Same-Sex Marriage and the “No” Campaign » LOUISE R ICHARDSON-SELF In September 2017, a non-compulsory postal (above) Skies over Sydney on 17 September 2017, during the postal survey period. IMAGE: GILLIAN COSGROVE (below) Fig. 1. Australian Marriage Law Postal Survey IMAGE: GILLIAN VANN, ID 719706406, SHUTTERSTOCK.COM survey seeking Australians’ opinion on marriage equality was launched — a compromise after the Government’s plan to hold a compulsory plebiscite on the issue was voted down by the Senate. There was only one question: Should the law be changed to allow same-sex couples to marry? (fig. 1). Same-sex marriage was first explicitly prohibited under Australian law with the Howard Government’s amendments to the Marriage Act 1961 (cth) in 2004, and campaigners have been working tirelessly to bolster public support for reform ever since. Back then, reports held that as few as 38% of Australians supported same-sex marriage; by 2007, the number had risen to 57%.1 By 2016, the number rose again 32 Humanities Australia to 62%.2 Overall, 79.5% of the population voluntarily voted in the postal survey, and 61.6% of respondents voted “Yes”. It is clear that public opinion on the legitimacy of same-sex relationships and marriage equality has shifted dramatically over the last thirteen years. This is no small feat. Bringing about genuine shifts in public opinion requires more than intellectual adoption of a particular point of view. To be lasting, it also requires emotional and affective shifts. In short, how we feel about an issue needs to change, not only what we think about an issue. I call this broader task an exercise in effecting changes within the ‘dominant social imaginary.’ This trend has been the focus of my research over the past eight years. My book — Justifying SameSex Marriage: A Philosophical Investigation — analyses and critiques a variety of justifications offered in support of same-sex marriage (fig. 2).3 In many ways, changes within Australia’s dominant social imaginary toward acceptance of same-sex marriage has been a conservative shift. Marriage equality advocates have long-traded on the “sameness” of different-sex and samesex relationships in familial, intimate relations. Longevity, commitment, monogamy, and above all “love” have been the central themes in representations of same-sex relationships. Whilst conservative and largely apolitical in its message, the tactic has a high degree of resonance for the heterosexual community, who often value deeply the ‘normative ideal of marriage.’ 4 However, what this postal survey revealed is that while same-sex relationship recognition has become normalised within the dominant social imaginary, endorsement of same-sex marriage is still precarious.5 What is interesting about the resounding success of grass-roots activism to shape and shift dominant public perceptions of samesex relationships, and increasingly same-sex marriage, is the effect this has had on the subsequent strategy undertaken by antiequality campaigners. In this context the survey presented me with an opportunity to analyse the arguments against same-sex marriage as they crystallised in the “No” campaign. For example, the Coalition for Marriage,6 perhaps the most visible body behind the “No” campaign, adopted three argumentative strategies: the first, an argument regarding changes to sexeducation and parents’ rights; the second, a free speech argument; and the third, an argument concerning freedom of religion.7 Some antiequality activists do still make arguments particular to marriage itself — for instance, they argue that marriage is about recognising a union which is procreative8 — but these arguments are no longer the predominant arguments in the debate. Activists also rarely tend to argue for the “wrongness” of homosexuality itself. Recently, “No” campaigners actively distanced themselves from comments made by David van Gend, a spokesman for the Coalition for Marriage and president of the associated Australian Marriage Forum, after he aired his view that homosexuality is a ‘disordered form of behaviour.’ 9 That the “No” campaign hardly focused its arguments on the union of marriage, and instead focused on the (alleged) direct causal consequences of legal change, marks a new trajectory in anti-queer advocacy. Whilst the slippery-slope tactic has been a staple of fear-mongering for some time, what sets these arguments apart is that the feared-for consequences do not relate to marriage itself.10 This article provides an analysis of this new tactic. I will illustrate the ways in which the “No” campaign tapped into six factors for change in an attempt to hinder social equality and reverse shifts in the dominant social imaginary. To some extent these tactics were successful, as reflected (left) Fig. 2. Cover of Louise RichardsonSelf, Justifying Same-Sex Marriage: A Philosophical