Running head: HARM MEDICAL PRACTICES 1

Harmful Medical Practices: Banninng Conversion Therapy on Minors

Samantha L. Blackburn

Legal Studies Academy

First Colonial High School

HARMFUL MEDICAL PRACTICES 2

Abstract

This paper summarizes the legality of banning conversion therapy, changing someones sexual

orrentaion from gay to straight through therapy, on minors. It goes into studies on conversion

therapy and its affectiveness and the effects it can have on a person, as well as conversion

therapy being fruadulant, states regualtions on it, and specificly Virginia regualtions on

conversion therapy.
HARMFUL MEDICAL PRACTICES 3

Harmful Medical Practices: Banning Conversion Therapy on Minors

Over 700,000 adults have gone through conversion therapy, about half of them as minors

(Fadel, 2019). Statistics show that people who have gone through conversion therapy are eight

times more likely to commit suicide, six times more likely to have depression, and three times

more likely to abuse drugs ("Jonah Conversion," n.d.). So why is it still legal? Conversion or

reparative therapy, as it is now commenly called, is the practice of changing a patient’s sexual or

gender orientation, from homosexual to hetrosexual, through the use of therapy, and is a practice

that most medical associations have deemed ineffective and harmful ("The Lies," n.d.).

According to the article “Gay Conversion Therapy's Disturbing 19th-Century Origins,” in 1899 a

psychiatrist made a claim that he had turned a gay man straight; this led to the creation of

conversion therapy. The practice became popular throughout the 1900’s due to the fact that

during that time period homoseuality was seen as a mental disorder. Like many mental disorders

in the 1900’s it was treated with what is now seen as unethical forms of therapy including

electroshock, lobotomies, aversion therapy, and many other treatments (Blakemore, 2018). In

(Blakemore, 2018). After that, many other health and psychiatric organizations’ position on

conversion therapy changed to match with the APA’s in that it does not work and cause lots of

harm to the patients ("The Lies," n.d.). Conversion therapy is fraudulant and endangers minors

through the use of questionable therapies and produces ineffective results.

Harmful and Ineffective

The Substance Abuse and Mental Health Services Administration (SAMHSA) and the

APA in 2007 conducted a study on some conversion therapy cases, and they concluded that

conversion therapy is dangourus and harmful to minors due to the fact that it is built off of
HARMFUL MEDICAL PRACTICES 4

hatered towards people who are LGBTQ. They also concluded that because many psychological

and medical organizations don’t approve of the practice, there aren’t any real guidelines on how

to conduct the therapy (Sibley, 2015).

Studies

There have been many studies done on the affects of conversion therapy and if sexuality

could be changed through therapy. David Jenkins and Lon Johnston, coauthors of “Unethical

Treatment of Gay and Lesbian People With Conversion Therapy,” a scholorly jornal that reviews

some of the studies done on sexualitly and conversion therapy, found that most studies done on

the effectiveness of conversion therapy violate the National Assocation of Social Workers

(NASW) code of ethics section 5.02. NASW Code of Ethics (1999) Sections 5.02, Evaluation

and Research, section 5.02n states "Social workers should report evaluation and research

findings accurately. They should not fabricate or falsify results and should take steps to correct

any errors later found in published data using standard publication methods." This means that

research should be reported accurately and without bias. Section 5.02p states that social workers

must "educate themselves, their students, and their colleagues about responsible research

practice.” Jenkins and Johnston found that either the code was violated through sampling flaws,

the measure of change was unreliable, or follow up studies where not being done. Studies done

by Bieber et al. (1962) and Masters and Johnson (1979) both have sampling flaws. In both

studies the participents consisted of both gay and bisexual people. This skewed the data due to

the fact that a percent of the participants found the opposite gender attractive already. Many

studies got their data through self-reporting, which could skew the data if there was a response

bias. As seen in the studies done by Bieber et al. (1962) and Mintz (1966), the participants in
HARMFUL MEDICAL PRACTICES 5

these studies did want to change their sexual orientation, so they were more likely to say that the

therapy worked even if it didn’t. Also most studies never go back to follow up the study, so

there's no way to know if the therapy works long term. This was seen in the studies done by

Throckmorton (1998) and Spitzer (2003) (Jenkins & Johnston, 2004).

