Last August, while researching a book on contemporary gay rights politics, I traveled to Spain, the country with the longest history of policies intended to make amends for past wrongs against the gay community, otherwise known as “gay reparation.” I wanted to know what made Spain—a country notorious for having burned “sodomites” at the stake during the Inquisition—a pioneer on this new front of LGBT activism. I was also eager to learn how the gay reparation movement had spread so quickly to other countries. In the last decade alone, close to a dozen nations, including the United States, have embraced some form of gay reparation—from financial compensation for those who faced criminal prosecution because of their sexual orientation, to a formal apology to the gay community for past policies of anti-gay discrimination, to the creation of a truth commission to chronicle the history of homosexual repression. And I was curious to gain insight into the puzzling question of why some countries in the West were choosing this particular moment in history to come to terms with a centuries-old grim legacy of state policies intended to humiliate, dehumanize, and even exterminate homosexuals.

While in Barcelona, I interviewed Antoni Ruiz, the president of the Association of Ex-Social Prisoners, an organization that advocates on behalf of the LGBT victims of the dictatorial regime of General Francisco Franco, who ruled Spain with an iron fist from the end of the Spanish Civil War in 1939 until his death in 1975; Ruiz has become something of a father figure for the Spanish gay reparation movement. Under Franco’s Ley de Vagos y Maleantes (Law of Vagrants and Thugs, 1954) and its replacement, the 1970 Ley de Peligrosidad y Rehabilitación Social (Law of Dangerousness and Social Rehabilitation), gays, lesbians, transsexual men and women, and gender and sexual deviants generally were deemed a threat to society and forced to undergo “gay aversion therapy.” According to El País, under these notorious laws some five thousand gays and lesbians were detained and arrested in Spain. In 1976, less than a year after Franco’s death, Ruiz himself—then just seventeen—was sent to prison on suspicion of being homosexual.

Ruiz’s journey to renown as one of Spain’s most effective gay activists began by happenstance. In 1995, while out for a stroll in his hometown of Valencia, a city on Spain’s east coast, two police officers stopped him and asked for his national identification card. When he failed to produce the card (he had left it at home), he was dragged off to the police station. While under interrogation, Ruiz overheard one officer refer to him as a maricón (faggot). The slur caught Ruiz’s attention not because it was offensive but because it revealed something the officer had seen in Ruiz’s file. Ruiz asked to view his file, but was told that he needed permission from the Ministry of Justice. So began a five-year struggle—ultimately successful—to obtain access to his police records.

What Ruiz found in his file floored him: an account of his 1976 arrest, something he thought had been expunged or sealed away. After all, he had been a minor at the time; and since 1978, with the passage of one of the world’s most progressive constitutions, Spain had been a functioning democracy. Ruiz’s arrest was triggered by his refusal to answer questions about his sexuality. The sentence was a week in prison followed by a year in reform school, but he ended up serving three harrowing months behind bars before being released. On his first day at Valencia’s Modelo prison, he was stripped, pushed into a cold shower, sprayed with an insecticide, and injected with an unspecified “vaccine” that left him scared and traumatized. He was also raped after the guards allowed three prisoners into his cell. He also spent time in two other prisons, including Carabanchel, in Madrid, at the time Spain’s largest prison and the most notorious for the sexual abuse of male prisoners. But the trauma was far from over.

After returning home, Ruiz learned the truth behind his arrest. He had come out to his mother, a widow and a devout Catholic; she had mentioned it to her sister, who then mentioned it to a nun, who, in turn, went to the police. The day after he told his mother about his orientation, plainclothes officers woke him at 6 AM, arrested him in front of his family, and took him to the police station. He also learned that his younger brother, then fifteen years of age, had been taken to a convent and questioned about whether he had been sexually molested by his older brother. Learning this about his brother, Ruiz said, caused him the most distress. This whole scenario was sadly typical. In Franco’s Spain, “well-meaning” relatives were in the habit of informing public authorities on homosexuals in the misguided hope that a spell in state custody would cure them of same-sex attraction.