Investigation, (London & New York: Rowman & Littlefield International, 2015). IMAGE: WITH PERMISSION FROM ROWMAN & LITTLEFIELD INTERNATIONAL. by a dip in support for same-sex marriage during the campaign period.11 This matters because arguments such as those produced by the Coalition for Marriage nonetheless inhibit the equal regard that the queer community are owed, even if these arguments convince only a minority of people. CHANGING THE DOMINANT SOCIAL IMAGINARY As noted above, bringing about genuine shifts in public opinion requires more than intellectual adoption of a particular point of view. To be lasting, it also requires emotional and affective shifts. That is, one must effect changes within the dominant social imaginary. In previous research, I identified ‘five factors for change;’ 12 I now believe that there are six. First, encounters with resistant imaginaries — i.e. with alternative ways of understanding the worlds that we inhabit and the possibilities for collectives of people within it — is required to generate ‘epistemic friction.’ 13 This is the factor of contradiction. Second, there must be desire for change. Mere contradiction is not enough to spark cultural revolution, since humans are often surprisingly tolerant of inconsistencies Humanities Australia 33 in belief sets and worldviews.14 The third factor is time. As I have pointed out elsewhere, no change is immediate, it is always gradual. But we should also consider the likelihood of change in relation to our “moment in time” — i.e. our historical context, as well as our imagined believed, we are hurtling toward a society of ‘gender-bending’ fluidity and confusion, as well as sexual experimentation, thanks to the ‘secrecy’ of such programs, which increasingly operate without recourse to parents’ wishes and without their consent. BRINGING ABOU T GENUINE SHIF TS IN PUBLIC OPINION REQUIRES MORE THAN INTELLECT UAL ADOP TION OF A PARTICUL AR POINT OF VIEW. TO BE L A STING IT AL SO REQUIRES E MOTIONAL AND AFFECTIVE SHIF TS. future. The extent to which we can expect new meanings to percolate into the dominant social imaginary also depends on some resonance between new meanings and the old, since new meaning-generating stories and normative practices must latch onto something that is already endorsed in order to make it sensible. Thus, resonance is the fourth factor. Fifth, there must be an element of critique, for without critique, there would be no challenge to the dominant social imaginary. To this, we can add “power” as the sixth factor. Some actors are more capable of bringing about shifts in the dominant social imaginary because they are perceived as being particularly credible, and hence have more social identity power than others.15 With this, we can analyse the strategy of the Coalition for Marriage in their campaign against marriage equality. ‘SAYING “YES” TO SAME-SEX MARRIAGE MEANS SAYING “NO” TO PARENTS’ RIGHTS’ The first key argument that the Coalition for Marriage put forward during the “No” campaign is that marriage equality consequently means that ‘radical’ sex education and gender theory will be taught in schools, and that parents will lose their right to decide what their children will be taught. In a series of television advertisements and pamphlets, and throughout their official website, the Coalition for Marriage targeted the Safe Schools and related programs, warning of a slippery slope to a society where none of the usual ‘safeguards’ for children apply, and where parents are rendered powerless by the Government and judiciary to stop the queer ‘agenda.’ If the Coalition for Marriage is to be 34 Humanities Australia Key to making these arguments stick, has been making “concerned parents,” and in particular, concerned mothers, the face of the argument. This has been achieved primarily through airing televised advertisements. In one advertisement, a mother states, ‘School told my son he could wear a dress next year if he felt like it,’ 16 while another claims, ‘Kids in Year Seven are being asked to role play being in a same-sex relationship.’ 17 Interspersed by blocks of text, the audience is told that ‘In countries with gay marriage, parents have lost their rights to choose’ and that ‘We have a choice. You can say no.’ 18 In a second advertisement, the same women assert that ‘School programs have no place teaching my son radical gender ideas; that he might not be who he was born as,’ and ask, ‘How am I supposed to protect my kids in the future from this stuff?’ 19 The on-screen text then urges viewers to ‘Say no to these radical sex and gender programs.’ 