The Missouri Court of Appeals decision below, that a mother's homosexual orientation cannot be presumed to be detrimental to her children is supported by a considerable body of scientific research on children of lesbian parents and on parenting by lesbians. Scientific investigation has consistently found that children raised by lesbians or gay men are comparable to children raised by heterosexuals and that lesbians and gay men are as good parents as heterosexuals. These studies provide no support for any presumption that a lesbian or gay parent's sexual orientation is or will be harmful to the children. Thus, as the Court of Appeals below found, the best interests of the child of a lesbian or gay parent can be determined only through an individualized, fact-based assessment.

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I. CHILDREN RAISED BY LESBIAN OR GAY PARENTS ARE AS HEALTHY PSYCHOLOGICALLY AND SOCIALLY AS CHILDREN RAISED BY HETEROSEXUAL PARENTS.

Research indicates that the sexual orientation of parents is not a predictive factor in the psychological and social development of their children. In the last two decades, a number of studies have been conducted on children of lesbian or gay parents. The consistent conclusion drawn from these studies is that the children demonstrate no appreciable differences in intellectual development, psychological well-being or social adjustment from children raised by a heterosexual parent. The research further shows that children of homosexual parents are no more likely themselves to be homosexual than children of heterosexual parents.

Initially, research on children raised by homosexual parents focused on the large number of children who were born in the context of a heterosexual relationship and lived, after their parents divorced, with their lesbian mother (and in some cases her partner). In order to separate the effects of divorce from any possible effects of the parent's sexual orientation, the studies compared these children?s development and well-being to the development and well-being of children of divorced parents being raised by a heterosexual parent (and in some cases the parent's spouse or partner). As more lesbians have become parents through donor insemination and adoption, a number of more recent studies have focused on children raised from birth by lesbian parents. Studies in both categories have reached the same conclusion: the sexual orientation of parents does not appreciably affect the psychological development, social adjustment, or sexual orientation of their children.

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A. Psychological Development

In studies of single-parent households produced by divorce, children raised by lesbian mothers and by heterosexual mothers demonstrated largely identical levels of psychological adjustment. Researchers found no statistically significant differences among such children in the prevalence of emotional or behavioral problems such as unsociableness, emotional difficulty, hyperactivity, or conduct problems. Similarly, a study of children raised by divorced mothers in two-adult households concluded there was no difference in the self-concepts and levels of self-esteem of adolescents who lived with a lesbian mother and her same-sex partner and adolescents who lived with a mother and her opposite-sex partner; all fell within the normal range.

Following such children into adulthood, researchers have found that the adult sons and daughters of lesbian mothers are no more likely to experience anxiety or depression, no more likely to have sought professional help for mental health problems, and no more likely to experience periods of unemployment than adult sons and daughters of heterosexual mothers. Another study of adult daughters found no higher incidence of emotional problems among those who had been raised by a lesbian mother than among those raised by a heterosexual mother. Thus, two scientists reviewing studies in this area commented:

The most striking feature of the research on lesbian mothers, gay fathers, and their children is the absence of pathological findings. The second most striking feature is how similar the groups of gay and lesbian parents and their children are to the heterosexual parents and their children that were included in the studies.

Consistent with the results of research on children of divorced parents, the research on children raised from birth in lesbian households has also found psychological parity between these children and their peers from heterosexual households. In a recent study comparing children raised from birth in lesbian households with matched children raised in heterosexual households, the researchers found it "impossible to distinguish" between the groups of children on the basis of social competence or behavior problems. The study concluded that ?[p]resent data are consistent with the notion that parenting ability and sexual orientation are unrelated.?

Other studies have consistently yielded equivalent results. For example, one researcher, comparing the results of well-known studies of children from the general population with her own administration of the same standard tests to children conceived by lesbians through donor insemination or adopted and raised by lesbian mothers, found no difference in behavioral problems or social competence between the two groups. Likewise, the children raised from birth in a lesbian household demonstrated the same levels of aggression, sociability, and desire to be the center of attention, as measured using a standard test for evaluating self-concept, as did the children raised by heterosexual mothers. And although the children of lesbians reported somewhat greater stress than their counterparts raised by heterosexual mothers, they also reported greater feelings of contentedness, comfort with themselves, and joy.

