interested in any grand, universal idea about what sex is than in what sex does for a given agency’s work.3 Officials in prisons, for example, have generally defined sex more restrictively than officials in departments of motor vehicles do, even within the same state. In recent decades, with few exceptions, even conservative states allowed people to change the sex marker on their drivers’ licenses, because those documents, from the state’s point of view, need to accurately describe what their holders look like.
Family law was a different story. Before bans on same-sex marriage were declared unconstitutional, judges often ruled that even trans people who had changed all their identity documents should be classified according to birth sex for the purposes of marriage, parentage, and inheritance. This is no accident: when it came to marriage and parenthood, the mere existence of trans people revealed that legal relationships—who is recognized as a parent, who gets to inherit what from whom—were masquerading as biological ones.
In 1989, for example, the Supreme Court upheld a long-standing common-law tradition of presuming that, during a marriage, the husband is the father of any children born to his wife. In Michael H. v. Gerald D., it was known that the husband was not the biological parent, but the justices maintained the fiction and ruled that he was legally the father anyway. About fifteen years later, however, when a married transgender man who was listed as the father on his child’s birth certificate asserted his fatherhood rights during divorce proceedings, the Illinois Court of Appeal ruled against him, holding that he was not male and therefore not entitled to the marital presumption of paternity. By excluding trans people, courts kept the biological veneer of inheritance intact. Only when the Supreme Court ruled in Obergefell v. Hodges (2015) that bans on same-sex marriage were unconstitutional was the problem that trans people posed for family law resolved: now a marriage involving a trans person would be valid whatever sex the state decided they were.
The law’s long-standing sex-based classifications, meanwhile, made the exclusion of women from public life possible. In the 1873 decision Bradwell v. Illinois, endorsing the principle that “God designed the sexes to occupy different spheres,” the Court found it perfectly constitutional for the State of Illinois to refuse to admit women to the bar: “The natural and proper timidity and delicacy which belongs to the female sex,” Justice Joseph P. Bradley wrote, “evidently unfits it for many of the occupations of civil life.”
In the twentieth century many of the legal distinctions between men and women started falling away, in large part owing to the efforts of what we now call liberal feminism.4 Reed v. Reed (1971) was the first case to determine that the Equal Protection Clause—which prohibits states from denying anyone the equal protection of the laws—applied to sex discrimination. Many other cases about state-sponsored discrimination followed, culminating in United States v. Virginia (1996), which found that a state-supported military academy could not limit its enrollment to men. Other major cases concerned discrimination in the private sphere. Because Title VII of the Civil Rights Act of 1964 had banned sex discrimination in employment, in 1989 the Supreme Court held that the accounting firm Price Waterhouse couldn’t deny a promotion to one of its workers, Ann Hopkins, for behaving “aggressively” if the company would reward that same behavior in a man. Doing so, it ruled, meant enforcing gendered expectations—stereotypes—tied to the employee’s sex.
As sex-based distinctions diminished, trans people gained legal ground. In 2000 an appeals court found that a bank had violated a federal prohibition on sex discrimination in lending when it refused to let a “biological male…dressed in traditionally feminine attire” apply for a loan. In 2020 Justice Gorsuch wrote the majority opinion in Bostock v. Clayton County, which held that discrimination against trans people is a form of sex discrimination under Title VII: if you fire a person assigned male at birth for transitioning to female, but you wouldn’t fire a person assigned female at birth for identifying as female, then you’re treating people differently based on their sex. These are the gains that the laws and executive orders defining sex as an immutable biological binary threaten to dismantle—and not just for trans people.
How did sex classification transform so quickly from a cog in the machinery of our administrative state into so central a dogma to the right-wing project? After Obergefell, having lost the battle over same-sex marriage, Republican strategists started casting around for a new target. In the struggle over trans rights, they found an especially potent wedge issue: a very small proportion of the population (roughly 2.8 million people above the age of thirteen), not well understood by most Americans, living in ways that confounded common assumptions about sex.