20 Whilst these advertisements contained questionable claims (for instance, schools denied claims that male students were told that they could choose to wear a dress, or that same-sex relationship “role play” was occurring), I find it instructive to analyse how these advertisements function when they are taken to be factual, for it is the interplay between (presumed) fact and affect that interests me here. The purpose of these advertisements is to imply that support for same-sex marriage is incompatible with retaining parental rights. They also aim to show that marriage equality undermines the binary certainty of sex and gender. This is the factor of contradiction at work: if marriage equality is permitted, then the natural gender order will be undermined and parents will be powerless to stop it. The implicit critique draws on a latent transphobia, trading on the affective responses of fear, anxiety, outrage, and (likely) disgust, to elicit a risk-aversive response to the issue of marriage equality — that is, to make uncertain voters desire the comfort and certainty of retaining the legal status quo. These advertisements are thus able to resonate with members of the Australian public by presenting the issue of marriage equality as inextricably linked to sex education and parents’ rights, issues with which many folk are keenly concerned, triggering ‘people’s natural sense of caution and suspicion.’ 21 The power of these advertisements to elicit a change of opinion seems to stem directly from the choice to place young mothers at the centre of the argument. Women are rarely seen to have much cultural authority except in their role as mothers. Simultaneously, the Coalition for Marriage are trying to push back against the assumption that all “No” voters are ‘angry and narrow-minded bigots’ 22 — a mantle usually placed upon men. The effect is that the concerns raised here appear to be legitimate, although they are in fact predicated on transphobia (i.e. fear, anxiety, or even disgust toward the separating of “gender” from “sex”) and a tenuous causal connection between marriage equality and stable gender identity. When it was presented prominently within a narrow time frame, the subsequent dip in support for marriage equality indicates the strength of this tactic, and illustrates that the perception of same-sex marriage as legitimate within the dominant Australian social imaginary is precarious at best. ‘SAYING “YES” TO SAME-SEX MARRIAGE MEANS SAYING “NO” TO FREEDOM OF SPEECH’ The second key argument that the Coalition for Marriage put forward during the “No” campaign is that marriage equality consequently means less protection for free speech. This argument comes hot on the heels of a Parliamentary Inquiry into Freedom of Speech in Australia and heated debate as to whether the restrictions in the Racial Discrimination Act 1975 (cth) on speech which offends, insults, humiliates or intimidates a person on the basis of their race should be valued above people’s ‘right to be a bigot.’ 23 On the local level, the Tasmanian Government has proposed changes to the AntiDiscrimination Act 1998 (Tas), which would see religious groups exempt from s17(1). This section provides that a person must not engage in any conduct which offends, humiliates, intimidates, insults or ridicules another person on the basis of certain attributes, including sexual orientation. The move for reform was instigated following a complaint by transgender rights activist Martine Delaney to the Anti-Discrimination Commission over the distribution of a pastoral letter titled Don’t Mess with Marriage (though this complaint was eventually withdrawn after conciliation failed). This case and testimony from others who feel they are being forced to support same-sex marriage by their employers have prompted the assertion that the most far-reaching threat of marriage equality ‘is to the freedom of individuals to voice their opinion in this debate, and to associate with others who do the same.’ 24 Once again, slippery-slope reasoning is employed to instil an affective response and shift people’s position on same-sex marriage. Both fear and indignation play a role here. As Damian Wyld — CEO of the Marriage Alliance, whose handbook was listed as a resource on the Coalition for Marriage website — points out, Australians only have an implied right to free political speech, and he warned: While the debate about the redefinition of marriage is occurring in Australia, the ability of a person to voice an opinion on the push to change the Marriage Act 1961 should fall within “political communication” and thus be protected by law. But it is arguable that this protection would disappear if the law was changed because the debate — and thus the “political communication” — would cease.25 Thus, the Coalition for Marriage argued, ‘If gender is removed from the marriage law, it will weaponise federal and state antidiscrimination laws.’ 26 They warned that this has already happened overseas, arguing that ‘People have been kicked out of university courses, fired, denied business or employment, or forced to resign for saying what they really think.’ 