by Jennifer Wright-Berryman, PhD
Introduction
Stories of employment, school, and healthcare discrimination against LGBTQIA+ (Lesbian, Gay, Bisexual, Transgender, Queer, Intersex, Asexual, plus) people are often highlighted in the media, establishing a precedent that not all providers will offer safe spaces or equitable access to goods and services (McCabe & Kinney, 2018; Singer, 2019). This may result in sexual and gender minorities avoiding some businesses and providers (Clark et al., 2022). Cases of sexual and gender minority discrimination among funeral providers have also made national news. Aimee Stephens, a transgender woman, was fired from her position at a Detroit funeral home when the directors learned of her plan to transition, resulting in the landmark Supreme Court decision in R.G. and G.R. Harris Funeral Homes v. EEOC (Young, 2020). In Zawadski v. Brewer Funeral Services, a Mississippi funeral home reportedly refused to pick up the deceased husband of a man once they learned he was gay (Grinberg, 2017; Lambda Legal, 2020).
A potential remedy is consumer protections for LGBTQIA+ people. Public accommodations law (PAL), designed to provide equal access to goods and services without discrimination based on race, religion, sex, or nationality, is embedded in Title II of the Civil Rights Act (Penrose, 2022). To date, twenty-one states and the District of Columbia have expanded PALs to include sexual orientation and/or gender identity. Additionally, five states are accepting complaints of discrimination based on sexual orientation and/or gender identity, and one state has prohibited discrimination based on sexual orientation only (Human Rights Commission, 2022). Currently, the U.S. House of Representatives has passed The Equality Act, which would provide anti-discrimination protection for public services, but it has yet to pass the Senate (Johnson, 2022). Without a federal policy in place, this leaves over half the country without explicit LGBTQIA+ consumer protections.
Unfortunately, PALs may not provide absolute protection, even those that include sexual orientation and gender identity groups. Several legal disputes over the last decade demonstrate how religious freedom laws may be deployed to deny goods and services to LGBTQIA+ people (Penrose, 2022; Singer, 2019). Services such as weddings and funerals may be considered “religious ceremonies” and could be refused to sexual and gender minorities if the provider claims conflict with their sincerely held religious beliefs. What, then, can LGBTQIA+ people do to protect themselves against possible discrimination in the deathcare industry?
Advanced death care planning (funerals, celebrations of life, and body disposition) may be the answer, however, LGBTQIA+ adults and older adults may not understand their rights, barriers, and options to access equitable services (Beringer, Gutman, & de Vries, 2021). A recent evaluation of website content of randomly selected funeral homes across the U.S. identified a lack of LGBTQIA+ inclusive language, graphics, images, or web-based forms (author cite, 2022). Therefore, accessing affirming funeral care services via the internet in the U.S. could be a challenge for sexual and gender minorities. Nearly 90% of funeral homes in the U.S. are private, family-owned establishments (National Association of Funeral Directors, NAFD, 2022). As such, individual funeral businesses may provide services aligned with their family and religious values, regional culture, and local market share. With PALs varying across states, safety from discrimination for LGBTQIA+ funeral service patrons is uncertain.
It is critical that LGBTQIA+ people understand the policies that support and present barriers to death care planning. This paper will describe protections for LGBTQIA+ people planning their death care services and will also highlight the gaps where policy falls short. Additionally, options and guidance for advanced planning to mitigate the risk of discrimination will be presented. This information can be used by end-of-life professionals, as well as consumers, to support sexual and gender minorities in this important decision-making.
Equality in Marriage and Death
In June 2015, the Supreme Court decided Obergefell v. Hodges (Yoshino, 2015), which provided same-sex couples federal marriage equality. The issue of same-sex spousal rights at death was included as part of the Obergefell case, when Robert Grunn, an Ohio funeral director and LGBTQIA+ advocate, joined the plaintiff’s case (Branch, 2015). Obergefell and his longtime partner, John Arthur, went to Maryland to marry when John’s Lou Gehrig’s disease became life-threatening as same-sex marriage was not legal in Ohio. Upon their return, Mr. Grunn worked with Obergefell to obtain a court injunction on John’s death certificate to have his name listed as surviving spouse. The injunction was granted, and when John Arthur died shortly thereafter, Obergefell’s name was recorded by Mr. Grunn on John Arthur’s death certificate. Mr. Grunn continued to do this for other same-sex couples, and eventually, these cases, along with others, were included in Obergefell v. Hodges (Porterfield, 2017).
