At Christian School, Non-Virgins Need Not Apply

Debra Haffner

I can't know the ethics of Ms. Hamilton's relationship, or her skills and talents to teach elementary school. What I do know is that premarital chastity should not be among the criteria of employment.

This article was originally published by The Huffington Post. It is reprinted here with permission by the author.

I couldn’t believe the news story was true.

The Southland Christian School in St. Cloud, Florida, fired an elementary school teacher, Jarretta Hamilton, for having had premarital sex. A school administrator said, “Jarretta was asked not to return because of a moral issue that was disregarded, namely fornication, sex outside of marriage.”

Ms. Hamilton is not an irresponsible teenager or young adult. She is 39 years old and married to the man she had sex with, who is the father of her child. Her mistake was telling the school she had conceived the child prior to their wedding night. It’s hard to imagine her husband would be fired for the same.

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Although many churches continue to mandate “celibacy until marriage,” most clergy today know that most of the couples they marry have already had shared sexual behaviors. According to the Guttmacher Institute, for at least the last 40 years, 95 percent of Americans had sexual intercourse before marriage. A Roman Catholic friend recently told me about a priest in premarital counseling who had asked couples to abstain for one month prior to the wedding ceremony, apparently acknowledging that most were already sexually involved.

I don’t believe that Ms. Hamilton acted immorally or unethically in having sex with her fiancé. In fact, I believe that sexual compatibility is so important in a marriage that I won’t perform a wedding for a couple that has only engaged in the least intimate sexual behaviors. In my time as ordained clergy, I have never performed a wedding for a couple who isn’t already cohabitating. I believe that an ethical sexual relationship is defined not by the marital status of the partners (nor by their sexual orientations or genders), but by whether their relationship is characterized by love, justice, mutuality, commitment, consent and pleasure.

From this distance, I can’t know the ethics of Ms. Hamilton’s relationship, or her skills and talents to teach elementary school. What I do know is that premarital chastity should not be among the criteria of employment, and that if the news reports are true, she should be re-instated. That’s the moral response that should not be disregarded.

Analysis Law and Policy

Do Counselors-in-Training Have the Right to Discriminate Against LGBTQ People?

Greg Lipper

Doctors can't treat their patients with leeches; counselors can't impose their beliefs on patients or harm them using discredited methods. Whatever their views, medical professionals have to treat their clients competently.

Whether they’re bakers, florists, or government clerks, those claiming the right to discriminate against LGBTQ people have repeatedly sought to transform professional services into constitutionally protected religious speech. They have grabbed headlines for refusing, for example, to grant marriage licenses to same-sex couples or to make cakes for same-sex couples’ weddings-all in the name of “religious freedom.”

A bit more quietly, however, a handful of counseling students at public universities have challenged their schools’ nondiscrimination and treatment requirements governing clinical placements. In some cases, they have sought a constitutional right to withhold treatment from LGBTQ clients; in others, they have argued for the right to directly impose their religious and anti-gay views on their clients.

There has been some state legislative maneuvering on this front: Tennessee, for instance, recently enacted a thinly veiled anti-LGBTQ measure that would allow counselors to deny service on account of their “sincerely held principles.” But when it comes to the federal Constitution, providing medical treatment—whether bypass surgery, root canal, or mental-health counseling—isn’t advocacy (religious or otherwise) protected by the First Amendment. Counselors are medical professionals; they are hired to help their clients, no matter their race, religion, or sexual orientation, and no matter the counselors’ beliefs. The government, moreover, may lawfully prevent counselors from harming their clients, and universities in particular have an interest, recognized by the U.S. Supreme Court, in preventing discrimination in school activities and in training their students to work with diverse populations.

The plaintiffs in these cases have nonetheless argued that their schools are unfairly and unconstitutionally targeting them for their religious beliefs. But these students are not being targeted, any more than are business owners who must comply with civil rights laws. Instead, their universities, informed by the rules of the American Counseling Association (ACA)—the leading organization of American professional counselors—merely ask that all students learn to treat diverse populations and to do so in accordance with the standard of care. These plaintiffs, as a result, have yet to win a constitutional right to discriminate against or impose anti-LGBTQ views on actual or prospective clients. But cases persist, and the possibility of conflicting court decisions looms.

