The Limits of Equality: Family Values Rhetoric in the Case of Bottoms v. Bottoms

Gay liberation had come to conservative Virginia in the 1970s and 1980s, and, during this time, LGBT Virginians had made some progress toward increased visibility, acceptance, and electoral strength. Nevertheless, when it came to the key definition of family, the laws in the Commonwealth remained some of the most oppressive in the nation. Those limits to equality imposed by traditional Christianity were certainly evident in the tragic case of Sharon Bottoms, a young, newly-out lesbian mother, who was sued by her own mother Kay for custody of Sharon’s infant son Tyler because Sharon was living in a committed relationship with another woman, April Wade. In 1993, Virginia Circuit Court Judge Buford Parsons ruled in favor of the grandmother stating bluntly that Sharon was inherently unfit to be a parent because sodomy was a crime in Virginia. This paper closely analyzes the arguments on both sides, concentrating on the family values arguments and tropes in the decision of Judge Parsons and the upholding of Parsons by the Virginia Supreme Court.