JOSHUA PALKKI
Georgia Institute of Technology
JUSTIN CAITHAML
DePaul University
SHAWN KIMBREL
Arizona State University
May 2026
Published in Action, Criticism, and Theory for Music Education 25 (3): 13–55 [pdf]. https://doi.org/10.22176/act25.3.13
Abstract: In 2023, The Heritage Foundation released the Mandate for Leadership document, commonly referred to as the “Project 2025 Report,” which outlined a conservative policy agenda for a potential Republican administration (Dans and Groves 2023). Drawing on the work of discourse theorists Fairclough and Fairclough (2012), who argue that language shapes social reality, and Butler (2024), who explores how constructed harms maintain systems of power, this study critically examines the report’s education chapter. Using Critical Feminist Discourse Analysis (CFDA; Sunderland and Litoselliti 2002) alongside Butler’s (2024) concept of a gender phantasm, we coded and analyzed key rhetorical patterns. We present our findings through three thematic categories suggested by Sunderland and Litoselliti (2002), revealing how gender and power are discursively constructed. We conclude with a discussion of the implications for music education and issue a call to action for scholars, preservice and in-service teachers, and professional music education organizations.
Keywords: Discourse analysis, divisive concepts laws, policy, trans and gender-expansive learners
“With a bit of imagination, nothing can be truly anomalous” (Gould
1996
, 128)
In 2023, the Heritage Foundation released a document called Mandate for Leadership: The Conservative Promise, known colloquially as the “Project 2025 Report,” outlining a conservative agenda for a potential Republican administration (Dans and Groves 2023). Report authors proposed sweeping changes to government agencies, regulatory policies, and social programs, emphasizing executive power, deregulation, and so-called “traditional values.” Utilizing critical policy analysis and Butler’s (2024) notions of gender ideology, we examined the “Department of Education” chapter of this document (Burke 2023) and explored what impact its implementation could have on music education. Although a complete policy analysis of Mandate for Leadership (Dans and Groves 2023) is warranted, we limited our analysis to the chapter on education, as its impacts on music education are the most immediate and direct.
Current Socio-Political Context
When we began this work in the form of a conference proposal, we hoped that writing this paper would simply be an interesting intellectual exercise. We hoped that we would be working on this paper in the context of a Harris-Walz administration continuing the policies of the Biden-Harris and Obama-Biden administrations that sought to protect queer youth in US public schools, namely through the expansion of Title VII[1] and Title IX[2] to protect trans and gender-expansive (TGX) people (e.g., Stern 2021). Instead, we are living through a barrage of assaults on public education and TGX people from the current presidential administration that is enacting many of the ideas from the chapter that we analyzed (Cruz et al. 2025).
The actions of the 47th presidential administration attempt to silence rhetoric that runs contrary to executive initiatives. At the time of this writing, a rash of anti-LGBTQA[3] legislation has been introduced across the United States (ACLU 2025; Trans Legislation Tracker n.d.), and some of these bills restrict student and educator rights (ACLU 2025). TGX individuals, in particular, have come under direct attack with a number of executive orders banning them from military service (Exec. Order No. 14183, 2025) and women’s sports (Exec. Order No. 14201, 2025), and blocking gender-affirming healthcare for trans youth (Exec. Order No. 14187, 2025). The 47th president’s administration has taken action to silence institutions that promote learning and cultural diversity. Following his purge of eighteen Democratic appointees and top Kennedy Center officials, the 47th president was named Chairman of the Kennedy Center (Ulaby 2025). Since then, the Kennedy Center cancelled LGBTQA Pride events that were part of the World Pride festival in Washington D.C. (Khalil 2025). Similarly, the Smithsonian Institution is closing its diversity office (Vanasco and Blair 2025) and the National Park Service removed the words “transgender” (Haigh 2025) and “bisexual” (Macieira-Fielding 2025) from the Stonewall National Monument in New York City. This is erasure, and it is happening at national and local levels.
The actions of the 47th president’s administration are part of larger discourses about equity and justice issues in US schools, and these discourses have direct implications for education. For example, book bans have been written into legislation across the country (Grote-Garcia and Ortlieb 2024), and bills restricting so-called “Divisive Concepts” are influencing what topics teachers can discuss in the classroom (e.g., Stitzlein 2022). PK–12 schools and universities continue to erase trans student athletes from school sports (e.g., Redfield 2025). Across the country, state legislatures continue to consider and pass anti-trans legislation with impacts for US schools; in 2025, 1,020 such bills were considered at the state level and 125 passed (Trans Legislation Tracker n.d.). These legislative developments have made supporting TGX students increasingly unsafe for educators.