The APA also did a study analizing other research done on conversion therapy and its

effects. They found that conversion therapy is unlikely to cause a decrease of sexual atttraction

for the same sex. Not only did the APA conclude that conversion therapy is inaffective but also

that it is dangerous, due to the fact that conversion therapy is based on predjudice towards

homosexuality. In conclusion, the APA deemed conversion therapy as inaffective and harmful

("The Lies," n.d.).

Effects on Minors

Many times people go to therapy to fix something that is wrong, like depression or a

marriage. Conversion therapy is no different, expecpt for the fact that conversion therapy is

based on the hatred towards being gay and the idea that homosexuality is a disorder and needs to

be and can be treated (Drescher & Zucker, n.d.). There is no support in conversion therapy,

unlike other types of therapy (Jenkins & Johnston, 2004). In Jenkins and Johnston jornal they

further found that in conversion therapy the relationship between the client and the therapist is

almost always going to be a negative one. Due to the fact that the therapy focuses on

homosexuality being bad and unnatural. This negative relationship can make the client feel

alone. In many cases of a minor going to conversion therapy, the minor is pressured into going

by their parents or other people in their lives, even if they don't want to change (2004). This in

turn only adds to the feeling of being alone. That feeling of being alone can lead to lowered
HARMFUL MEDICAL PRACTICES 6

self-esteem, lower self-worth, depression, feelings of shame, and even suicidal thoughts in a

client (Drescher & Zucker, n.d.). Many clients struggle with these emotions for years down the

road (Guay, 2014).

Like in the case of James Guay, at 16 he came out to his parents and was put into

conversion therapy. James went willingly because he wanted the therapy to work. He even went

to ex-gay confferences till he was 20 in the hopes that he would become striaght. In conversion

therapy Guay was told that it was his parents’ fualt that he was gay. That is because his

relationship with his father wasn’t very strong; he was gay. He was told that he needed stronger

same-sex friendships. None of it worked, and during those four years, Guay became depressed

and suicidal, and he began to self harm. Guay came to terms with his sexuality in his 20’s, but he

still suffered from suicidal thoughts, shame, and depression. He finally started seeing a therapist

in his 30’s to help him get over what he went through in conversion therapy (Guay, 2014). A

similar thing happened to Peter Nunn. He was 15 when he came out to his parents and started

conversion therapy. But unlike Guay, he was not going willingly. Nunn reported that on the car

ride to the therapist he felt that everything he knew was being threatened. In the therapy he was

told that he was wrong and was committing a sin. Nunn eventualy tried to commit suicide. After

many years he was able to overcome what was done to him and is now living happily with his

husband (Fadel, 2019). There are thousands of case just like theirs of poeple going to conversion

therapy, etheir willingly or unwillingly, and in the end the person is still attrected to the same

sex, but now has feelings of self loathing, shame, depression, and sometimes even suicidal

thoughts (Drescher & Zucker, n.d.).

HARMFUL MEDICAL PRACTICES 7

Regulations & Cases

There aren’t many regulations, medical or state, that specifically target conversion

therapy and how it should be counducted. But there are laws banning conversion therapy on

minors in some states. In the states California, Colorado, Delaware, Hawaii, Maryland,

Massachusetts, Nevada, North Carolina, Oregon, and Rhode Island conversion therapy is banned

on the grounds that it is harmfull and unaffective (Movement Advancement Project, 2019). In

Delaware’s ban on conversion therapy, SB No.65, Delaware states that it has “a compelling

interest in protecting the physical and psychological well-being of children, including lesbian,

gay, bisexual, and transgender children, and in protecting its children against exposure to serious

harms caused by conversion therapy.” The bill also states that Delaware opposes conversion

therapy due to the fact that there is no sugnificant evidnce proving that it works, and that it has

been proven to be harmfull to minors (An Act to Amend, 2018).