However, marriage equality has not preempted discrimination based on sexual orientation in death care. In the 2017 case Zawadski v. Brewer Funeral Services, a Mississippi man was told by the local nursing home caring for his husband that the funeral director, learning that the deceased’s spouse was a man, stated they “don’t serve their kind” and would not come to pick up the body. The funeral home was seemingly happy to serve the family when the nephew initially called to make the arrangements. It was not until the funeral home discovered the deceased was a man married to a man that they refused to serve them. This left the family quickly calling around to several funeral homes in the area. They finally found one to take Mr. Zawadski’s husband, although it was over an hour away (Grinberg, 2017).
Public Accommodations Laws and Religious Freedom
Title II of the Civil Rights Act of 1964 states: “All persons shall be entitled to the full and equal enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of any place of public accommodation . . . without discrimination on the ground of race, color, religion, or national origin” (National Archives, 2022). PALs were created so consumers do not have to think about their skin color, belief system, or home country when patronizing a public establishment. Anti-discrimination is not the reality, however, perhaps especially for sexual and gender minorities.
In Masterpiece Cake Shop, Ltd. v. Colorado Civil Rights Commission, the Supreme Court ruled that Jack Phillips, the cakeshop owner who refused to make a cake for a same-sex couple about to be married, should not be made to do so against his “sincerely held religious beliefs” (Lavelle, 2019). Lower courts had ruled in favor of the plaintiff in Craig v. Masterpiece Cake Shop, Ltd., requiring Phillips to cease discrimination based on sexual orientation, as Colorado’s PAL included sexual orientation and gender identity. However, Phillips, represented by Alliance Defending Freedom, a religious legal defense organization, was granted Certiorari by the Supreme Court which resulted in a reversal of the lower courts’ rulings (Stephens, 2020). Since Masterpiece, several cases at all levels of the court have been heard related to public accommodations, sexual orientation discrimination, and religious freedom (Penrose, 2022).
After Obergefell, several states enacted religious freedom policies that seemed to countermand the liberties offered through marriage equality. Proponents of religious freedom state legislation claimed a need for these policies as the country was becoming more secular. During the 2015-2016 legislative cycle, thirty-six state legislatures introduced over 100 bills addressing religious liberties (Dhooge, 2017). Indiana’s Religious Freedom Restoration Act, signed into law by then Governor Mike Pence, drew fire from local and national businesses, musicians, and sports organizations as it created space for LGBTQIA+ discrimination (Dhooge, 2017; Singer, 2019). Pence publicly denied this claim, stating he would have vetoed any bill he felt was discriminatory. Similar policies in Arkansas, Texas, and North Carolina have prevented same-sex couples from accessing benefits and services. In Arkansas, a lesbian couple was denied having both of their names put on their child’s birth certificate. In Texas, same-sex couples were being denied employment spousal benefits. In Mississippi, religious protections were implemented to allow businesses and government officials to deny services if a person believes: 1) marriage is between one man and one woman, 2) sexual relations should be between heterosexual couples only, and 3) sex of a person is assigned at birth (Brown & Scott, 2019).
Discrimination against same-sex couples was not the only lingering problem post-Obergefell. In North Carolina, a “bathroom bill” was passed whereby a person was only allowed to use the bathroom matching the gender on their birth certificate. Other states followed suit, however, the outcry and litigation from the LGBTQIA+ community motivated the North Carolina law to be amended (Riano & Eskridge, 2020).
Even in states where PALs include sexual orientation and gender identity, such as Colorado and Arizona, providers may use the claim that their religious values collide with offering equitable services to LGBTQIA+ people, such as in Masterpiece. In Phoenix, wedding calligraphers filed a suit stating they should not have to make wedding invitations for same-sex couples and wanted to state this publicly on their business materials. Anticipating problems from the City of Phoenix because of the local anti-discrimination laws, they asked for an injunction on enforcement of the law. Phoenix courts denied their request (Brown & Scott, 2019).