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Keeton v. Anderson-Wiley

The first major challenge to university counseling requirements came from Jennifer Keeton, who hoped to receive a master’s degree in school counseling from Augusta State University. As detailed in the 2011 11th Circuit Court of Appeals decision considering her case, Keeton entered her professional training believing that (1) “sexual behavior is the result of personal choice for which individuals are accountable, not inevitable deterministic forces”; (2) “gender is fixed and binary (i.e., male or female), not a social construct or personal choice subject to individual change”; and “homosexuality is a ‘lifestyle,’ not a ‘state of being.'”

It wasn’t those views alone, however, that sunk her educational plans. The problem, rather, was that Keeton wanted to impose her views on her patients. Keeton had told both her classmates and professors about her clinical approach at a university-run clinic, and it wasn’t pretty:

  • She would try to change the sexual orientation of gay clients;
  • If she were counseling a sophomore student in crisis questioning his sexual orientation, she would respond by telling the student that it was not OK to be gay.
  • If a client disclosed that he was gay, she would tell him that his behavior was wrong and try to change it; if she were unsuccessful, she would refer the client to someone who practices “conversion therapy.”

Unsurprisingly, Keeton also told school officials that it would be difficult for her to work with LGBTQ clients.

Keeton’s approach to counseling not only would have flouted the university’s curricular guidelines, but also would have violated the ACA’s Code of Ethics.

Her conduct would have harmed her patients as well. As a school counselor, Keeton would inevitably have to counsel LGBTQ clients: 57 percent of LGBTQ students have sought help from a school professional and 42 percent have sought help from a school counselor. Suicide is the leading cause of death for LGBTQ adolescents; that’s twice or three times the suicide rate afflicting their heterosexual counterparts. And Keeton’s preferred approach to counseling LGBTQ students would harm them: LGBTQ students rejected by trusted authority figures are even more likely to attempt suicide, and anti-gay “conversion therapy” at best doesn’t work and at worst harms patients too.

Seeking to protect the university’s clinical patients and train her to be a licensed mental health professional, university officials asked Keeton to complete a remediation plan before she counseled students in her required clinical practicum. She refused; the university expelled her. In response, the Christian legal group Alliance Defending Freedom sued on her behalf, claiming that the university violated her First Amendment rights to freedom of speech and the free exercise of religion.

The courts disagreed. The trial court ruled against Keeton, and a panel of the U.S. Court of Appeals for the 11th Circuit unanimously upheld the trial court’s ruling. The 11th Circuit explained that Keeton was expelled not because of her religious beliefs, but rather because of her “own statements that she intended to impose her personal religious beliefs on clients and refer clients to conversion therapy, and her own admissions that it would be difficult for her to work with the GLBTQ population and separate her own views from those of the client.” It was Keeton, not the university, who could not separate her personal beliefs from the professional counseling that she provided: “[F]ar from compelling Keeton to profess a belief or change her own beliefs about the morality of homosexuality, [the university] instructs her not to express her personal beliefs regarding the client’s moral values.”

Keeton, in other words, crossed the line between beliefs and conduct. She may believe whatever she likes, but she may not ignore academic and professional requirements designed to protect her clients—especially when serving clients at a university-run clinic.

As the court explained, the First Amendment would not prohibit a medical school from requiring students to perform blood transfusions in their clinical placements, nor would it prohibit a law school from requiring extra ethics training for a student who “expressed an intent to indiscriminately disclose her client’s secrets or violate another of the state bar’s rules.” Doctors can’t treat their patients with leeches; counselors can’t impose their beliefs on patients or harm them using discredited methods. Whatever their views, medical professionals have to treat their clients competently.

Ward v. Polite

The Alliance Defending Freedom’s follow-up case, Ward v. Polite, sought to give counseling students the right to withhold service from LGBTQ patients and also to practice anti-gay “conversion therapy” on those patients. The case’s facts were a bit murkier, and this led the appeals court to send it to trial; as a result, the student ultimately extracted only a modest settlement from the university. But as in Keeton’s case, the court rejected in a 2012 decision the attempt to give counseling students the right to impose their religious views on their clients.