27 Ultimately, “Yes” campaigners were positioned as ‘bullies’ who ‘intimidate people Humanities Australia 35 into silence,’ who want to override the rights of “No” campaigners to express their right to free speech, while demanding that those who oppose same-sex marriage should be forced to offer their business services to those who do, or participate in pride events. This is a shrewd argument to advance within Australia’s current political climate. Again, this argument aims to elicit a desire to maintain the status quo on marriage, but in an interesting way. Many Australians are dissatisfied with the scope of what constitutes racist hate speech under federal law. By highlighting the Delaney case, brought in a state with similar laws applying to homophobic speech, the “No” campaign can capitalise on current dissatisfaction with the law and standards of political correctness. Because freedom of speech debates have played such a prominent role in recent public discourse, there is a high degree of resonance, and hence higher likelihood of changing public opinion if people can see a direct link between marriage equality and freedom of speech. The campaign was able to piggy-back off the critiques which have already been levelled at the Australian Government for failing to adequately protect freedom of speech. This allowed campaigners to assert that they bear no ill-will towards the queer community, and assert that they were campaigning merely because they ‘don’t trust what a “Yes” vote will mean’ for the future.28 More strongly, they may assert that ‘If we change marriage, we change what we are free to say.’ 29 What the “No” campaign is trying to capitalise on, is the idea that a society which permits same-sex marriage cannot co-exist with a society that protects free speech (the contradiction component). Time also plays a role here, not only in the sense of duration — since appeals to some uncertain, risky future are employed as a scaretactic — but in the sense of timeliness. Ten years ago, the free speech argument against samesex marriage simply would not have as much political resonance as it does today. Finally, the role of power in this argument is also interesting: “No” campaigners position themselves as underdogs who need to fight back against the ‘elite’ — the powerful triad of parliamentarians, media conglomerates, and corporations. This allows campaigners to feel as though they are fighting for their own empowerment and against 36 Humanities Australia a Government that ignores their “rights”, whilst simultaneously having access to many cultural resources to pursue this aim. ‘SAYING “YES” TO SAME-SEX MARRIAGE MEANS SAYING “NO” TO RELIGIOUS FREEDOM’ Of all the arguments put forward by the Coalition for Marriage, the argument for religious freedom most clearly betrays a veiled fear — that parishes, schools, businesses, and individuals will be reproached if they steadfastly retain and express their belief that queers ought not to be seen as equivalent to straights. However, opposing marriage equality on grounds of religious freedom does not, to their mind, mean “No” voters are ‘bad people,’ ‘haters,’ or ‘bigots.’ 30 The issue is accordingly recast as a fight to prevent an intolerable future, one in which their rights and freedoms are trampled, which certainly cannot be permitted. Apparently, The concerns about the freedom of religion extend far beyond whether an individual minister of religion or celebrant is required to solemnise a same-sex wedding. It has to do with what faith leaders will be able to preach, what schools and parents will be able to teach, and how every day Australians will be able to conduct their businesses in accordance with their beliefs.31 The Coalition for Marriage were also concerned as to whether faith-based charities will retain their tax-exempt status, and whether religious organisations will be permitted to hire people who support their ethos, as they have done in the past. Again, in this argument, the Coalition for Marriage tries to present religious observers as the threatened underdogs. They suggest that the Government ‘has not made it clear what protections for freedom of religion, if any, will be included in any legislation to change the Marriage Act,’ 32 whilst warning that any protections that are received may prove to be ultimately futile. They point to Opposition Leader Bill Shorten’s commitment to ‘repealing protections for religious freedom if they were contained in legislation to change the Marriage MARRIAGE EQUALITY: (far left) BECOMING ‘NORMAL’ Act’ 33 as evidence to support The Australian Editor-at-Large Paul Kelly’s comment that ‘there would eventually be no “halfway house” permitted when it comes to acceptance of same-sex marriage.’ 34 The freedom of religion argument is presented as a zero-sum game: either we protect religious groups, or we permit same-sex marriage and ‘give a free pass to the government to make legislation without important protections.’ 