Another study, comparing children raised from birth by a lesbian couple with matched children raised by married heterosexual parents, found no differences in behavioral functioning, cognitive abilities, developmental progress, social skills, or school performance. And a study comparing children raised from birth by a lesbian mother with children raised by a single heterosexual mother found no differences in the children?s psychological well-being or behavior.

Thus, three very recent reviews of the research to date have concluded from the evidence that children raised by lesbians are as healthy psychologically as children raised by a heterosexual parent or parents. One, for example, explained: ?No differences between children of lesbian and single heterosexual mothers have been identified for emotional well-being, quality of friendships, or self-esteem.? Another summarized:

These children [raised by lesbian mothers or lesbian couples] have play and activity preferences that are similar to children raised in heterosexual households, and do not show heightened anxiety, depression, or behavior problems.

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B. Social Adjustment

All the scientific research to date indicates that children raised by lesbian parents have the same types of social relationships and the same degree of ease or difficulty with such relationships as children or adults raised by heterosexual parents. With regard to relationships with other children, research indicates that prior to the onset of puberty, most children, regardless of the sexual orientation of their parents, have best friends of the same sex, and that children of lesbians do not otherwise differ appreciably from children of heterosexuals in choice of friends. Other studies also show no significant differences between children raised by lesbian and heterosexual mothers with respect to maternal ratings of the children's leadership qualities and popularity, the children's self-ratings of popularity, and overall social adjustment.

Studies also indicate that children raised in lesbian households are not deprived of male role models. Indeed, in one study of children of divorced couples being raised by their mothers, those living with lesbian mothers actually visited with their fathers more often than those living with heterosexual mothers. Among the children in another study, more than 90% of those living with their divorced lesbian mothers had contact with their fathers. And in a third study, lesbian mothers as a group demonstrated more concern that their children have positive relationships with men than did heterosexual mothers as a group. This study reported that the children of lesbians, in particular children being raised by their mother and her same-sex partner, had more men in their lives as family friends than did children being raised by divorced heterosexual mothers. And although the rate of contact with their fathers was the same for both groups in that study, the children being raised by lesbians were more likely to include male relatives in their activities.

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C. Sexual Identity

Concern about lesbians and gays raising children has sometimes focused on whether the sexual orientation of the parents affects the development of their children's sexual identity. Research into three separate aspects of sexual identity -- gender identity, gender role, and sexual orientation -- does not evidence any differences between children of lesbian or gay parents and children of heterosexual parents.

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1. Gender identity and gender role behavior

Gender identity concerns a person's self-identification as male or female. Studies using a variety of methods to test and compare the gender identity of children raised by a lesbian mother with the gender identity of children raised by a heterosexual mother have found no significant difference between the two groups. Most children in both groups identify with their actual biological sex, and most also indicate satisfaction with their gender.

Likewise, research indicates that children's gender role behavior, or tendency to engage in activities commonly regarded by society as ?masculine? or "feminine", is also not particularly influenced by the sexual orientation of their parents. Comparisons of children raised by lesbian mothers and those raised by heterosexual mothers did not reveal any appreciable differences in gender role behavior. Most girls living with lesbian mothers demonstrated "feminine" behavior and most boys living with lesbian mothers demonstrated "masculine" behavior.

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2. Sexual orientation

Research in this area also indicates that there is no basis in fact for any preconception that children raised by gay or lesbian parents will be more likely themselves to be homosexual than children raised by heterosexuals. One study, for example, comparing children raised by heterosexual mothers and children raised by lesbian mothers found that children of lesbian mothers "are no more likely than their peers from heterosexual mother families to identify themselves as gay or lesbian or to be attracted to someone of the same gender." It found that the adult sons and daughters of lesbian and heterosexual mothers did not differ appreciably with respect to sexual identity, and that the percentage of sons or daughters of lesbian mothers that identified themselves as gay or lesbian also appeared consistent with general population norms. Another study of adult daughters of lesbian and heterosexual mothers showed "no significant difference in the percentage of lesbian children between the two groups."