Courts have decided these cases in different ways, creating confusion about antidiscrimination laws in the context of religious freedoms. Interestingly, religious freedom laws may not represent the real-time views of the populace related to LGBTQIA+ rights. In a 2019 Pew Research Center survey of marriage equality support among the religious, two-thirds of mainline Protestants and Catholics support same-sex marriage, however, only a third of evangelical Protestants support marriage equality (Pew Research Center, 2019). This suggests that the type of religious affiliation may have some bearing on who may claim religious conflict when providing goods and services to LGBTQIA+ people.
The Equality Act
By 2021, LGBTQIA+ citizens had equal rights to marry and a new federal law to ensure employment anti-discrimination. Bostock v. Clayton County, which included the R.G. and G.R. Harris Funeral Homes v. EEOC case, was a watershed U.S. Supreme Court decision providing employment anti-discrimination protection for sexual and gender minorities (Manuel, 2021). The next step will be a federal public accommodations law, also known as The Equality Act (TEA). TEA would extend Title II of the Civil Rights Act by including sexual orientation and gender identity as protected groups (Pizer, 2022). The current language of TEA was proposed in 2015, passed through the House in 2019 and 2021, and the Senate Judiciary Committee heard testimony in March of 2021. However, TEA still awaits Senate Committee vote and floor action (Pizer, 2021).
Passing TEA will have a sweeping impact on public accommodations security for LGBTQIA+ people and will send a message that equal rights are truly for all. Without them, sexual and gender minorities may continue to experience disparities in healthcare (Gonzales & Gavulic, 2020) and may have concerns using public services without explicit inclusive messaging (author cite, 2022). Additionally, the TEA may mitigate barriers set forth by religious freedom laws as these claims are often not weighed favorably against federal civil liberties (Pizer, 2022).
Even with TEA, discrimination can still occur. Although refusing services based on sexual orientation and gender identity may become illegal, LGBTQIA+ people may continue to be treated poorly by those who do not honor non-normative ways of living and loving.
Death Care Services and LGBTQIA+
Like marriage, funerals may be considered a religious ceremony. Given the conflicts between public accommodation and religious freedom laws, sexual and gender minorities may be cautious in accessing death care services. Most funeral homes are privately owned, and their websites do not contain clues about whether sexual and gender minorities are welcome (author cite, 2022). It could be argued that funeral home websites do not contain exclusive language, however, a lack of exclusive language is not equivalent to inclusivity. For example, Phillips’ bakery, Masterpiece, did not explicitly advertise their services were for heterosexual couples only, yet, a same-sex couple was denied a wedding cake. What can be gleaned, therefore, is that laws designed to protect do not always operate that way.
It might be helpful, then, to take a closer look at the values embedded in the funeral industry. Nearly 90% of the 18,000 funeral homes in the United States are family-owned and operated, and most are members of the National Association of Funeral Directors (NFDA, 2022). Other funeral homes are owned by corporations, such as Service Corporation International (SCI). Both the NFDA and SCI have diversity statements and/or ethical professional guidelines including anti-discrimination tenets regarding sexual orientation and gender identity. The NFDA Code of Professional Conduct, in Section I, Part 1, “Service to Families” states “Members shall provide funeral services to families without regard to religion, race, color, national origin, sex, sexual orientation or disability” (NFDA, 2022). The SCI Corporate Responsibility Code of Conduct, in the section Discrimination and Harassment, states “Any type of discrimination, harassment or other unwelcome conduct whether physical or verbal, that is on the basis of race, color, national origin, religion, language, ethnicity, age, gender, sex, sexual orientation, gender identification, veteran’s status, political or other opinions, social origin, disability or any other legally protected status, is not tolerated” (SCI, 2022). Both the NFDA and SCI have internal reporting and investigation methods to ensure compliance with these standards.
These statements by the NFDA and SCI are positive measures to protect LGBTQIA+ employees and customers. It is not clear whether the NFDA or SCI have taken action against funeral homes if cases of discrimination have been reported. Cases that make national news, such as R.G. and G.R. Harris v. EEOC and Zawadski v. Brewer Funeral Services, may cause concern for sexual and gender minorities about the friendliness of death care providers. Without explicit affirming signaling or marketing to the LGBTQIA+ community, funeral homes may not be assumed safe spaces, even with these corporate pledges of anti-discrimination.