In the case of ​Pickup v. Brown​ (2013), a friend-of-the-court brief was filed to the U.S.

Ninth Circuit Court of Appeals by Lambda Legal, representing 12 national and regional

organizations. The brief pleaded for the judges to uphold SB 1172, which is a California law

outlawing the use of conversion therapy on minors. The courts ruled to uphold the SB 1172 law

(​Pickup v. Brown​, 2013). In 2017 a challenge to California’s 2012 law banning conversion

therapy, the same law from the ​Pickup v. Brown​ case, was brought to the United States Supreme

Court. The plaintiffs claimed that the law was prohibiting their right to practise their religion.

The Supreme court rejected the challenge, upholding the ban (Chung, 2017).
HARMFUL MEDICAL PRACTICES 8

Fraud

Fraud as defined by USLegal is the intentional act of “misrepresentation of material

existing fact made by one person to another with knowledge of its falsity and for the purpose of

inducing the other person to act, and upon which the other person relies with resulting injury or

damage.” This means that any intentional act of lying to get someone to do something for your

own gain, or promising someone something even though you have specific knowledge of

information opposing that promise, is fraud (USLegal, n.d.).

There are many different types of fraud: tax fraud, check fraud, insurance fraud, and

many others (Content Team, 2014). In regards to conversion therapy, consumer fraud is what is

being committed. Consumer fraud according to Winston and Strawn LLP is a “deceptive

business practices that cause consumers to suffer financial or other losses.” ("What Is the

Definition," n.d.). Conversion therapy is a practices that has been widely discredited by most

phychological and medical orginizations. So a business claiming to be able to change one's

sexual orientation from gay to straight through conversion therapy would be deceiving the

patient, commiting fraud (USLegal, n.d.).

State Laws

Many states have banned conversion therapy due to the fact that it is fraudulant.

Connecticut, Illinois, New Jersey, New Mexico, and Washington all have laws banning

conversion therapy on minors and any medical practices caught offering the practice to minors

will be charged with fruad (Movement Advancement Project, 2019). In Connecticut under the

law HR 6695, conversion therapy was banned. The law states that any medical practice found to
HARMFUL MEDICAL PRACTICES 9

be practicing conversion therapy will be commiting fruad under the the Connecticut Unfair

Trade Practice Act (CUTPA)(An Act Concerning, 2017).

Therapeutic Fraud Act

The Therapeutic Fraud act of 2017 is a federal bill that has yet to be passed or even

voted on by the House or Senate ("Therapeutic Fraud," n.d.). If the bill were to be passed,

Congress would not only be recognizing that being gay, lesbian, bisexual, or transgender are not

mental disorders, but also that conversion therapy is dangerous and not proven to be affective.

The act defines conversion therapy as any practices that claims to be able to change ones sexual

oreiantaion or gender identy, not including practices that provided aid to those going through

gender transition or those that offer support and acceptance of lgbtq. The act states that:

It shall be unlawful for any person—(1) to provide conversion therapy to any

individual if such person receives monetary compensation in exchange for such

services; (2) to advertise for the provision of conversion therapy and claim in such

advertising—(A) to change another individual’s sexual orientation or gender

identity; (B) to eliminate or reduce sexual or romantic attractions or feelings

toward individuals of the same gender; or (C) that such efforts are harmless or

without risk to individuals receiving such therapy; or (3) to assist or facilitate the

provision of conversion therapy to an individual if such person receives monetary

compensation, from any source, in connection with providing conversion therapy.

This means that if a practice claims and advertises that the practice can change one’s sexual

orientation or gender identity, or reduce same sex attraction, and or that it can be done safely, is
HARMFUL MEDICAL PRACTICES 10

commiting fruad and will be punished under the section 18(a)(1)(B) of the Federal Trade

Commission Act, or by what the state deems appropriate (Therapeutic Fraud, 2017).