Julea Ward studied counseling at Eastern Michigan University; like Keeton, she was training to be a school counselor. When she reviewed the file for her third client in the required clinical practicum, she realized that he was seeking counseling about a romantic relationship with someone of the same sex. As the Court of Appeals recounted, Ward did not want to counsel the client about this topic, and asked her faculty supervisor “(1) whether she should meet with the client and refer him [to a different counselor] only if it became necessary—only if the counseling session required Ward to affirm the client’s same-sex relationship—or (2) whether the school should reassign the client from the outset.” Although her supervisor reassigned the client, it was the first time in 20 years that one of her students had made such a request. So Ward’s supervisor scheduled a meeting with her.

Then things went off the rails. Ward, explained the court, “reiterated her religious objection to affirming same-sex relationships.” She told university officials that while she had “no problem counseling gay and lesbian clients,” she would counsel them only if “the university did not require her to affirm their sexual orientation.” She also refused to counsel “heterosexual clients about extra-marital sex and adultery in a values-affirming way.” As for the professional rules governing counselors, Ward said, “who’s the [American Counseling Association] to tell me what to do. I answer to a higher power and I’m not selling out God.”

All this led the university to expel Ward, and she sued. She claimed that the university violated her free speech and free exercise rights, and that she had a constitutional right to withhold affirming therapy relating to any same-sex relationships or different-sex relationships outside of marriage. Like Keeton, Ward also argued that the First Amendment prohibited the university from requiring “gay-affirmative therapy” while prohibiting “reparative therapy.” After factual discovery, the trial court dismissed her case.

On appeal before the U.S. Court of Appeals for the Sixth Circuit, Ward eked out a narrow and temporary win: The court held that the case should go to a jury. Because the university did not have a written policy prohibiting referrals, and based on a few troubling faculty statements during Ward’s review, the court ruled that a reasonable jury could potentially find that the university invoked a no-referrals policy “as a pretext for punishing Ward’s religious views and speech.” At the same time, the court recognized that a jury could view the facts less favorably to Ward and rule for the university.

And although the decision appeared to sympathize with Ward’s desire to withhold service from certain types of clients, the court flatly rejected Ward’s sweeping arguments that she had the right to stray from the school curriculum, refuse to counsel LGBTQ clients, or practice anti-gay “conversion therapy.” For one, it said, “Curriculum choices are a form of school speech, giving schools considerable flexibility in designing courses and policies and in enforcing them so long as they amount to reasonable means of furthering legitimate educational ends.” Thus, the problem was “not the adoption of this anti-discrimination policy, the existence of the practicum class or even the values-affirming message the school wants students to understand and practice.” On the contrary, the court emphasized “the [legal] latitude educational institutions—at any level—must have to further legitimate curricular objectives.”

Indeed, the university had good reason to require counseling students—especially those studying to be school counselors—to treat diverse populations. A school counselor who refuses to counsel anyone with regard to nonmarital, nonheterosexual relationships will struggle to find clients: Nearly four in five Americans have had sex by age 21; more than half have done so by the time they turn 18, while only 6 percent of women and 2 percent of men are married by that age.

In any event, withholding service from entire classes of people violates professional ethical rules even for nonschool counselors. Although the ACA permits client referrals in certain circumstances, the agency’s brief in Ward’s case emphasized that counselors may not refuse to treat entire groups. Ward, in sum, “violated the ACA Code of Ethics by refusing to counsel clients who may wish to discuss homosexual relationships, as well as others who fail to comport with her religious teachings, e.g., persons who engage in ‘fornication.'”

But Ward’s approach would have been unethical even if, in theory, she were permitted to withhold service from each and every client seeking counseling related to nonmarital sex (or even marital sex by same-sex couples). Because in many cases, the need for referral would arise well into the counseling relationship. And as the trial court explained, “a client may seek counseling for depression, or issues with their parents, and end up discussing a homosexual relationship.” No matter what the reason, mid-counseling referrals harm clients, and such referrals are even more harmful if they happen because the counselor disapproves of the client.

Fortunately, Ward did not win the sweeping right to harm her clients or otherwise upend professional counseling standards. Rather, the court explained that “the even-handed enforcement of a neutral policy”—such as the ACA’s ethical rules—”is likely to steer clear of the First Amendment’s free-speech and free-exercise protections.” (Full disclosure: I worked on an amicus brief in support of the university when at Americans United.)

Ward’s lawyers pretended that she won the case, but she ended up settling it for relatively little. She received only $75,000; and although the expulsion was removed from her record, she was not reinstated. Without a graduate counseling degree, she cannot become a licensed counselor.

