Dear Legislator – FTC Complaint
National Task Force for Therapy Equality
Equality And Justice For All
P.O. Box 15898 Arlington, VA 22215
June 5, 2017
The National Task Force for Therapy Equality represents thousands of clients who experience sexual and gender identity conflicts, as well as their parents, families, places of worship, and communities. In the last five years, our coalition of licensed psychotherapists, social workers, psychiatrists, and physicians have worked with legislatures across the country to educate them on efforts to ban voluntary psychotherapy with licensed professionals for minors and their families who seek to resolve unwanted homosexual and gender identity conflicts. In the course of our work from 2012 to the present, we have been supported by the majority of state legislatures where legislation to ban therapy has been introduced1. Unfortunately, eight states have passed bills into law that will deprive young people of their rights. Even more concerning is the nature of how these bills have been passed.
The purpose of the attached document is to alert you of the dangerous and irresponsible tactics of three of the largest gay activist organizations (Human Rights Campaign, Southern Poverty Law Center, and National Center for Lesbian Rights) that are responsible for introducing and lobbying for these bills. The nature of their deceptive work is so egregious that our Task Force thought it necessary to file a consumer fraud complaint with the Federal Trade Commission (FTC) titled:
In Their Own Words — Lies, Deception, and Fraud: The Southern Poverty Law Center, Human Rights Campaign, and National Center for Lesbian Rights’ Hate Campaign to Ban Psychotherapy for Individuals with Sexual and Gender Identity Conflicts.
This complaint was filed on behalf of nine organizations, representing over 20,000 licensed psychotherapists, psychiatrists, and physicians2. As the attached complaint details, the three opposing organizations have been actively working together for at least five years in a deceptive and fraudulent hate campaign with the goal of deceiving law makers on the state, federal, and international level to enact legislation to ban licensed psychotherapy for minor clients that experience unwanted same-sex attractions and/or gender identity conflicts. To date, eight states and several cities and jurisdictions have passed such legislation into law, prompting several lawsuits across the country.
The complaint to the FTC documents evidence of the following:
- The three organizations have actively and knowingly engaged in deceptive and fraudulent marketing practices of the kind the FTC considers malicious, which are particularly deceptive and misleading to consumers and the general public. This complaint is pursuant to the FTC’s definition of unfair practices, defined as those that “cause or are likely to cause substantial injury to consumers which is not reasonably avoidable by consumers themselves and not outweighed by countervailing benefits to consumers or to competition” (15 U.S.C. Sec. 45(n)).
- The three organizations have supported witnesses on the state, federal, and international level that have delivered unverifiable and fraudulent testimony in front of law-making bodies in the effort to persuade legislative action to ban psychotherapy. Through multiple examples, it has now been proven these witnesses have lied and engaged in a variety of deceptive practices on behalf of the organizations’ hate campaigns to ban psychotherapy.
- The three organizations, through their marketing campaigns, are actively raising large sums of money in the effort to ban psychotherapy by using deceptive and fraudulent practices. These practices are misleading to the general public, and, as this complaint documents, it is highly unlikely that the three organizations are unaware of the false and misleading nature of how their statements distort the facts and research around psychotherapy to help clients with sexual and gender identity conflicts. As such, they are knowingly misleading consumers in their efforts to profit from such activities.
- The three organizations, through their marketing campaigns, have actively and knowingly distorted the research to promote efforts to ban psychotherapy for clients with sexual and gender identity conflicts, including misleading statements regarding the 2009 American Psychological Association Task Force Report on Appropriate Therapeutic Responses to Sexual Orientation, as well as other research (e.g., Ryan et al., 2009). The three organizations use these statements to make false and misleading claims that psychotherapy is harmful and ineffective for minors who experience sexual and gender identity conflicts.
- The three organizations, through their marketing campaigns, have actively distorted the scientific research in promoting the “Born Gay” hoax, a notion that has been disproved and refuted by organizations such as the American Psychological Association through their 2008 Position Statement and 2014 APA Handbook of Sexuality and Psychology. The three organizations have perpetrated the “born this way” lie to further their respective political agendas, and in so doing, have raised untold sums of money from unsuspecting consumers and the general public.
- The three organizations have also engaged in smear and defamatory attacks on licensed psychotherapists and faith-
based ministries providing help and assistance to those who experience sexual and gender identity conflicts. Until recently, one of the organizations (SPLC) included an interactive “Hate Map” that identified nearly 100 therapists and ministries on their website. The SPLC recently removed this map in the aftermath of the crime of Floyd Corkins, a gunman who was inspired by the SPLC’s “Hate Map” to enter the Family Research Council in 2013 and attempt to murder conservatives.
- One of the organizations (SPLC) was also reported to the Internal Revenue Service (IRS) in 2017 by the Federation for American Immigration Reform (FAIR) for engaging in practices of using “opinion-based smears and innuendos” as though they were educational while violating governmental regulations and using tactics that it claims shields it from liability lawsuits. The organization’s blatant engagement in political activity is a clear violation of their 501(c) (3) status with the IRS, says the complaint.
By engaging in these deceptive and fraudulent practices, the three organizations are perpetrating undue harm on millions of consumers and the general public, thousands of licensed mental and medical health providers, and thousands of clients and potential clients that experience sexual and gender identity conflicts. Because their hate campaigns have already resulted in therapy bans enacted in at least eight states and several cities and jurisdictions, this report respectfully requests the FTC to review these fraudulent and deceptive practices and to promptly order the organizations to cease their activities in an effort to protect therapists, clients, consumers, and the general public from further harm. In addition, we respectfully requested the FTC to order the three organizations to issue press releases, correct inaccurate statements on their websites, and actively work with legislators across the United States to reverse legislation that has been passed into law so that further harm can be avoided.
We hope you recognize the serious nature of these fraudulent and deceptive acts by these three organizations and take steps to ensure the therapy equality of all young people, and their families, in your state, city, or jurisdiction.
Christopher J. Doyle, MA, LPC, LCPC
Co-Coordinator, National Task Force for Therapy Equality
These states include: New Hampshire, Arizona, Georgia, West Virginia, Nevada, Minnesota, Rhode Island, Pennsylvania, Ohio, Iowa, Colorado, Virginia, Washington, Florida, Texas, New York, Massachusetts, Maryland, and Hawaii.
These organizations include: American College of Pediatricians, Christian Medical and Dental Associations, Alliance for Adolescent Health, Family Watch International, Voice of the Voiceless, Center for Family and Human Rights, Alliance for Therapeutic Choice and Scientific Integrity, Jewish Institute for Global Awareness, and Freedom X.