Cases

In the case of ​Ferguson v. Jonah​ (2012), five people filed an action against JONAH, Jews

Offering New Alternatives for Healing, claiming that it violated New Jersey Consumer Fraud

Act ("CFA"), ​N.J.S.A.​ 56:8-1 to -20. Jonah offered conversion therapy, claiming to be able to

change a person sexual orentation to hetarosexual. The way that this was done was through

one-on-one sessions and group sessions. During one-on-one sessions plaintiffs reported that they

would be told to get naked in front of a mirror, and touch themselves, or to say something

negative about themselves. They where told to blaim their parents for them being gay, and would

even be told to beat up a dummie while imagining it was their parents. In group sessions they

would do reenactments of past abuse; having slurs yelled at them and yelling them themselves.

There would be group cuddling sessions where everyone would strip down and cuddle. The

plaintiffs would be paying for these sessions and yet they weren't working. The courts ruled in

favor of the plaintiffs, agreeing that JONAH was committing consumer fraud (​Ferguson v.

Jonah,​ 2014).("Michael Ferguson," n.d.).

Resistance to Banning Conversion Therapy

Even with the APA and many other major health organizations speaking against

conversion therapy, there are still supporters of the practice. Ex-gay supporters belive that

conversion therapy works and that it is possible to change ones sexual orrentation from

homosexual to hetrosexual. They argue that banning conversion therapy is taking away
HARMFUL MEDICAL PRACTICES 11

therapists’ First Amendment rights of free speech, and taking away the parents’ rights to raise

their child how they see fit.

Consent

Consent is a key factor in the medical field. The scholarly journal ​Innovations in Clinical

Neuroscience​, states that before medical care can be given to a patient, the patient must first give

their consent to the treatment. If the patient is a minor, then a parent or guardian must give their

consent due to the fact that in most cases, children are not able to give consent (McNary, 2014).

For this reason, many supporters of conversion therapy say that the government is taking away

their right to raise their child how they see fit (Wardle, 2015).

The fight between parents rights to raise their child as they see fit and the government's

interest in the welfare of minors has been going on for years. Not just in the realm of conversion

therapy. In a report done by the American Psychological Association (APA), the many cases of

the government getting involved in the medical welfare of minors are reviewed. In the

1950s-1980s, a movement began where people of religious or faith based communities would

refuse many medical treatments, due to their faith. It got so bad that the hospitals and social

workers would file actions to be appointed temporary medical guardian of the minor just so that

they could get the treatment needed. The government also has put laws into place banning

parents from performing highly controversial medical treatments to their children. In most of

these cases the government only got involved once the right of the parents or guardians to

choose, put the minor at risk of harm (Wardle, 2015). The supporters of conversion therapy fight

that it is in their right to choose to put their child in conversion therapy or not, and that it does

not cause harm to the child, which is not true. The government has the right to get invovled due
HARMFUL MEDICAL PRACTICES 12

to the fact that most major health orginiazations have denoced conversion therapy due to it being

harmful.

Laws Suits & Cases

There are many cases of supporters going to court to fight the bans on conversion

therapy. In an NBC news article it states that a lawsuit was brought to court by a health therapist

under the grounds that the ban violated the First Amendment. The plaintiff’s lawyer argued that

the ban “treats the speech of professionals like Mr. Doyle differently from other constitutionally

protected speech.” The plaintiff also argued that the ban violates the patients’ First Amendment

rights to be informed of all information, and that the law does not distinguish between willing

and unwilling conversion therapy. The judge through out the case stating that the ban was put

into place to protect minors from the harms of conversion therapy, that therapist are not aloud to

practice conversion therapy, and that it only bans speech done on the grounds of changing one’s

sexual orientation. The judge also stated that children under the age of 16 can’t legally consent to

anything in Maryland (The Associated Press, 2019).

In September of 2019, an advocacy group brought the city of Tampa, Florida, to federal

court, challenging the city’s 2017 ban on conversion therapy on minors. The advocacy group

argued that while the city was in its right to ban therapies that harm a minor even verbally, the

bill was too broad and vague. The city argued that “the ban is aimed at cases where therapists

have a predetermined goal of converting children into being heterosexual or to the gender

identity assigned to them at birth.” The court is supposed to make a decision later this year

(O'Donnell, 2019).
HARMFUL MEDICAL PRACTICES 13

Bannning conversion therapy in Virginia

There are two options that Virginia can persue to ban conversion therapy on minors.