Pre-planning Death Care as a Solution
Considering the confusing landscape where policy, ethics, and human rights collide, how should an LGBTQIA+ person proceed in crafting a death care plan that aligns with their life story? First, planning should begin in advance as opposed to “at-need” (the time when death is imminent, or the person has recently died) when loved ones are left to make arrangements on behalf of the dying or deceased. Second, LGBTQIA+ people should take the time to find and interview friendly death care providers. Last, sexual and gender minorities should learn their rights and the policy barriers that support or impede their chosen death care plan.
Advanced Planning and Finding a Friendly Funeral Home or Crematory
A recent evaluation of LGBTQIA+ content from randomly selected funeral home websites across the U.S. returned discouraging results. None of the funeral homes selected displayed any LGBTQIA+ affirming language, graphics, or community collaborations (author cite, 2022). In addition, the web-based forms used by the funeral homes use dichotomous “male” and “female” gender options. Given that many LGBTQIA+ people find it safer to identify preferred service providers via the internet (Martinez & Tang, 2020), it is unlikely a sexual or gender minority person will easily find a friendly funeral home. Instead, if one uses search terms “LGBTQ” or similar, and “funeral home” they would likely find one of the court cases referenced earlier, causing alarm about the safety of funeral homes for LGBTQIA+ people. Avoiding advanced planning could result in a distressing search at an already emotional time. Especially so for sexual and gender minorities who cannot easily find a friendly funeral home via web search.
LGBTQIA+ people have grown accustomed to finding friendly service providers through allies in their community (Whittemore, 2022). Numerous resources have been designed to advance this need nationally, including LGBTQIA+ chambers of commerce and online “gayborhood” directories. These resources may not be helpful, however, for those in rural areas (Stone, 2018) or in LGBTQIA+ urban spatial service “deserts” (Rosentel, VandeVusse, & Hill, 2020). This may put LGBTQIA+ people at risk for discrimination by calling or visiting a funeral home or other death care provider and asking directly about their level of acceptance and inclusion.
Alternatives to Funeral Homes
There are many ways to create a death care plan. Typically, death care plans contain a person’s preferences for a memorial and body disposition. Funeral homes offer traditional ground burial and cremation, with some now providing “green burial” or “eco-friendly burial” as more of these types of burials are being requested by environmentally conscious consumers (Shelvock, Kinsella, & Harris, 2022; Stock & Dennis, 2021). However, today, some consumers avoid funeral homes and opt for home funerals, send-off parties, or other ways to celebrate a life (Webster, 2018). There are also emerging body disposition choices aside from in-ground burial, cremation, or medical donation, including remains composting (Alfus, 2020), aquamation (also known as water cremation or alkaline hydrolysis, Haneman, 2021), and cryonics (Pradeep & Praveen, 2020). However, these options are not legal or available in every state.
Only eleven states require the use of a funeral home to oversee a death care plan (Marsh, 2020), but funeral homes remain the majority provider of death care services in the U.S. Funeral directors have the authority to assist with several practical and legal aspects of death, including transporting the body, overseeing memorial services, preparing a body for disposition, facilitating body disposition, assisting with obituaries, and completing death certificates and other paperwork. Alternative providers, such as death doulas- persons trained to accompany someone and provide compassionate companionship and care at the end of life- may not have a funeral director’s license and are therefore limited in their ability to aid in some of the legal requirements upon death (Rawlings, Tieman, Miller‐Lewis, & Swetenham, 2019).
State Statutes and Pre-planning
Everyone has the right to pre-plan their own death care. Some assume that by completing advanced directives, a will, and a durable power of attorney, their death care plan will be ensured. However, this may not be the case. A power of attorney for health care, or a designated health care representative/proxy, can make decisions for their charge at the end of life, but generally not after death. Instead, if there is concern about how a death care plan will be managed, a person will want to consider who has next-of-kin rights for the disposition of their remains or should legally name a designated agent and record their death care preferences (Marsh, 2020). Designated agent and preferred preferences state statutes vary, making it critical that people understand their state laws. It should be noted that since each state governs the disposition of the remains of its citizens, a person’s death care plan can only be recognized in the state in which it was created. If a person dies in a different state, their plan may not be recognized or considered valid (Haneman, 2022; Marsh, 2020).