The strategists’ first statewide attempt backfired spectacularly. When North Carolina passed a bill in 2016 requiring all its residents to use bathrooms matching the sex listed on their birth certificate, hundreds of corporations and the National Collegiate Athletic Association threatened boycotts. Theodore B. Olson, a Republican who had served as solicitor general in President George W. Bush’s administration, filed an amicus brief in the Department of Justice lawsuit to block the law on the grounds that it compelled “transgender people to deny a fundamental feature of their character and personhood in the name of safety concerns that are wholly illusory.” It was repealed a year later.
The right moved on from bathrooms to organized sports, which turned out to have more traction with the public. In 2019 a poll by a conservative organization called the American Principles Project discovered that banning trans athletes was more popular among voters than banning trans people’s access to bathrooms. The following year Idaho passed the first law banning trans girls and women from participating on girls’ and women’s teams in primary and secondary schools and colleges. Eight more states passed similar laws in 2021; the number has now risen to twenty-seven.
In 2021 came the attack on medical care for trans youth, then censorship in school curricula and public libraries—and then the revival of the panic over bathrooms. Twenty states now have bathroom bans. This time there are no corporate boycotts; the strategy evidently succeeded at expanding a new prejudice. The number of anti-trans bills considered each year has grown from twenty-one in 2015 to over one thousand in 2025.
In much of the country, this legislative barrage licensed a political culture openly hostile to trans people even before Trump began his second term. In 2023 The Texas Observer reported that Sid Miller, the commissioner of the state’s Department of Agriculture, issued a new dress code policy for department employees requiring them, among other things, to wear clothes “consistent with their biological gender.” Last year the Florida Department of Highway Safety and Motor Vehicles issued a memorandum declaring that “misrepresenting one’s gender, understood as sex, on a driver’s license constitutes fraud,” and the Texas city of Odessa enacted a bathroom law that allows private citizens to sue, for “not less than $10,000,” anyone they catch using a city-owned bathroom that doesn’t correspond to their birth sex. In a survey from December 2024, the Williams Institute found that 21 percent of its trans respondents had already moved to a state more progressive on trans issues, and another 25 percent were considering doing so. “Simply put,” one of the anonymous respondents said, “my state does not offer the safety I deserve.”
The architects of this anti-trans campaign had quickly settled on a playbook that could help them forge an alliance with conservative Christians. For decades, as the legal scholar Mary Anne Case has shown,5 Catholic leaders outside the US, including the future pope Benedict XVI, had been assailing “gender theory” and “gender ideology,” phrases that Vatican publications used to describe ideas about gender roles within marriage that threaten the “physical, psychological and ontological complementarity” of men and women. Breaking free from this religiously grounded understanding of sexual difference, they argued, results in such degradations as premarital sex, birth control, abortion, homosexual marriage, and trans identity.
The term “gender ideology” spread less quickly in the US than it did in Europe and South America. One reason was that, since the 1970s, “gender” had been used interchangeably with “sex” in US law, following a strategy—pioneered by Ruth Bader Ginsburg during her years as a legal advocate—of avoiding the word “sex,” which might “conjure up improper images” in the minds of judges. It was not until around 2017 that leaders of the religious right—from Roger Severino, then the director of the DeVos Center for Religion and Civil Society at the Heritage Foundation, to Tony Suarez, a member of Trump’s evangelical council during his first administration—latched on to the terminology and started describing abortion rights and LGBTQ rights as pernicious effects of “gender ideology” and “gender theory.” This rhetoric soon crossed over into right-wing evangelical Protestantism, featuring prominently at the Family Research Council’s annual Values Voters Summit in 2018. Soon it moved into the mainstream, where it was used more narrowly as a specifically anti-LGBTQ—and often just anti-trans—rallying cry.