Virginia could ban conversion therapy on the grounds that it is harmfull and inaffective, like

Califronia and Delaware, or Virginia could ban conversion therapy on the grounds that it is

fraudulent, like New Jersey and Connecticut.

Banning Conversion Therapy on the Grounds that it is Harmfull & Inaffective

Virginia has tried to ban conversion therapy on the grounds that it is harmful and

inaffective before, but each time the ban was thrown out by legislators on the grounds that it

would be abstrocting peoples freedom of religon. A Washington Blade news article reported that

earlierer this year a bill was introduced to the Senate that would ban physical conversion therapy

practices on minors, meaning electroshock and adversion therapies, on the grounds that it is

harmful to minors, but would not ban talk therapy. The bill was passed, but the following day the

Senate relooked at the bill, and in the end the bill was not passed (Wellemeyer, 2019). ​Mechelle

Hankerson​, a reproter for the Virginia Mecury, reported that in January of this year the board of

psychology created a guidance document for Virginia legislators in support of banning

conversion therapy on minors in all regards, be it through physical or verbal therapy. In October

of this year Virginia Beach requested for a state wide ban on conversion therapy to the genral

assembly. This would ban conversion therapy on the grounds “that any psychological practice be

done within professional standards, and there are none for conversion therapy as it is a

denounced practice” states Michael Berlucchi, a Virgina Beach council member. The ban has yet

to be passed (Hankerson, 2019).

Banning Conversion Therapy on the Grounds that it is Fraudulent

HARMFUL MEDICAL PRACTICES 14

While Virginia has had no luck banning conversion therapy on the grounds that it is

harmful and inaffective, Virginia could still ban conversion therapy due to it being fraudulent. In

2015 Illinois revised their Youth Mental Health Protection Act. In the revision, conversion

therapy is banned on the grounds that it is fraudulent. The revision states that any person or

practices that offers conversion therapy “in a manner that represents homosexuality as a mental

disease, disorder, or illness, with intent that others rely upon the concealment, suppression, or

omission of such material fact” would be commiting fraud under the Consumer Fraud and

Deceptive Business Practices Act (Youth Mental, 2015). Using Illinois’s bill as a precedent,

Virginia could make conversion therapy illegal under the Virginia Consumer Protection Act

(VCPA). The VCPA protects consumers not just from fraud but also “any other deception,

…false pretense, false promise, or misrepresentation in connection with a consumer transaction.”

(Berlik, 2014). Which would encompase conversion therapy due to there being no suggnifigent

evidance of conversion therapy working (​Appropriate Therapeutic,​ 2009). So any person or

practice offering conversion therapy promising to change a person’s sexual orrentaion from gay

to streight would a fasle promise (Berlik, 2014).

HARMFUL MEDICAL PRACTICES 15

Conclusion

Conversion therapy has long been a denounced practice by most major health and

psychological orginizations due to the fact that it was harmful and inaffective. As seen in Jenkins

and Johnston study, there is no substantial proof that conversion therapy can succsefuly change

someone’s sexual orentation from homosexual to heterosexual (2004). And in the APA’s study

research showed that the effects of conversion therapy are rarely positive; in most cases it causes

depresion, suicidle thoughts, feelings of shame and self hatered ("The Lies," n.d.). This idea that

conversion therapy should be banned is has now spread into legislation. Some states have banned

conversion therapy on minors on the grounds that it is harmful and inaffective just like many

health orginizations had, but other states banned conversion therapy on the grounds that it is

fraudulant (Movement Advancement Project, 2019). As of 2019, 16 states including the District

of Columbia and Puerto Rico have banned conversion therapy on minors, and more states are to

follow (Fadel, 2019).

HARMFUL MEDICAL PRACTICES 16

References

An Act Concerning the Protection of Youth From Conversion Therapy, H.R. 6695, 2017 Gen.