Because of his conviction as a sexual outlaw, Ruiz was unable to secure housing and steady employment. Only the intervention of friends and relatives prevented him from becoming homeless. It was around this time that he began to trace those whom he refers to as “Franco’s gay prisoners.” This led to the creation in 2004 of the organization that he leads today. He eventually folded his activism into the movement for the recovery of the historical memory, an attempt by human rights activists to force Spain to address the atrocities of the Civil War and the Franco dictatorship. Until the mid-2000s, Spaniards had largely willed themselves into political amnesia in the name of consolidating democracy. In 2008, soon after the enactment of the 2007 Law of Historical Memory—which declared illegitimate the institutions of the Franco regime and offered compensation to its victims—the government allocated some 2 million euros ($2.27 million) to fund compensation specifically for the homosexual victims of the Franco regime. This was not an enormous sum, but symbolically it was huge—for the first time in history, a government had agreed to compensate homosexuals for state-sanctioned anti-gay discrimination.

Rather fittingly, in 2009 Ruiz became the first beneficiary of Spain’s gay reparation policy; he received compensation of 4,000 euros. He also received a letter of apology from the Ministry of Justice. In October 2012, a woman identified in court papers only by her initials, M.C.D., filed the first case of a lesbian successfully seeking compensation—this speaks to the stigma and shame that former homosexual prisoners still suffer about their arrest and abuse. M.C.D. was arrested in 1974, also at the age of seventeen. After a trial at which her state-appointed attorney offered no defense, casting her on the mercy of the court, she was sentenced to a maximum of three years in prison and forced to undergo a program of “re-education.” The terms of her compensation settlement are not publicly known.

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Spain’s experience with gay reparation, which relies on individual claims against the state for financial compensation and moral rehabilitation, stands in contrast to the varying approaches embraced by other nations. Britain, for example, has not created any kind of compensation scheme, but in 2016 the government offered a pardon to thousands of gay and bisexual men who had once been convicted of crimes such as buggery, gross indecency, and loitering with intent. These types of discriminatory sexual offenses laws, which remained on the books in parts of the United Kingdom until 2013 (and, as in much of the English-speaking world, applied only to men), were used to convict an estimated 100,000 men; of these, an estimated 15,000 were still living in 2016. Prime Minister Theresa May subsequently expressed regret over Britain’s role in propagating homophobic laws throughout the world via its empire. Speaking at the Commonwealth Heads of Government meeting in London in April 2018, she called on those countries to reform their legal codes. “I am all too aware that these laws were often put in place by my own country,” she said. “They were wrong then, and they are wrong now.”

Britain’s gesture of atonement towards the gay community was set in motion by a petition signed by some half-million people demanding a posthumous pardon and apology for Alan Turing, the World War II code-breaking genius, fifty-five years after he was convicted of “gross indecency” and sentenced to chemical castration. Turing apparently committed suicide two years later, at age forty-one. (His story was told in the 2014 film The Imitation Game). Announcing Turing’s pardon in 2009, then-Prime Minister Gordon Brown noted: “While Turing was dealt with under the law of the time and we can’t put the clock back, his treatment was of course utterly unfair and I am pleased to have the chance to say how deeply sorry I and we all are for what happened to him.”

Among those who signed the Turing petition was the veteran gay rights activist Peter Tatchell, whose eponymous foundation has become the engine behind Britain’s gay reparation movement. Tatchell told me that the easiest first step was to press for a public apology, but the eventual goal is for Parliament to pass a compensation scheme—given the real harms involved. “We are pressing for compensation for men who were prosecuted for consenting adult same-sex acts,” he wrote me via email. “We know the consequences of criminalization—a criminal conviction resulted in fines and/or jail, often the loss of job, home, marriage, and friends; plus depression, anxiety, mental-ill-health, alcoholism, and suicide attempts. This makes compensation worthy and deserved.”

Other parts of the English-speaking world quickly followed Britain’s lead, including New Zealand, Canada, Ireland, and several Australian states. Scotland issued its own apology, in 2017, since the British apology applied only to England and Wales. In the case of Canada, the apology was accompanied by compensation: a payout of $85 million. This followed a report from the Egale Canada Human Rights Trust that chronicled the country’s history of systemic discrimination of LGBT people; the payout was earmarked for victims of the so-called gay purge, an officially sanctioned policy, lasting until the 1990s, that for decades caused thousands to lose their jobs and face prosecution because of their sexual orientation.

Gay reparation developments in Spain and Britain put pressure on Germany to deal with its especially dark history of homosexual repression through the twentieth century. An 1871 provision in the German criminal code that criminalized homosexuality, known as Paragraph 175, was used by the Nazis to carry out a brutal crackdown on homosexuals. According to the United States Holocaust Memorial Museum, from 1933 to 1945 some 100,000 men were arrested and charged with homosexual offenses. About half received ordinary prison sentences, while as many as 15,000 were sent to concentration camps (where they were forced to wear a pink triangle to denote their homosexuality); an unknown number of gay men died in prison from hunger, disease, or deliberate violence.