Other studies of children raised by a lesbian parent or couple have likewise found that these children's expressed sexual orientation does not differ appreciably from that of children raised by a heterosexual parent or parents. A study of sons of gay fathers found that more than 90% of those whose sexual orientation could be rated were heterosexual. Interestingly, the sons' sexual orientations were unrelated to the amount of time they spent living with their fathers.

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II. LESBIANS AND GAY MEN ARE AS FIT PARENTS AS HETEROSEXUALS.

Scientific research provides no empirical basis for any negative presumption about the fitness of lesbians or gay men as parents. To the contrary, studies of parenting have consistently concluded that the parenting skills of lesbians and of female heterosexuals are comparable. Fewer studies have concentrated on the parenting skills of gay men, but research to date offers no reason to believe that gay men are unfit parents. Thus, scientific research provides no support for the belief that lesbians or gay men lack the parenting instincts and ability of heterosexuals.

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A. Homosexuality Is Not A Mental Disorder.

Professional psychiatric and psychological associations have long rejected the view that homosexuality is a mental disorder, based on extensive empirical research demonstrating that earlier assumptions about homosexuality cannot be justified by scientific observation. Nearly a quarter century ago, the American Psychiatric Association removed "homosexuality" from its list of mental disorders, declaring that "homosexuality per se implies no impairment in judgment, stability, reliability, or general social or vocational capabilities." Following a rigorous review of the scientific evidence, in 1975, amicus APA adopted the same position, urging all mental health professionals to work to dispel the stigma of mental illness long associated with homosexual orientation.

Thus, any question about the fitness of gay men and lesbians to be parents, if based on a belief that their sexual orientation indicates psychological dysfunction, is entirely unfounded. No scientific evidence supports a view that lesbians

and gay men are categorically incapable of being good parents or even less likely to be good parents. Like heterosexuals, lesbians and gay men are highly diverse, having many different backgrounds, interests, occupations, and experiences. In fact, research indicates that with respect to the nonsexual aspects of their lives, lesbians and gay men in general are indistinguishable from the heterosexual population.

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B. Parenting Skills

Research specifically concentrating on the parenting abilities of lesbians demonstrates a "remarkable absence of distinguishing features between the life-styles, child-rearing practices, and general demographic data" of lesbian mothers and heterosexual mothers. Results of one study indicate that lesbian mothers and heterosexual mothers are similar in maternal interest, current lifestyles, and child-rearing practices. Another study showed that lesbian mothers, as a group, demonstrated greater concern with their children?s long-range development than the heterosexual mothers did. A third study found that lesbian parents scored better than heterosexual parents on the Parent Awareness Skills Survey (PASS), a standard tool for measuring the effectiveness and sensitivity with which a parent responds to typical child care situations. Lesbian and heterosexual biological mothers scored comparably. However, lesbian second parents scored considerably better than did fathers.

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Scientific research has consistently found that the sexual orientation of parents is not a predictive factor as to the parenting ability of those parents or as to the psychological and social development of their children. There is no basis, therefore, for a presumption that lesbian or gay parents are unfit, or less fit than heterosexual parents, or that awarding a lesbian or gay parent custody will have a deleterious effect on the child. Two decades of scientific investigation have, in fact, provided considerable evidence for the opposite conclusion: that children raised by a lesbian or gay parent are as healthy psychologically and socially as children raised by heterosexual parents, and that lesbian mothers are as good parents as heterosexual mothers. Therefore, unless a specific parent's sexual orientation can be shown to have an actual harmful effect on the child, it should not affect the outcome of a custody determination.

Respectfully Submitted,