Talk of “gender ideology” sent a dual message. To religious conservatives the phrase signaled a wholesale counterrevolution against reproductive rights, feminism, and LGBTQ rights; at the same time, it allowed politicians to seem to limit their public-facing attacks to a community made vulnerable by its small size and by the fact that a majority of Americans don’t personally know a trans person. This ambiguity, in turn, made it possible for anti-trans campaigners in the US to take on the mantle of women’s rights by presenting their defense of sex-segregated spaces and institutions as a way to “protect women.” Most women’s organizations don’t support anti-trans campaigns, but it can’t be denied that many people who consider themselves feminists have accepted the argument that the very existence of transgender people, especially transgender women, threatens feminism itself.
Since Trump took office, his administration has used every tool at its disposal to crack down on the rights and freedoms of anyone who lives in a gender different from their birth sex: banning visas for trans athletes; denying public service student loan forgiveness to anyone who works at an organization that provides health care to transgender youth; making it official US policy not to “fund, sponsor, promote, assist, or support the so-called ‘transition’ of a child from one sex to another”; and threatening to cut funding to schools that indoctrinate students in “gender ideology.” A blitz of anti-trans executive orders requires that passports list birth sex, trans women in federal prisons be housed with men and denied transition-related medical care, and federal employees use bathrooms associated with their birth sex. (All these policies are being challenged in the courts, and some have been temporarily blocked.)
Federal agencies are now required to expurgate any statements, policies, forms, or regulations that might be thought to undermine “sex-based rights,” including the propagation of “gender ideology,” which replaces “the biological category of sex with an ever-shifting concept of self-assessed gender identity.” Ongoing litigation has forced the administration to restore research web pages that it had deleted in the course of this purge, but now they come with a warning. A Centers for Disease Control web page listing “fast facts” about “HIV and Women,” for instance, includes trans women in its analysis but prefaces the research it summarizes with a statement asserting that “any information on this page promoting gender ideology is extremely inaccurate and disconnected from truth.”
The administration has hardly tried to hide its bigotry. Russell Vought, Trump’s director of the Office of Management and Budget and the architect of much of Project 2025’s agenda, has referred to “transgender sewage that’s being pumped into our schools and institutions.”6 Trump’s executive order banning trans people from serving in the military dispenses with operational justifications in favor of calling trans service members fundamentally dishonest: “Adoption of a gender identity inconsistent with an individual’s sex conflicts with a soldier’s commitment to an honorable, truthful, and disciplined lifestyle, even in one’s personal life.”
What had been a hodgepodge of seemingly contradictory state policies on sex classification is now a stark partisan map of red and blue. Trans students in Colorado can, at least in theory, use bathrooms and play on sports teams that match their gender. Those living in South Dakota cannot. In New York it’s considered an illegal form of harassment to consistently misgender a coworker; in Wyoming you can sue the state for damages if a government entity or state contractor asks you to use a colleague’s “preferred pronoun.”
This blue-state backstop may not last long. The Trump administration is using the levers of federal power, including Title IX, to force institutions in blue states to conform to its “Defending Women” executive order. The Department of Justice has issued subpoenas to providers across the country seeking medical records related to the provision of health care for trans youth. In August the Trump administration announced that, as of 2026, transition-related medical care would no longer be covered under the Federal Employee Health Benefits Program, the insurance plan used by eight million current and retired federal employees and their families.
Many of these policies remain the subject of battles in the courts. But the outcomes of those cases could favor the right, given the Supreme Court’s increasingly activist conservative majority. In June the usual six-justice bloc ruled in United States v. Skrmetti that Tennessee did not discriminate on the basis of sex when it passed a law banning puberty blockers and hormones for trans youth, even as it allowed the same medications for cisgender youth.
Chief Justice Roberts insisted that Skrmetti was a case narrowly about medical treatments for minors. But in the following weeks the justices cited the ruling to vacate and remand for reconsideration recent appellate decisions, even though they involved other matters. Two concern the constitutionality of excluding adults—state employeesin North Carolina and people on Medicaid in West Virginia—from transition-related medical coverage. A third concerns the governor of Oklahoma’s 2021 executive order barring individuals from amending the sex designation on their birth certificate—an order that a lower court had found to be in violation of the Equal Protection Clause. Lower courts have also taken the decision as a cue to retreat: less than two weeks after the Skrmetti decision, the Seventh Circuit vacated its own opinion in a case involving bathrooms in schools.