In 1968, some two decades after the partition of Germany at the end of World War II, the German Democratic Republic in the East rescinded Paragraph 175. But it remained the law of the land in the Federal Republic in the West until 1994, when it was invalidated as part of the process of German reunification. In 2016, the German government vacated all previous homosexual convictions, some four years after all other criminal convictions under the Nazis were expunged. All those once convicted of homosexual offenses who are still alive (some 5,000 as of 2016) can now claim compensation from a fund that has been allocated 30 million euros. The precise amount of any financial reparation is determined by a number of factors, including the length of time the individual spent in prison. “We will never be able to remove these outrages committed by this country,” said Justice Minister Heiko Maas, announcing the payout, “but we want to rehabilitate the victims.”

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Compared to its democratic peers in Western Europe, the United States is a gay reparation laggard. It was only this past June that the movement made any headway in the US, and timidly at that, when the New York Police Department apologized for its conduct that led to the 1969 Stonewall Riots, an event sparked by police harassment of LGBT people that led to the creation of the Gay Liberation Front, widely seen as a precursor to the contemporary LGBT rights movement. To coincide with the uprising’s fiftieth anniversary, NYPD Commissioner James P. O’Neill stated: “The actions taken by the NYPD were wrong—plain and simple… The actions and the laws were discriminatory and oppressive, and for that, I apologize.”

Until then, the closest America had come to offering reparation to gays and lesbians was the Obama administration’s policy of allowing military veterans who had been dismissed from service because of their homosexuality to petition to have their discharges reclassified as “honorable” rather than “undesired.” Yet even this policy was made on a case-by-case basis. Such a limited approach to gay reparation has done little to rectify America’s long history of officially sanctioned oppression and humiliation of its gay citizens, as I noted in an op-ed for The New York Times this past summer.

That history includes President Dwight D. Eisenhower’s 1953 executive order 10450, which called for the expulsion of homosexuals from all levels of the federal government, the so-called Lavender Scare that purged at least 5,000 homosexual men and women (and by some estimates, many thousands more) from the federal bureaucracy, including private contractors and military personnel. The victims were not only forced out of their government jobs, but were also forced out of the closet—thereby destroying both their professional and personal lives. Among the better-known victims of the Lavender Scare was Frank Kameny, a military veteran and Harvard-trained astronomer who was fired from the Army Map Service in 1957. He challenged his firing in the courts, appealing it all the way up to the Supreme Court, which ultimately turned down his petition. After his firing, Kameny was unable to find employment; instead, he devoted his life to fighting for the civil rights of homosexuals.

Executive order 10450 remained in effect until President Bill Clinton rescinded it in 1995. During the years it was in force, the order ushered in a host of other initiatives, court orders, and state legislation that demeaned and demonized the LGBT community for decades, among them: “Save Our Children,” a 1977 crusade led by country music singer Anita Bryant that succeeded in overturning an anti-gay discrimination ordinance enacted by Dade County, Florida, by branding gay males as predators and pedophiles; Bowers v. Hardwick, a Supreme Court decision that upheld anti-sodomy laws (a decision not overturned until 2003, with Lawrence v. Texas, making the US one of the last democracies in the West to fully decriminalize homosexuality); and “Don’t Ask, Don’t Tell,” the infamous 1993 law that allowed homosexuals to serve in the armed forces provided that they kept their sexual orientation a secret. By the time DADT was repealed by the Obama administration, in 2011, it had led to the dismissal of some 13,000 service members, including medical doctors, fighter pilots, and Arabic translators and interpreters.

Another legacy of Eisenhower’s executive order was that it enabled a powerful anti-gay rights movement led by the Christian Right. The movement created a moral panic about same-sex marriage that succeeded in enacting some thirty state constitutional amendments banning same-sex marriage from 1998 to 2012, most of them by referendum. The most infamous of these amendments was California’s Proposition 8, which invalidated thousands of same-sex marriages overnight. For decades, the Christian Right has also championed “gay conversion therapy,” which uses biblical teachings to eradicate unwanted same-sex attraction. By one account, some 700,000 Americans have been exposed to a therapy that the American Psychological Association has deemed harmful to the mental well-being of homosexuals, including increasing the risk of suicide.

