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The public educational system is charged with more than the academic success of America's youth. Educators are responsible for "nurtur[ing] students social and moral development by transmitting to them an official dogma of community values." As Keeton v. Anderson-Wiley demonstrates, community values are rapidly changing to acknowledge new constructions of homosexual identity and constitutional interests relative to historically marginalized attributes. In Keeton the United States District Court for the Southern District of Georgia denied a preliminary injunction to a student asserting various First Amendment claims against her university for requiring her to complete remedial training for counseling gay, lesbian, bisexual, transgender, and queer/questioning (GLBTQ) clients. The district court followed the Supreme Court of the United States's analysis of school-sponsored speech in Hazelwood School District v. Kuhlmeier. But more significantly, the district court's straightforward acceptance of homosexuality remained a pervasive theme in Keeton. As such, Keeton represents a growing culmination of homosexual rights, emphasizing the readiness of modern courts to both reflect and shape public opinion with a positive acknowledgement of the homosexual community. As momentum builds toward an evaluation of same-sex marriage by the Supreme Court, such vital undercurrents of social construction will decidedly bear on the constitutional rights of homosexuals in the United States.

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