35 The implicit critique is that we can have one or the other, but we cannot have both (contradiction), and we should privilege freedom of religion. The aim is to achieve resonance with “soft” religious voters who are intending to vote “Yes.” If the value of freedom of religion resonates with them, and they see this value as more desirable and simultaneously contradictory with marriage equality, they should be driven to vote “No,” instead. The intention with this argument is to capitalise on people’s conservative tendencies, assuring them that it really is okay to say “No,” all while instilling fear that they will lose certain forms of control (or power) over their own lives if “anti-discrimination” is to trump “freedom of religion”. Fig. 3. Australian and Rainbow flags The Coalition for Marriage utilised some shrewd tactics to garner support for their cause. They provided new meaning-generating stories, charged with affect, that attach to the issue of marriage equality. The affective charge was strengthened by the fact that changes to the norms of one institution (marriage) do seem — indirectly, at least — to pave the way for further normative shifts around gender, sex, and sexuality which some may not be ready for. By presenting threats to children and parents’ rights, free speech, and religious freedom as direct causal consequences of same-sex marriage, voters were led to believe that changes to the status quo would bring about an intolerable dystopian future. This elicits fear and resistance to change — and it is by playing up to these fears that the Coalition for Marriage managed some success in their campaign. The Coalition for Marriage were keenly aware that ‘people need motivation more than information to vote;’ consequently, neighbourhood campaign training material encourages ‘Brief dialogue and not a lengthy debate.’ 36 Minimising their arguments against same-sex marriage down to a few anxietyinducing sound bites, engaging ‘people’s natural sense of caution and suspicion,’ is a clever strategy to elicit their preferred response in voters.37 By appealing to contemporary political concerns in Australia, campaigners were able to tap into voters’ sense of fear, disgust, and even indignation. IMAGE: NITO, ID 756241684, SHUTTERSTOCK.COM (left) Fig. 4. Louise Richardson-Self accepts the 2016 Max Crawford Medal at the Fellows’ Dinner, Melbourne IMAGE: MICHELLE McFARLANE Humanities Australia 37 But, of course, the success of this tactic ultimately rested with how plausible the causal connections drawn by the “No” campaign were perceived to be — and we know that the majority of Australians were not convinced. This strategy also required voters to share implicit reservation about the content of sex education, ideals about unfettered speech, and that they privilege religious freedom over tolerance, which many Australians did not. Insofar as there was low resonance for many voters, the power of this critique was largely minimised, and the Coalition for Marriage only achieved a modicum of success in minimising the “Yes” vote. Nonetheless, even this modicum of success goes to show that for many Australians their support of marriage equality is not unconditional, and their belief in the equal status of LGBTI Australians is not unreserved. ¶ LOUISE RICHARDSON-SELF is an early-career researcher and lecturer in Philosophy and Gender Studies at the University of Tasmania. She was the 2016 recipient of the Max Crawford Medal (awarded jointly by the Australian Academy of the Humanities with Dr David McInnis), and in 2017, she was a Residential Fellow of the Humility and Conviction in Public Life project, hosted by the University of Connecticut’s Humanities Institute. Her book — Justifying Same-Sex Marriage: A Philosophical Investigation — was published with Rowman & Littlefield International in 2015. While she retains a strong interest in studies of sexuality, she has since turned her attention to another prominent political issue: hate speech. Her recent publications in Hypatia (2018) and Feminist Philosophy Quarterly (forthcoming 2018) analyse who can be a victim of hate speech, how hate speech against women takes a distinctive shape, and how analysis of dominant and resistant social imaginings in Australia can highlight or obscure the harms of hate speech. 38 Humanities Australia 1. Misha Schubert, ‘Public backs gay unions, equality’, The Age, 21 June 2007 <http://www. theage.com.au/news/national/public-backs-gayunions-equality/2007/06/20/1182019204491. html> [Accessed 30 October 2017]. 2. SBS Wires, ‘Same-Sex Marriage Support Drops: Poll’, SBS, 25 September 2017 <http://www. sbs.com.au/news/article/2017/09/25/samesex-marriage-support-drops-poll> [Accessed 4 November 2017]. 