Assem. (Conn. May 4, 2017). Retrieved from

https://www.cga.ct.gov/2017/FC/2017HB-06695-R000719-FC.htm

An Act to Amend Tittles 24 and 29 of the Delaware Code Relating to Conversion Therapy, S.

65, 2017 Gen. Assem. (Del., as passed, July 23, 2018).

Report of the American Psychological Association task force on: Appropriate therapeutic

responses to sexual orientation.​ (2009, August). Retrieved from

https://www.apa.org/pi/lgbt/resources/therapeutic-response.pdf

The Associated Press. (2019, September 24). Judge tosses lawsuit challenging Maryland

conversion therapy ban. Retrieved from NBC News website:

https://www.nbcnews.com/feature/nbc-out/judge-tosses-lawsuit-challenging-maryland-co

nversion-therapy-ban-n1058056

Berlik, L. E. (2014, November 10). Virginia Consumer Protection Act not limited to fraud.

Retrieved December 13, 2019, from Berliklaw website:

https://www.virginiabusinesslitigationlawyer.com/virginia-consumer-protection-a-1/

Blakemore, E. (2018, June 22). Gay conversion therapy's disturbing 19th-Century origins.

Retrieved June 28, 2019, from History.com website:

https://www.history.com/news/gay-conversion-therapy-origins-19th-century

Chung, A. (2017, May 1). U.S. top court rejects 'gay conversion' therapy ban challenge (W.

Dunham, Ed.). Retrieved December 12, 2019, from Reuters website:

HARMFUL MEDICAL PRACTICES 17

https://www.reuters.com/article/us-usa-court-gayconversion/u-s-top-court-rejects-gay-co

nversion-therapy-ban-challenge-idUSKBN17X1SJ

Clucas, R. (2017). Sexual orientation change efforts, conservative christianity and resistance to

sexual justice. ​Social Sciences​, ​6​(2). https://doi.org/10.3390/socsci6020054

Content Team. (2014, December 1). Fraud. Retrieved December 9, 2019, from Legal Dictionary

website: https://legaldictionary.net/fraud/

Corvino, J. (Ed.). (1997). ​Same sex debating the ethics, science, and culture of homosexuality.​

Lanham, MD: Rowman & Littlefield.

Cramer, R. J., Golom, F. D., LoPresto, C. T., & Kirkley, S. M. (2008). Weighing the evidence:

Empirical assessment and ethical implications of conversion therapy. ​Ethics & Behavior​,

18​(1), 22, 93-114. Retrieved from

https://doi-org.eztcc.vccs.edu:2443/10.1080/10508420701713014

Drescher, J., & Zucker, K. J. (Eds.). (n.d.). ​Ex-Gay research analyzing the spitzer study and its

relation to science, religion, politics, and culture.​ Harrington Park Press.

Fadel, L. (2019, April 26). Activist and suicide prevention groups seek ban on conversion

therapy for minors. ​NPR.​ Retrieved from

https://www.npr.org/2019/04/26/716416764/activists-and-suicide-prevention-groups-seek

-bans-on-conversion-therapy-for-mino

Ferguson v. Jonah, 129 N.J. Super (Superior Court June 6, 2014).

Guay, J. (2014, July 15). My hellish youth in gay conversion therapy and how I got out. ​Time​.

Retrieved from https://time.com/2986440/sexual-conversion-therapy-gay/

HARMFUL MEDICAL PRACTICES 18

Halgin, R. P. (2009). ​Taking sides: Taking sides. clashing views in abnormal psychology​ (5th

ed.). Boston: McGraw-Hill Higher Education.

Hankerson, M. (2019, October 16). Virginia Beach will ask the General Assembly to ban

conversion therapy. Retrieved December 5, 2019, from Virginia Mercury website:

https://www.virginiamercury.com/blog-va/virginia-beach-will-ask-the-general-assembly-

to-ban-conversion-therapy/

Jenkins, D., & Johnston, L. B. (2004). Unethical treatment of gay and lesbian people with

conversion therapy. ​Families in Society,​ ​85(​ 4). https://doi.org/10.1606/1044-3894.184

Jonah conversion therapy case. (n.d.). Retrieved from Southern Poverty Law Center website:

https://www.splcenter.org/seeking-justice/case-docket/michael-ferguson-et-al-v-jonah-et-

al

King, K. A., & Vidourek, R. A. (2012). Teen depression and suicide: Effective prevention and

intervention strategies. ​The Prevention Researcher,​ ​19(​ 4). Retrieved from Gale Academic

OneFile database.