Cash v. Hofherr

The latest anti-gay counseling salvo comes from Andrew Cash, whose April 2016 lawsuit against Missouri State University attempts to rely on yet murkier facts and could wind up, on appeal, in front of the more conservative U.S. Court of Appeals for the Eighth Circuit. In addition to his range of constitutional claims (freedom of speech, free exercise of religion, equal protection of law), he has added a claim under the Missouri Religious Freedom Restoration Act.

The complaint describes Cash as “a Christian with sincerely-held beliefs”—as opposed to insincere ones, apparently—”on issues of morality.” Cash started his graduate counseling program at Missouri State University in September 2007. The program requires a clinical internship, which includes 240 hours of in-person client contact. Cash decided to do his clinical internship at Springfield Marriage and Family Institute, which appeared on the counseling department’s list of approved sites. Far from holding anti-Christian bias, Cash’s instructor agreed that his proposed class presentation on “Christian counseling and its unique approach and value to the Counseling profession” was an “excellent” idea.

But the presentation itself revealed that Cash intended to discriminate against LGBTQ patients. In response to a question during the presentation, the head of the Marriage and Family Institute stated that “he would counsel gay persons as individuals, but not as couples, because of his religious beliefs,” and that he would “refer the couple for counseling to other counselors he knew who did not share his religious views.” Because discrimination on the basis of sexual orientation violates ACA guidelines, the university determined that Cash should not continue counseling at the Marriage and Family Institute and that it would be removed from the approved list of placements. Cash suggested, however, that he should be able to withhold treatment from same-sex couples.

All this took place in 2011. The complaint (both the original and amended versions) evades precisely what happened between 2012 and 2014, when Cash was finally expelled. You get the sense that Cash’s lawyers at the Thomas More Society are trying to yadda-yadda-yadda the most important facts of the case.

In any event, the complaint does acknowledge that when Cash applied for a new internship, he both ignored the university’s instructions that the previous hours were not supposed to count toward his requirement, and appeared to be “still very much defend[ing] his previous internship stating that there was nothing wrong with it”—thus suggesting that he would continue to refuse to counsel same-sex couples. He continued to defend his position in later meetings with school officials; by November 2014, the university removed him from the program.

Yet in challenging this expulsion, Cash’s complaint says that he was merely “expressing his Christian worldview regarding a hypothetical situation concerning whether he would provide counseling services to a gay/homosexual couple.”

That’s more than just a worldview, though. It also reflects his intent to discriminate against a class of people—in a manner that violates his program’s requirements and the ACA guidelines. Whether hypothetically or otherwise, Cash stated and reiterated that he would withhold treatment from same-sex couples. A law student who stated, as part of his clinic, that he would refuse to represent Christian clients would be announcing his intent to violate the rules of professional responsibility, and the law school could and would remove him from the school’s legal clinic. And they could and would do so even if a Christian client had yet to walk in the door.

But maybe this was just a big misunderstanding, and Cash would, in practice, be willing and able to counsel same-sex couples? Not so, said Cash’s lawyer from the Thomas More Society, speaking about the case to Christian news outlet WORLD: “I think Christians have to go on the offensive, or it’s going to be a situation like Sodom and Gomorrah in the Bible, where you aren’t safe to have a guest in your home, with the demands of the gay mob.” Yikes.

Although Cash seems to want a maximalist decision allowing counselors and counseling students to withhold service from LGBTQ couples, it remains to be seen how the case will turn out. The complaint appears to elide two years’ worth of key facts in order to present Cash’s claims as sympathetically as possible; even if the trial court were to rule in favor of the university after more factual development, Cash would have the opportunity to appeal to the U.S. Court of Appeals for the Eighth Circuit, one of the country’s most conservative federal appeals courts.

More generally, we’re still early in the legal battles over attempts to use religious freedom rights as grounds to discriminate; only a few courts across the country have weighed in. So no matter how extreme Cash or his lawyers may seem, it’s too early to count them out.

* * *

The cases brought by Keeton, Ward, and Cash not only attempt to undermine anti-discrimination policies. They also seek to change the nature of the counselor-client relationship. Current norms provide that a counselor is a professional who provides a service to a client. But the plaintiffs in these cases seem to think that counseling a patient is no different than lecturing a passerby in the town square, in that counseling a patient necessarily involves expressing the counselor’s personal and religious beliefs. Courts have thus far rejected these attempts to redefine the counselor-patient relationship, just as they have turned away attempts to challenge bans on “reparative therapy.”