Designated Agent (DA) statutes allow a person to name someone to act on their behalf for death care. The language of these statutes has been influenced by funeral directors to absolve them for acting on the preferences of the deceased, when those conflict with family preferences (Marsh, 2020). Preferred Preferences statutes (PP) recognize a person’s right to declare their wishes for their body disposition. However, the language of these statutes may be scripted so that a person does not have complete autonomy. For example, twenty-three state statutes include language about “pre-need contracts”, a process designed by the funeral industry to ensure the use of a funeral service for final wishes (Marsh, 2020).
An important pre-planning goal for sexual and gender minorities considering these varying legalities is not only to create a death care plan in advance, but to also update it regularly. Using an attorney, legal service, or advocate can aid in understanding state statutes and can keep documents secure. There are also important steps one can take without an attorney by using publicly available documents and following state guidelines (some require notarization, witnessing, or a combination), keeping in mind documents may still be contested by next-of-kin (Marsh, 2020). Funeral homes are often confused by conflicting decisions by loved ones, and without designated agent or preferred preferences documents, there may be no reference to honor the decedent’s wishes.
After creating a death care plan that adheres to state statutes, with or without the assistance of legal representation, it is imperative to share the plan with loved ones. In nearly every state, next-of-kin is usually 1) spouse, 2) adult children, 3) parents, 4) next closest relative (Marsh, 2020). If an unmarried LGBTQIA+ person without adult children has poor relationships with parents and other family members, they will want to plan their death care in advance, name a designated agent, record their preferences (following the statutes), and collaborate with a provider to avoid a death care plan being made for them by people with whom there is discord.
Conclusion and Future Directions
A recent study of the end-of-life planning of Canadian older adults pre- and post- COVID-19 pandemic revealed that the rate of planning was higher among LGBTQIA+ people than heterosexual people since the pandemic began (de Vries et al., 2021). These authors speculate that the COVID-19 pandemic may have triggered fears associated with the AIDS epidemic which, in turn, motivated more sexual and gender minorities to prepare their end-of-life plans, have more conversations with loved ones about their plans, and keep their plans updated. Similar research should be done in the United States to understand the barriers and solutions to death care planning for sexual and gender minorities. Studies should include the voices of sexual and gender minorities to co-create solutions.
LGBTQIA+ people may want to consider how they want their chosen families (de Vries, 2019; Knauer, 2016), their romantic relationships, spouses, identities, and other important life events and experiences remembered when creating their death plan. Designing a plan in advance can be life-affirming and can reduce anxiety about what might happen if loved ones disagree. Recording personal preferences, naming a designated agent, completing the necessary legal paperwork, adhering to state statutes, keeping it updated (especially if one moves states), and sharing it with loved ones are essential steps to ensuring a death care plan that aligns with one’s identity and life story.
Death care providers have opportunities to support the LGBTQIA+ community in several ways. A recent AARP national survey of sexual and gender minority persons offers insights into how businesses can contribute to the health and wellbeing of older LGBTQIA+ adults (AARP, 2022). Supporting the passage of The Equality Act, listening to and understanding the needs of LGBTQIA+ people, and incorporating training about sexual and gender minorities in the workplace were among the suggestions.
LGBTQIA+ people and death care providers, as well as policy makers and advocates can collaborate to transcend policy barriers and co-create solutions. Death care providers can be more transparent with their support, and LGBTQIA+ people can offer their voices to make their death care preferences and needs known. However, until there is a cultural shift in the death care marketplace and policy support in the U.S., sexual and gender minorities should consider advanced death care planning, leaving themselves ample time to find resources and craft a plan that aligns with their preferences.