The lies and dangers of "conversion therapy". (n.d.). Retrieved September 23, 2019, from Human

Rights Campaign website:

https://www.hrc.org/resources/the-lies-and-dangers-of-reparative-therapy

McNary, A. (2014). Consent to treatment of minors. ​Innovations in Clinical Neuroscience,​

11​(3-4), 43-45. Retrieved from https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4008301/

Michael Ferguson, ET AL., v. Jonah, ET AL. (n.d.). Retrieved from Southern Poverty Law

Center website:
HARMFUL MEDICAL PRACTICES 19

https://www.splcenter.org/seeking-justice/case-docket/michael-ferguson-et-al-v-jonah-et-

al

Movement Advancement Project. (2019, August 5). ​Conversion therapy laws​ [Fact sheet].

Retrieved from lgbtmap website:

https://www.lgbtmap.org/img/maps/citations-conversion-therapy.pdf

New study shows teenage depression rates rising. (2018, May 15). Retrieved from Newport

Academy website:

https://www.newportacademy.com/resources/mental-health/teen-depression-study/

O'Donnell, C. (2019, September 24). Tampa's ban on 'conversion therapy' has its day in court.

Retrieved December 5, 2019, from Tampa Bay Times website:

https://www.tampabay.com/news/tampa/2019/09/24/tampas-ban-on-conversion-therapy-

has-its-day-in-court/

Pickup v. Brown (9th Cir. ). Retrieved from

https://www.lambdalegal.org/in-court/cases/pickup-v-brown-and-welch-v-brown

Rodgers, B. (2019, September 5). Utah's proposed 'conversion therapy' ban slated for public

hearing later this month. ​The Salt Lake Tribune​. Retrieved from

https://www.sltrib.com/news/politics/2019/09/05/utahs-proposed-conversion/

Sibley, C. (2015, October 20). Opinion: gay conversion therapy is mental torture for LGBT

youth opinion: gay conversion therapy is mental torture for LGBT youth. ​The Daily

Reveille​. Retrieved from

https://search.proquest.com/docview/1724053307/66BD07A2F84045F9PQ/1?accountid=

3785
HARMFUL MEDICAL PRACTICES 20

Therapeutic Fraud Act of 2017, H.R. 2119 (as introduced, Apr. 24, 2017).

Therapeutic fraud prevention act of 2017. (n.d.). Retrieved September 25, 2019, from Countable

website:

https://www.countable.us/bills/hr2119-115-therapeutic-fraud-prevention-act-of-2017

USLegal. (n.d.). Fraud law and legal definition. Retrieved December 9, 2019, from USLegal

website: https://definitions.uslegal.com/f/fraud/

Wardle, L. D. (2015). Controversial medical treatments for children: The roles of parents and of

the state. ​Family Law Quarterly,​ 509-533. Retrieved from ProQuest 5000 database.

Wellemeyer, J. (2019, February 7). Bill to ban physical conversion therapy treatments for minors

killed in Va. Senate. Retrieved December 9, 2019, from Washington Blade website:

https://www.washingtonblade.com/2019/02/07/bill-to-ban-physical-conversion-therapy-tr

eatments-for-minors-killed-in-va-senate/

What is the definition of consumer fraud? (n.d.). Retrieved December 9, 2019, from Winston &

Strawn website: https://www.winston.com/en/legal-glossary/consumer-fraud.html

Youth Mental Health Protection Act., H.R. HB0217, 2015 Gen. Assem. (Ill. Aug. 20, 2015).

Retrieved from http://www.ilga.gov/legislation/99/HB/PDF/09900HB0217lv.pdf