In early July the Court agreed to hear two cases challenging bans on trans girls and women playing sports. In one of them the State of Idaho, defending its ban, called on the Court to adopt an “objective” definition of sex (reproductive capacity, perhaps) rather than the “subjective” one (gender identity, perhaps) advanced by some lower courts. It is hardly a stretch, considering these cases, to imagine that the justices may be open to such a suggestion, which would entail rolling back transgender rights protections across the country.
That possibility became still more concerning in November, when the Court let the Trump administration temporarily proceed with its new policy of putting birth sex on passports because, according to the unsigned order, “the Government is likely to succeed on the merits.” In the majority’s view, putting the bearer’s sex at birth on their passport is “merely attesting to a historical fact.” This undermines the very purpose of a passport, which has to be renewed every ten years precisely because it serves as an up-to-date description of the bearer; putting birth sex on a trans person’s passport is akin to requiring that the photograph be a baby picture. Meanwhile the policy will mean that transgender people have to choose between risking discrimination and harassment at border crossings or forgoing international travel.
The administration’s policies might seem to target trans people with frightening precision. But the logic that governs them will inevitably seep—and is arguably designed to seep—into laws and precedents affecting cis people as well, particularly cis women. Even as Trump purports to “defend women” by attacking trans communities, his administration is working to dismantle the gains that liberal feminism secured. His executive order “Ending Radical and Wasteful Government DEI Programs and Preferencing” has licensed the erasure of women’s achievements across the federal government; the Bureau of Engraving and Printing canceled its association with Women in Manufacturing—hardly a radical organization—and the Secret Service blocked employees’ access to material on women’s law enforcement groups.
The administration’s war on abortion continues apace: since January it has appointed judges with antiabortion records, dropped an abortion rights case pursued by the previous administration, rescinded guidance on the obligations of hospitals to provide emergency abortion care, reinstated the global gag rule, and refused to distribute $10 million worth of contraceptives to women in low-income countries. And although much attention has been paid to the administration’s ongoing efforts to force colleges and universities to ban trans women from participating in women’s sports, there’s been much less coverage of its decision, this past February, to reverse a Biden-era guidance that instructed colleges to distribute “name, image, and likeness” revenue to male and female student athletes equitably—a change affecting far more women than have ever had to compete alongside trans athletes.
The push to confine transgender people to their birth-assigned sex will only help roll back women’s legal rights further, because limiting sex discrimination law to biological sex means severely undermining it in practice. Judges today often assume that the Supreme Court’s rulings on sex discrimination rest on a biological understanding of sex. But as Naomi Schoenbaum has shown in an authoritative recent article, when the Court’s justices have struck down laws that discriminate on the basis of sex, with few exceptions they have not been concerned with biological sex itself. Instead they have relied on the social phenomenon of sex stereotyping to justify finding a given law in violation of the Equal Protection Clause.7 The 1864 Idaho law the Court struck down in Reed, which favored men as estate administrators, had nothing to do with the kind of reproductive cells one has; its rationale was that women are not as competent at executing estates as men—a stereotype. In Frontiero v. Richardson (1973), the Court likewise found that automatically allowing male service members but not female ones to claim their spouses as dependents relied on stereotypes about gender roles.
Conflating gender with biological sex results in the very kind of sex stereotyping that this tradition of law has long opposed. Gender theory has advanced greatly since the Court began striking down sex-based distinctions as discrimination. But the old-fashioned concept of sex stereotyping suffices to explain what’s so concerning about, for instance, the findings section of the Tennessee law upheld in Skrmetti, which lists the state’s “legitimate, substantial, and compelling interest in encouraging minors to appreciate their sex, particularly as they undergo puberty.” There’s a lot of coercion required for the state to “encourage” such appreciation.