References
AARP. (2022). Dignity 2022: The experience of LGBTQ older adults. Retrieved on 10/20/2022 from https://www.aarp.org/content/dam/aarp/research/surveys_statistics/life-leisure/2022/lgbtq-community-dignity-2022-report.doi.10.26419-2Fres.00549.001.pdf
Alfus, K. M. (2020). Better Homes and Scattered Gardens: Why Iowa Should Legalize” Human Composting” as a Method of Final Disposition. Iowa L. Rev., 106, 325.
Author Cite. (in press, 2022). Are funeral homes safe spaces for sexual and gender minorities? A website content analysis. Death Studies.
Beringer, R. M., Gutman, G., & Vries, B. D. (2021). Exploring and promoting advance care planning among lesbian, gay, bisexual, transgender, and queer (LGBTQ) older adults living in non-metropolitan British Columbia. Journal of Gay & Lesbian Social Services, 33(4), 407-426.
Branch, J. L. (2015). Life after Love Wins: What the Obergefell Decision Means for Ohio. Ohio Law., 29, 8.
Brown, E., & Scott, I. (2019). Belief v. belief: resolving LGBTIQ rights conflicts in the religious workplace. American Business Law Journal, 56(1), 55-114.
Clark, K. D., Luong, S., Lunn, M. R., Flowers, E., Bahalkeh, E., Lubensky, M. E., … & Flentje, A. (2022). Healthcare mistreatment, state-level policy protections, and healthcare avoidance among gender minority people. Sexuality Research and Social Policy, 1-14.
de Vries, B., Gutman, G., Humble, Á., Gahagan, J., Chamberland, L., Aubert, P., … & Mock, S. (2019). End-of-life preparations among LGBT older Canadian adults: The missing conversations. The International Journal of Aging and Human Development, 88(4), 358-379.
de Vries, B., Gutman, G., Beringer, R., Gill, P., & Daudt, H. (2021). Advance care planning among older Canadians amid the COVID-19 pandemic: a focus on sexual orientation. Palliative Care and Social Practice, 15, 26323524211019056.
Dhooge, L. J. (2017). The Impact of State Religious Freedom Restoration Acts: An Analysis of the Interpretive Case Law. Wake Forest L. Rev., 52, 585.
Gonzales, G., & Gavulic, K. A. (2020). The equality act is needed to advance health equity for lesbian, gay, bisexual, and transgender populations. American Journal of Public Health, 110(6), 801.
Grinberg, E. (2017). Funeral home refuses to cremate gay man, lawsuit alleges. Retrieved on 10/1/2022 from https://www.cnn.com/2017/05/02/health/mississippi-funeral-home-gay-couple-lawsuit/index.html
Haneman, V. J. (2021). Alkaline Hydrolysis. ACTEC LJ, 47, 55.
Haneman, V. J. (2022). Prepaid Death. Harv. J. on Legis., 59, 329.
Human Rights Commission. (2022). State and Local Laws, Policy, and Discrimination. Retrieved on 10/4/2022 from https://www.hrc.org/resources/state-maps
Johnson, R. (2022). Discrimination because of sexual orientation and gender identity: the necessity of the equality act in the wake of Bostock v. Clayton County. Brigham Young University Law Review, 47(2), 685-710.
Knauer, N. J. (2016). LGBT older adults, chosen family, and caregiving. Journal of Law and Religion, 31(2), 150-168.
Lambda Legal. (2020). Zawadski v. Brewer Funeral Services. Retrieved on 10-14-2020 from: https://www.lambdalegal.org/sites/default/files/legal-docs/downloads/012_2017-03-07_first_amended_complaint.pdf
Lavelle, L. E. (2019). Saving Cake for Dessert: How Hearing the LGBTQ Title VII Cases First Can Inform LGBTQ Public Accommodation Cases. Geo. Mason UCRLJ, 30, 123.
Manuel, V. D. (2021). Bostock v. Clayton County: The Supreme Court’s Textualist Recognition of LGBTQ+ Employment Rights. Tulane Journal of Law & Sexuality, 30, 203.
Marsh, T. D. (2020). You Can’t Always Get What You Want: Inconsistent State Statutes Frustrate Decedent Control Over Funeral Planning. Real Property, Trust, and Estate Law Journal, 55(2), 147-198
Martinez, T. S., & Tang, C. (2022). The Impact of COVID-19 on LGBTQIA+ Individuals’ Technology Use to Seek Health Information and Services. In International Conference on Pervasive Computing Technologies for Healthcare (pp. 53-70). Springer, Cham.