To delve deeper into why gay reparation faces such an uphill struggle in the United States, last August I caught up with Charles Francis, president of the Mattachine Society of Washington, D.C., an organization that takes its name from the pre-Stonewall era organization that campaigned for tolerance toward homosexuals. A former Republican public affairs consultant who grew disenchanted with his party’s hostility toward gay rights, Francis devotes much of his time to getting the gay reparation movement off the ground in the United States. As a prelude to compensation, Francis’s organization is exploring a formal acknowledgment and apology for the decades of discrimination, investigations, firings, and forced conversion therapy at government psychiatric facilities, such as St. Elizabeths Hospital in Washington, triggered by Eisenhower’s executive order.

I spoke with Francis about the resistance in American history to almost any kind of reparation, with the eventual compensation of Japanese-Americans for their World War II internment being a rare exception. We also discussed the way in which the unsettled debate about slavery reparations makes other claims for reparations seem less pressing and important, and whether that helps explain the apparent lack of interest in issues of restorative justice among mainstream American gay rights organizations, such as the Human Rights Campaign. Ultimately, however, we agreed that the most significant opposition comes from the Christian Right, historically the political gatekeeper blocking the advance of gay rights in the US. I had seen some measure of this opposition in a response from the influential rightwing blog Red State to my Times op-ed. It asked, “To what group should we atone for our shameful behavior next? The obese, the disfigured, the disabled, the short, the bald?”

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Why some countries are coming around to making amends to the homosexual community is far from clear. After all, gays and lesbians are among the most consistently despised minorities in the history of the West. Certainly, we are living in the so-called age of apology: in recent decades, governments have sought to make amends for all kinds of past failings and oppressions. The Irish government has attempted to atone for sending unmarried women and illegitimate children to inhumane state-run institutions. The Argentine Catholic Church has apologized for its complicity in the Dirty War of the military dictatorship of the 1970s and early 1980s. And the Canadian government has expressed regret for policies that separated indigenous parents from their children, whom it placed in institutions that erased their languages and cultures.

It is also the case that gay reparation reflects the maturation of the gay rights movement. It is no accident that gay reparation policies have arrived in the wake of numerous gay rights victories, most notably the legalization of same-sex marriage in some two dozen nations. These victories have had a two-fold effect in facilitating the rise of gay reparation: significantly advancing the normalization of homosexuality while at the same time allowing gay activists to shift their attention from demanding new rights to redressing past wrongs.

Still less clear is why nations differ in their approach to gay reparation. But it appears that this owes more, in each case, to the state of a particular country’s domestic struggle for gay rights and how this struggle is framed than to any standardized or universal measure of the effects of homosexual oppression, such as the number of victims. From that perspective, it is not surprising that Spain would be a gay reparation pioneer and the United States a laggard. In 2005, Spain and Canada became only the third and fourth countries in the world to allow homosexual couples to wed (after the Netherlands and Belgium), and the first one to grant homosexual couples all the rights and responsibilities of marriage, including adoption. Spain has also been a global leader on transgender rights and reproductive rights for same-sex couples. Less apparent is that Spain’s gay rights campaign went beyond the minimal agenda of demanding equal rights for the LGBT community. In particular, the Spanish same-sex marriage campaign was presented as an argument for full citizenship rather than for marriage rights. This broad framing enabled a deepening of LGBT rights while paving the way for addressing past injustices toward the LGBT community.

Despite the overwhelmingly positive press the United States gets on its LGBT advances, the contrast with Spain is striking: although same-sex marriage finally arrived nationwide in 2015 (imposed by the courts), in many other areas of American life, LGBT rights are either weak or under attack. According to a report in The Washington Post, based on data collected by the American Civil Liberties Union, since 2013, legislatures across the US have introduced 348 bills, twenty-three of which have become law, that could limit LGBT rights; and there has been a steep increase in such anti-gay rights legislative efforts in the years since gay marriage was legalized. Under the Trump administration, the Department of Justice has taken the position that existing civil rights legislation does not protect against anti-gay discrimination. The Trump administration has also barred transgender people from serving in the armed forces.

At least when compared to the Spanish experience, the struggle for same-sex marriage in the United States failed to engage the public into a larger debate about the history of homosexuality in the country and about the contributions of LGBT people to society today. To the detriment of the LGBT community, the movement for marriage equality stuck to narrow legal arguments about the need to grant marriage rights and benefits to homosexual couples. In the process, activists made the LGBT movement virtually synonymous with the marriage rights movement. One price of that victory has been to leave intact and largely unexamined the long history of anti-gay animus, discrimination, and homophobia in American culture.