That coercion isn’t confined to trans people: the current wave of efforts to enshrine biological definitions of sex pressures cis people, too, to conform to a conservative vision of gender difference. A sports ban in Utah led officials to investigate the birth sex of a cis girl after parents of her competitors complained. News reports document a troubling number of gender-nonconforming cis women being harassed in women’s bathrooms. A play about boys cast as women in Shakespearean theater was canceled at the University of Central Oklahoma because, according to university administrators, its gender-blind casting may have run afoul of Oklahoma’s 2024 anti-DEI bill and the Trump administration’s approach to Title IX. The new Texas Department of Agriculture dress code applies not only to employees living in a gender different than their assigned birth sex but to all employees full stop. Adhering to business attire, for men, involves “a long-sleeved dress shirt, tie, and sport coat worn with trousers.” For women, it means “tailored pantsuits, businesslike dresses, coordinated dressy separates worn with or without a blazer.”
To justify defining sex according to sex assigned at birth, some state bills refer to “enduring” physical differences between men and women. That word is a nod to Justice Ginsburg’s decision in United States v. Virginia, one of the pillars of feminist jurisprudence. Ginsburg noted that, because “physical differences between men and women…are enduring,” there may be limited instances where it could be constitutional for governments to treat men and women differently.
Here she might indeed have been thinking of bathrooms or locker rooms, though it’s possible she would have thought birth sex the wrong criterion for such segregation. (Birth sex rules would require even the most masculine transgender man—bearded, muscular, and so on—to use women’s bathrooms, which would be unlikely to make women feel safer.) But the state’s interest in treating men and women differently must, according to the Court’s own doctrine, be substantially related to an important government interest, and Ginsburg stressed that this interest needs to be independent of the classification itself. She cited a 1982 decision written by Sandra Day O’Connor, Mississippi University for Women v. Hogan, which found that a state nursing program violated the Equal Protection Clause by limiting its enrollment to women. Drawing on O’Connor’s language, Ginsburg pointed out that a gender-based rule cannot be justified by “circular” reasoning or “‘self-fulfilling’ prophec[ies]” based on “‘fixed notions concerning the roles and abilities of females.’”
And yet that doctrine is starting to come undone. Most of the state-level bills and orders defining sex include a paragraph spelling out the government’s objective in mandating the separation of sexes, such as maintaining privacy and safety. At least two of these policies—the statute passed this year in Texas and the executive order by the governor of Nebraska—include “education” in the list of potentially appropriate places for sex segregation. The Texas statute specifies that
biological differences between the sexes are enduring and may, in some circumstances, warrant the creation of separate social, educational, athletic, or other spaces in order to ensure individuals’ safety and allow members of each sex to succeed and thrive.
What sorts of educational experiences will these “enduring differences” between men and women lead to? For men, perhaps military leadership training? And for women, nursing programs? We don’t need gender theory to identify the circular reasoning at work in such laws: the state can relegate men and women to different “social, educational, athletic, or other spaces” for the simple reason that they are, according to the state, different. Nondiscrimination law always provided a thin sort of protection against such inequities, and over the years liberal feminism has drawn well-deserved criticisms for its myopia around class and race. But even that fragile latticework of formal equality will be missed when it’s gone.
Over the past two decades, anti-trans and pro-trans policy has swung, pendulum-like, with successive administrations, drawing headlines with each reversal. But the conservative legal movement operates on a longer timescale. It advances methodically through court decisions and attorney generals’ memos; it gradually works to spread generalized fear—of “wokeness,” of “DEI,” of “gender theory”—in the institutions of civil society. The current anti-trans movement claims to defend women from trans people—but in practice it has begun to quietly dismantle the doctrinal edifice built to protect all women from discrimination. For the logic of the anti-trans campaign is, at root, little different from Justice Bradley’s logic in Bradwell: once again the conflation of gender with sex, of stereotypes with nature, becomes the basis for deciding whose lives do—and don’t—count as “natural and proper.”
—November 19, 2025
English (US) · 