McCabe, H. A., & Kinney, M. K. (2018). LGBTQ+ Individuals, Health Inequities, and Policy Implications. Creighton L. Rev., 52, 427.
National Archives. (2022). Milestone Documents. Civil Rights Act 1964. Retrieved on 10/13/2022 from: https://www.archives.gov/milestone-documents/civil-rights-act
National Association of Funeral Directors. (2022). Code of Professional Conduct. Retrieved on 10/14/2022 from: https://nfda.org/Portals/0/NFDAORG/About/Professional_Conduct/Code-of-Professional-Conduct.pdf
National Association of Funeral Directors. (2022). Statistics. Retrieved on 10/15/2022 from: https://nfda.org/news/statistics
Penrose, M. M. M. (2022). The Public Accommodations Dilemma-Whose Right Prevails. Akron ConLawNOW, Forthcoming, Texas A&M University School of Law Legal Studies Research Paper Forthcoming.
Pew Research Center. (2019). Attitudes of Same-Sex Marriage by Religious Affiliation. Retrieved on 10/14/2022 from: https://www.pewresearch.org/religion/fact-sheet/changing-attitudes-on-gay-marriage/#CHAPTER-h-attitudes-on-same-sex-marriage-by-religious-affiliation
Pizer, J. C. (2022). Anything less Is less than Equal: The Structure and Goals of the
Equality Act. Human Rights, 47(3-4), 10-12.
Porterfield, J. (2016). Marriage Equality: Obergefell v. Hodges. Enslow Publishing, LLC.
Rawlings, D., Tieman, J., Miller‐Lewis, L., & Swetenham, K. (2019). What role do death doulas play in end‐of‐life care? A systematic review. Health & Social Care in the Community, 27(3), e82-e94.
Riano, C. R., & Eskridge, W. (2020). The unfinished business of LGBTQ+ equality: five
years after Obergefell v. Hodges. New York State Bar Association Journal, 92(5),
38-42.
Rosentel, K., VandeVusse, A., & Hill, B. J. (2020). Racial and socioeconomic inequity in the spatial distribution of LGBTQ human services: an exploratory analysis of LGBTQ services in Chicago. Sexuality Research and Social Policy, 17(1), 87-103.
Service Corporation International. (2022). Code of Conduct and Ethical Standards. Retrieved on 10/14/2022 from: https://www.sci-corp.com/about/responsibility/ethics
Singer, J. W. (2019). Public Accommodations & Human Flourishing: Sexual Orientation & Religious Liberty. Cornell JL & Pub. Pol’y, 29, 697.
Shelvock, M., Kinsella, E. A., & Harris, D. (2022). Beyond the corporatization of death systems: Towards green death practices. Illness, Crisis & Loss, 30(4), 640-658.
Stephens, B. (2020). Where Were the States? Same-Sex Marriage Before Obergefell. In International Handbook on the Demography of Marriage and the Family (pp. 273-284). Springer, Cham.
Stock, P. V., & Dennis, M. K. (2021). Up in smoke or down with worms? older adult environmentalist’s discourse on disposal, dispersal, and (green) burial. Mortality, 1-17.
Stone, A. L. (2018). The geography of research on LGBTQ life: Why sociologists should study the south, rural queers, and ordinary cities. Sociology Compass, 12(11), e12638.
Webster, L. (2018). Why Caring for Our Own Dead is an Act of Social Justice. Wake Forest JL & Pol’y, 8, 125.
Whittemore, A. H. (2022). Finding Queer Life through Allies: The Geography and Intentions of Mainstream-Oriented, Ostensibly LGBTQ-Supportive Businesses in a Smaller Metropolitan Area of the US South. Annals of the American Association of Geographers, 1-16.
Yoshino, K. (2015). A New Birth of Freedom?: Obergefell v. Hodges. Harv. L. Rev., 129, 147.
Young, E. I. (2020). What the Supreme Court Could Have Heard in RG & GR Harris Funeral
Homes v. EEOC and Aimee Stephens. Calif. L. Rev. Online, 11, 9.