The principles underlying the courts’ decisions protect more than just LGBTQ clients. As the 11th Circuit explained in Keeton, the university trains students to “be competent to work with all populations, and that all students not impose their personal religious values on their clients, whether, for instance, they believe that persons ought to be Christians rather than Muslims, Jews or atheists, or that homosexuality is moral or immoral.” Licensed professionals are supposed to help their clients, not treat them as prospective converts.

Culture & Conversation Family

Dating Up, Settling Down: Moira Weigel’s Book Details Shifts in Courtship

Eleanor J. Bader

How Americans find partners has changed according to economic prospects, women's changing roles, and social movements.

For decades, the New York Times wedding section has been offering accounts of so-called good matches: pairings that connect people of similar class backgrounds and educational levels, with compatible values, interests, and tastes. While the narratives have become more diverse over the years—the paper now acknowledges same-sex nuptials, for examplethe newspaper’s accounts of how folks met and fell head-over-heels continue to provide an entertaining window into the coupling of America’s lovebirds.

Moira Weigel’s first book, Labor of Love: The Invention of Dating (Farrar, Straus and Giroux) enters this territory, delving into U.S. social mores about dating and marriage. It explores how capitalism has influenced attitudes about women and family, and addresses how economic shifts affect domestic life and intimate relations. Although much of the historical information has been written about before (notably by writers including Elizabeth Abbott, Stephanie Coontz, Kathy Peiss, and Ruth Rosen), Weigel’s easy-to-read overview ties past to present and brings the material into the 21st century. The end result is a fascinating but limited look at trends among mostly white, middle-to-upper class cisgender heterosexuals.

“All human societies, and many animal ones, have always had courtship rituals,” Weigel writes in the book’s introduction. “They have not all had dating. The male, blue-footed booby does a mean mating dance, but he does not date. Neither did Americans until around 1900. Since then, experts have constantly declared that dating was dead or dying. The reason is simple. The ways people date change with the economy.”

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To wit: In the 1890s, a serious economic downturn pushed many young, single women off the family farm and into city-based jobs. By 1900, Weigel reports, more than half of all U.S. women were working outside the home—most commonly in laundries, textile plants, and in domestic service. Because they were paid much less than men, they relied on male suitors to take them out, whether to restaurants, saloons, dance halls, amusement parks, or nickelodeons.

This sometimes caught the attention of the police. Weigel notes that “in the eyes of the authorities, women who let men buy them food and drinks or gifts and entrance tickets looked like whores, and making a date seemed the same as turning a trick.”

The class politics of these encounters were particularly glaring since the upper crust was slow to incorporate dating into its social rites. In fact, “calling” remained in vogue for ladies of leisure until World War I. This required a young woman to decide whether to allow male visitors to see her in the family parlor, albeit with an adult chaperone. After the suitor presented his card, the girl decided whether she wanted to fraternize. If she did, he entered. If not, he was sent away; both scenarios reinforced the idea that men were the seekers and women the sought.

Meanwhile, “charity girls” made it clear that if they accepted a date, the man was responsible for buying them whatever they wanted, from a pack of cigarettes to a meal. By the second decade of the 20th century, however, this practice had not only lost the taint of disapproval, but was consistently described as romantic in novels, short stories, and popular magazines. After all, “nice girls” had shrugged off concerns about the practice and were openly appreciative of the perks that came their way.

By the “Roaring Twenties,” Weigel writes, many working-class women felt free to express an overt interest in dating or marrying “up.” As opportunities to work in department stores, restaurants, and offices expanded, clerks, secretaries, and waitresses could potentially marry the boss or catch a wealthy patron’s eye.

The growing cosmetics industry took advantage of this ideological shift, giving women a way to telegraph “that she valued her femininity and was willing to spend time and money on her appearance.” Alongside frequent magazine articles that described the feminine “beauty duty,” women were told how to market themselves, as if they were products to be consumed by male shoppers.

Any other alternative to heterosexual romance seemed near-impossible, even scorn-worthy, and while a small LGBTQ community was coming into its own in several big cities, homophobia kept the vast majority of individuals from publicly coming out.

