The Narrow Way

55 - Correcting Dr. Lisa Diamond

July 17, 2026•7 min read

The work of Dr. Lisa Diamond’s should be familiar to readers of R4R, as her findings that sexual orientation is not immutable or unchangeable have been quoted in numerous editions of this newsletter. She and legal professor Clifford J. Rosky filed an Amicus Brief in the Chiles v. Salazar Supreme Court case earlier this year, which would benefit from clarification.

In their brief, Rosky and Diamond state that their work has been mischaracterized as confirming that “conversion therapy” is beneficial:

Petitioners [Chiles] cite amici’s research article as support for the proposition that “longitudinal, population-based studies” reveal changes “in the same-sex attractions of some individuals over time.” Brief for Petitioners at 7-8, Chiles v. Salazar, No. 24-539 (U.S. June 6, 2025) (quoting Lisa M. Diamond & Clifford J. Rosky, Scrutinizing Immutability: Research on Sexual Orientation and U.S. Legal Advocacy for Sexual Minorities, 53 J. Sex Res. 363, 368 (2016)). But Petitioners omit amici’s explicit clarification—immediately preceding the sentence introducing this longitudinal data—that these data concern “change that occurs outside the context of [sexual orientation change efforts]” and have no bearing on the efficacy of sexual orientation change efforts at all. Diamond & Rosky, 53 J. Sex Res. at 368 (emphasis added).[1]

Disagreement exists with Dr. Diamond on numerous points. First, the general contention is that changes in same sex attractions are impossible across the board, and this is seen as the primary reason why counseling is harmful or not beneficial. The fact that changes do occur is crucial to understanding the importance of this case. Knowing that changes do occur in behavior, identity, and attractions is crucial for the basis of any sexual orientation exploration in counseling.

Dr. Diamond makes the distinction between:

(a) longitudinal evidence showing that some individuals experience spontaneous shifts in attraction or identity over time,[2] and
(b) evidence regarding deliberate attempts to alter orientation through conversion therapy and sexual orientation change efforts. [3]

Later in the same document, she refers to “the distinction between naturally occurring sexual-orientation fluidity and therapist-directed ‘conversion therapy.”[4]

Here we find a mischaracterization of the nature of counseling. “Therapist-directed ‘conversion therapy’” is a red herring. Therapists do not “direct” their clients in terms of setting goals or regarding methodology in talk therapy sessions. Clients and therapists work together collaboratively, rather than through dictates or authoritarian prescriptions. The kind of therapy Chiles is arguing for before the Supreme Court is explorative in nature, not some intervention directed by the therapist.

When Dr. Diamond argues that fluidity in sexual attractions/identity and gender identity only occurs “naturally,” and that it is dangerous to work with a counselor to seek changes in these areas, she is undermining the essence of science. The scientific method examines natural occurrences, and in the field of medicine, we use that knowledge to help facilitate the body’s ability to heal. Antibiotics, for example, target a bacterium’s cell walls or the proteins needed for bacterial growth, allowing the body’s immune system to fight off an infection.

False Assertions

Another misconception found in this submission to the Supreme court is found in this quote:

“therapists cannot ethically offer individuals the promise of changing their sexual orientation, given the lack of evidence that such permanent change can be therapeutically achieved.”[5]

No one is arguing for the ability of therapists to promise changes in their clients’ attractions, identities, and/or behaviors. Therapists do not typically promise results in any area of their practice. Furthermore, the lack of evidence is partly due to the chilling effect of bans on talk therapy, which aims to explore the possibility of facilitating these changes. A win in this Supreme Court case will open the door for further study of how these changes “naturally occur,” which will, in turn, assist counselors as they work with their clients who are interested in learning more about this part of their lives.