3. Louise Richardson-Self, Justifying Same-Sex Marriage: A Philosophical Investigation, (London & New York: Rowman & Littlefield International, 2015), pp. 128–34. 4. Cheshire Calhoun, Feminism, the Family, and the Politics of the Closet: Lesbian and Gay Displacement (Oxford: Oxford University Press, 2000), p. 130. 5. Richardson-Self, Justifying Same-Sex Marriage, p. 13. 6. The Coalition for Marriage describes itself as ‘a grassroots movement of individuals and organisations supporting a common cause: the preservation of the definition of marriage and through it, the protection of the individual rights and freedoms of all Australians’, and as ‘a voice for the silent majority.’ Damian Wyld, ‘Consequences: Changing the Law on Marriage Affects Everyone’, Coalition for Marriage & Marriage Alliance, 2017, p. 73 <https://d3n8a8pro7vhmx.cloudfront.net/ coalitionformarriage/pages/361/attachments/ original/1505297007/Handbook.pdf> [Accessed 30 October 2017]. 7. Lyle Shelton, ‘3 Ways Gay Marriage Will Impact Your Family’, Coalition for Marriage, 2017 <https://d3n8a8pro7vhmx.cloudfront.net/ coalitionformarriage/pages/405/attachments/ original/1505533020/> [Accessed 31 October 2017]. 8. John Ozolins, ‘Why the Argument for SameSex Marriage is Not Sound’, ABC Religion and Ethics, 4 September 2017 <http://www.abc. net.au/religion/articles/2017/09/04/4728711. htm> [Accessed 27 October 2017]; Wyld, ‘Consequences’, 8–11. 9. Michael Koziol, ‘Leading “no” campaign spokesman says homosexuality “a disordered form of behaviour”’, The Sydney Morning Herald, 26 October 2017 <http://www.smh.com.au/ federal-politics/political-news/leading-nocampaign-spokesman-says-homosexuality-adisordered-form-of-behaviour-20171026-gz8oxs. html> [Accessed 30 October 2017]. 10. Comparatively, consider the arguments put forward in Bill Muehlenberg, ‘No’, Why vs Why: Gay Marriage (Seaforth, N.S.W.: Pantera Press, 2010), pp. 1–48 — each relates directly to marriage or the wrongness of the queer lifestyles. 11. David Crowe, ‘Newspoll: “Yes” vote losing ground’, The Australian, 25 September 2017 <http://www.theaustralian.com.au/nationalaffairs/samesex-yes-vote-losing-ground-innewspoll/news-story/1d21b1dbe415c8a678f39a311 f9d6d9c> [Accessed 30 October 2017]. 12. Richardson-Self, Justifying Same-Sex Marriage, pp. 130–33. 13. José Medina, ‘The Relevance of Credibility Excess in a Proportional View of Epistemic Injustice: Differential Epistemic Authority and the Social Imaginary’, Social Epistemology, 25 (2011), 15–35 (pp. 28–32). 14. Moira Gatens, ‘Paradoxes of Liberal Politics: Contracts, Rights, and Consent,’ in Illusion of Consent: Engaging with Carole Pateman, ed. by D. O’Neill, M. Shanley and I. Young (University Park: The Pennsylvania State University Press, 2008), pp. 31–48 (p. 43). 15. Miranda Fricker, Epistemic Injustice: Power and the Ethics of Knowing (Oxford: Oxford University Press, 2007), pp. 14–17. 16. S. York, ‘You Can Say No’, YouTube, 28 September 2017 <https://www.youtube. com/watch?v=RrCOMTpQGw4> [Accessed 1 November 2017]. coalitionformarriage/pages/361/attachments/ original/1505535929/C4M_Field_-_NVC_ Training_Script.pdf?1505535929> [Accessed 31 October 2017]. 22. Shelton, ‘Neighbourhood Visitation Campaign,’ p. 5. 23. George Brandis, in Emma Griffiths, ‘George Brandis defends “right to be a bigot” amid Government plan to amend Racial Discrimination Act’, ABC News, 24 March 2014 <http://www.abc.net.au/news/2014-03-24/ brandis-defends-right-to-be-a-bigot/5341552> [Accessed 2 November 2017]. 24. Wyld, ‘Consequences’, p. 31. 25. Wyld, ‘Consequences’, p. 26. 26. Shelton, ‘Marriage Will Impact Your Family’, emphasis added. 27. Lyle Shelton, ‘Frequently Asked Questions,’ Coalition for Marriage, 2017, p. 2 <https:// d3n8a8pro7vhmx.cloudfront.net/ coalitionformarriage/pages/361/attachments/ original/1505535836/C4M_Field_-_NVC_ Training_FAQs.pdf?1505535836> [Accessed 31 October 2017]. 28. Shelton, ‘Neighbourhood Visitation Campaign’, p. 4. 29. Shelton, ‘Frequently Asked Questions’, p. 1. 30. Wyld, ‘Consequences’, p. 5. 17. York, ‘You Can Say No’. 31. Lyle Shelton, ‘Freedom of Religion’, Coalition for Marriage, 2017 <https://www. coalitionformarriage.com.au/freedom_of_ religion> [Accessed 31 October 2017]. 18. York, ‘You Can Say No’. 32. Shelton, ‘Frequently Asked Questions’, p. 3. 19. Lyle Shelton, ‘Our Ad — The Gender Fairy’, Coalition for Marriage, 2017 <https://www. coalitionformarriage.com.au/our_ad_gender_ fairy> [Accessed 31 October 2017]. 33. Shelton, ‘Freedom of Religion’. 34. Wyld, ‘Consequences’, p. 23. 35. Shelton, ‘Frequently Asked Questions’, p. 3. 20. Shelton, ‘The Gender Fairy’. 36. Shelton, ‘Neighbourhood Visitation Campaign’, p. 3, original emphasis. 21. Lyle Shelton, ‘Neighbourhood Visitation Campaign,’ Coalition for Marriage, 2017, p. 3 <https://d3n8a8pro7vhmx.cloudfront.net/ 37. Shelton, ‘Neighbourhood Visitation Campaign,’ p. 3. Humanities Australia 39