Weigel’s nod to queer culture—including bars and clubs catering to gay men, lesbians, and “drag” performances—is brief; nonetheless, the book includes several vivid descriptions of “the secret theater” that allowed LGBTQ folks to be themselves in a few urban settings.

Still, it was World War II that allowed a crack in the closet door. As Weigel writes: “During the war, the armed forces had been eager to enlist recruits, and many young gays and lesbians who felt isolated in their hometowns saw military service as a chance to escape.”

The book says nothing, however, about the many “Rosies” who took to riveting and left me wondering how—or if—their employment affected dating and sexual behavior. Despite this gap, Weigel writes that by the end of the war, straight shop girls, secretaries, and waitresses were sharpening their flirtation skills in order to find a man, leave the workforce, and pursue domesticity.

In addition, college girls followed an equally well-honed script to earn an “M.R.S.” degree. College, as Weigel explains it, gave those with the resources for postsecondary schooling a chance to mingle freely, date openly, and “pet” before marriage. Going “all the way,” however, was explicitly verboten. As popular culture presented it in the early 20th century, female virginity was a woman’s most cherished asset. According to Weigel, “as soon as she married, America about-faced. Not only should a young wife have sex, she should have lots of sex, and she should like it. If you do not like sex as much as your husband, your marriage will not be well-adjusted,” the media warned.

Betty Freidan pinpointed the contradictory messages about sex, marriage, monogamy, work, and love that bombarded middle class stay-at-home wives and mothers decades later when she published The Feminine Mystique in 1963. The critique resonated. But Friedan also had critics. “Because African American women had always worked outside their homes,” Weigel points out, “ever since their ancestors were brought to the United States as slaves, they did not mistake the ‘opportunity’ to work as an adequate solution to all the problems that women had to deal with. … [Black and working-class women] knew that earning a wage was not a fix-all. In fact, many black feminists attested that in their homes was the only place that they felt respite from a racist world.”

A few years later, when the Free Love movement elbowed its way into popular consciousness, many male adherents seemed to forget that women could not legally abort unwanted pregnancies. Needless to say, Free Love did little to change gender roles or equalize gender dynamics. By the end of the 1960s, Weigel notes that hippies began to realize that creating a new world was going to be a lot harder than they had initially anticipated. “They had not clearly established who would do the things that still needed to be done,” she writes. “In the absence of a plan, they often fell back into highly stereotyped gender roles.”

Yuppies eventually replaced hippies and rejected the indiscriminate coupling of the previous generation. What’s more, the advent of AIDS in the 1980s coincided with workforce changes that encouraged telecommuting and longer hours on site. Taken together, these changes have had a marked impact on how we date, whether we date, and how we partner.

In fact, by the 1980s, Weigel reports that many highly educated heterosexual women were pushing to marry their intellectual and social equals. Perhaps more startling, not only did yuppies want to marry other yuppies, they began to see dating as similar to other work. New businesses popped up to accommodate them: speed dating, virtual dating assistants to “manage” their social engagements, and a wide array of dating apps and online services to connect them with a potential Mr. or Ms. Right.

But despite the assistance, all was still not well in Dating Land. Many considered going out with a stranger to be a chore, “less like a pleasurable diversion and more like one more thing to fit in.” Then, as messages about one’s biological clock start to tick, the market in assisted reproductive technologies increased the disquiet. Add in bestselling books like The Rules, Ignore the Guy, Get the Guy, and It’s Not Him, It’s You, and the retro message that every 30-something needs to settle down started to blare. If one listens closely enough, the declaration is unmistakable: No heartbreak can compare to turning 40 and being unmarried and childless.

To her credit, Weigel challenges this absurdity, but Labor of Love never deconstructs the equally damaging idea that every person has a soulmate and needs to find this person in order to be complete. Where this notion comes from remains a mystery. Nonetheless, as the linchpin for most romantic mythology, it deserves an attentive and complete undressing. Likewise, the dating games of nonwhite, working-class and low-income individuals, and religious immigrants need the same attention and scrutiny that Weigel gives to rich professionals.

Furthermore, anyone who has been in a long-term relationship knows that finding a potential mate is merely the starting point. The real labor of love comes long after the initial attraction and centers on the daily work of keeping the relationship going. At the end of the day, dating may have been an invented form of social engagement, but the chase is meaningless if the parties never hunker down in the muck of everyday life.