Abstract
Commentators lament that we still have a long way to go for gay rights, yet in all of this angst over a potential anti-gay backlash leading to innovative state legislation to limit gay rights, several innovative measures seeking to expand gay rights have flown under the radar. California Senate Bill (SB) 1172 is one notable example of this phenomenon. It prohibits mental health providers and therapists from engaging in sexual orientation change efforts with minors under eighteen years of age. This Note discusses SB 1172 and the resulting litigation since its passage, as well as the bill’s potential implications.