In this brief, numerous reports are cited associating counseling with harm for those looking for assistance with unwanted same sex attractions or confusion/insecurity about their gender. These reports have been debunked, as noted in R4R [6] and in another Amicus Brief submitted by the International Foundation for Therapeutic Counseling Choice:

For example, Trevor Project researchers said, “questions examining attempts to convince young people to change their sexual orientation and gender identity were endorsed by two thirds of respondents; however, these questions were too broad to be operationalized as formal SOGICE [sexual orientation and gender identity change efforts].” They also said many participants who experienced change efforts would not endorse use of the language “reparative therapy or conversion therapy.” Green, Self-Reported Conversion Efforts at 1225 (2020).
The researchers threw out 105 respondents who said they experienced “conversion or reparative therapy” but not someone trying to “convince” them to change, hence potentially respondents who experienced consensual counseling conversations. Id. Most surveys asked the U.S. 2015 Transgender Survey question, “Did any professional (such as a psychologist, counselor, religious advisor) try to make you identify only with your sex assigned at birth (in other words, try to stop you being trans)?” Researchers acknowledged the survey question was broad enough to include experiences that were not “conversion counseling.” See, e.g., Campbell, Conversion Therapy at 4. In a recent survey using these same questions, researchers said, “…we did not disaggregate GICE exposure based on the setting in which it was administered (i.e. religious vs. non-religious). Future studies should examine whether the administration of GICE in religious vs. non-religious settings is associated with differing outcomes.” Mammadli, Understanding Harms at 175. Other researchers who used these questions said, “We also lack data regarding the degree to which GICE [gender identity change efforts] occurred (eg, duration, frequency, and forcefulness of GICE, as well as what specific modalities were used.” Turban, Association Between at E8. Due to these methodological weaknesses these surveys are not useful sources of information about young-person-led consensual counseling conversations that are the subject of the Chiles case and the target of counseling bans. Pg 29-31[7]

The same critique can be found regarding a survey by the Williams Institute claiming harm resulting from counseling regarding sexual attractions: Not on Good Authority – Part I, Mar 15, 2022

Bans against “conversion therapy” across the country and internationally[8] have been written so broadly that they create human rights violations against an individual’s freedom to seek professional assistance with unwanted behaviors, desires, and feelings. Part of this can be seen as a measure to uphold the unstable identity categories related to sexuality and gender, which obviously are not immutable like one’s race.[9]

No one is arguing that therapists should be able to coerce or dictate to their clients, or make false promises.[10] Through her research, Dr. Diamond has made the case for fluidity in attractions, even among individuals who are not seeking it. She has not made the case in this Amicus Brief or elsewhere that it is always ineffective or harmful to seek to facilitate it through counseling. I, and many others, are living proof that counseling can be helpful in exploring the possibility of fluidity in attractions.[11]

[1] https://www.supremecourt.gov/DocketPDF/24/24-539/370607/20250825130742013_24-539acProfessorCliffordJ.RoskyProfessorLisaM.Diamond.pdf

[2] It is interesting that Dr. Diamond relates “shifts in attraction or identity” and “sexual orientation fluidity,” not mentioning changes in behavior. It is easy to see how ones identity or behavior can change, while changes in attraction seem to be the central focus of debate.

[3] https://www.supremecourt.gov/DocketPDF/24/24-539/370607/20250825130742013_24-539acProfessorCliffordJ.RoskyProfessorLisaM.Diamond.pdf

[4] Ibid.

[5] https://www.supremecourt.gov/DocketPDF/24/24-539/370607/20250825130742013_24-539acProfessorCliffordJ.RoskyProfessorLisaM.Diamond.pdf

[6] See also: SOCE Helpful, Not Harmful – Part III, Intentional Bias , Oct 11, 2022

SOCE Helpful, Not Harmful – Part II, Psychological and Social Harms Reduced , Oct 6, 2022

SOCE Helpful, Not Harmful – Part I, Reduction in Suicidal Ideation Found , Oct 4, 2022

[7] https://www.supremecourt.gov/DocketPDF/24/24-539/363195/20250613153058649_Chiles%20Supreme%20Court%20Brief.pdf

[8] See: Victorian Law Passes - A Christian Response, Feb 8, 2021

Standing for Evidence-Based Care In England and Australia, Jul 25, 2023 •

Australia, Part II, Jan 14, 2021

Australia, Part I, Jan 12, 2021

Ministry in Canada Continues Under New Chilling Laws – Part II, Apr 14, 2022