Music organizations and music educators are not exempt from the fear and erasure inspired by this anti-TGX discourse. Part of the aforementioned Kennedy Center cancellations included performances of the Washington Gay Men’s Chorus (Salazar 2025) and the International Pride Orchestra (Khalil 2025). In recent years, music educators have grappled with Divisive Concepts Laws (DCLs), which Salvador (2023) defined as “legislative and executive orders that seek to restrict teaching, professional learning, and student learning in K–12 schools and higher education regarding race, gender, sexuality and US history” (5). DCLs at the state and federal level also impact music classrooms (Bylica, Hawley, and Lewis 2024; Salvador 2023; Salvador, Bohn, and Martin 2023) and draw from the same conservative ideologies and philosophies that undergird the Project 2025 report. For example, music educators wanting to use a student’s name and pronouns in public-facing documents like concert programs are facing backlash from both parents and administrators (Bylica, Hawley, and Lewis 2024). DCLs inspire fear in the adults meant to care for US students: “Teachers are frightened and are afraid to mention anything that could be viewed as divisive with no guidance on what that means” (Bohn 2023, 25). This ambiguity is the very foundation of Burke’s (2023) chapter.
In this paper, we interrogate the Heritage Foundation’s discourses about education and explore how these discourses (and their potential or actual implementation) could impact the music education profession. Music educators and music education scholars who disagree with the Heritage Foundation’s rhetoric and policy recommendations could draw upon the Advocacy Coalition Framework, “a system in which coalitions of actors with different belief systems interact and compete to dominate policy subsystems” (Cairney 2016, 485), to seek like-minded stakeholders in navigating the complexities of the current sociopolitical climate.
Such coalition building, however, can be co-opted by a series of other actors with the opposite impact. Butler (2024) noted that:
Those who fear gender know that it holds out a promise of freedom, a freedom from fear and discrimination, homophobic violence and murder, femicide, incarceration, restriction from public life, failed health care, either permitted or enforced by expanding state powers. The vision of alliance and empowerment required to defeat these toxic phantasms installed in policy, platform, and policing will be one that artists help us to make, a form of imagining that emerges from gatherings authored by no one, the ones already alive, and whose promise strikes fear into the hearts of those who would impose their reactionary politics through state powers, including violence. (244)
In addition, we recognize Butler’s (2024) specific mention of artists in their observation above as an endorsement of the power of the arts in times of strife. While a “crisis of standardization” (Allsup 2016, 110) has limited some creative efforts in music education over the past decade, we argue that creativity is a necessary addition to creating alliances and empowering individuals to fight back against the gender phantasm that, we posit, is actively causing harm. To that end, music educators can utilize both a vision of alliance through the work of Sabatier’s (1993) Advocacy Coalition Framework (Cairney 2016; Sabatier 1993) and a vision of empowerment through the work of Emejulu’s (2022) Fugitive Feminism.
The Heritage Foundation
To contextualize the suggestions in the Project 2025 report, it is important to understand the organization from which it comes. As Fairclough (1992) wrote, “Discourse contributes to the constitution of all those dimensions of social structure which directly or indirectly shape and constrain it: its own norms and conventions, as well as the relations, identities and institutions which lie behind them” (64, emphasis added). The Heritage Foundation is a Washington D.C.-based conservative think tank advocating for policies promoting free enterprise, limited government, and undefined “traditional values.” The Heritage Foundation (n.d.) website outlines three main priorities: “(1) Providing Solutions—researching, developing, and promoting innovative solutions, (2) Mobilizing Conservatives—uniting the conservative movement to work together, and (3) Training Leaders—preparing future generations who will lead America.” The author of the Department of Education chapter is Lindsay M. Burke, who has championed education policy that minimizes federal bureaucracy and maximizes parental choice and local accountability, advocating for elimination of the US Department of Education, the shift of federal funds to state-controlled school choice mechanisms like Education Savings Accounts, and the prioritization of conservative values over federal mandates.
Corredor (2019) noted that anti-gender campaigns require vast coordinated resources to protect traditionally valued roles of gender, sex, and sexuality. The Heritage Foundation is among these well-resourced actors, with a 2022 annual revenue totaling $106 million according to ProPublica (n.d.)—76% of which comes from individual donors (Heritage Foundation n.d.). The Project 2025 report is not theoretical. At the time of this writing, several suggestions from the report have been implemented by the 47th president and his administration (e.g., Cruz et al. 2025): “A side-by-side review by POLITICO found dozens of cases where the president’s early executive actions have aligned with portions of the 922-page policy document, including some instances with nearly verbatim language lifted from the report to the White House” (para 2, emphasis added). For example, Table 1 compares language regarding gender diversity from the Project 2025 report and a federal executive order.
| Project 2025 | Executive Order 14168 |
| Commence a new agency rulemaking process to rescind the current Administration’s Title IX regulations … and define “sex” under Title IX to mean only biological sex recognized at birth. (Burke 2023, 333) | It is the policy of the United States to recognize two sexes, male and female. These sexes are not changeable and are grounded in fundamental and incontrovertible reality. (The White House 2025, para. 5) |
Table 1. Comparison of language from the Project 2025 Report vs. Executive Order 14168.
Any claims that the 47th president is/was unaware of Project 2025 seem highly unlikely.
Positionality
Each of us, as authors, come to this research with a variety of identities that have influenced our analysis. As Sunderland and Litosseliti (2002) noted, “Critical discourse analysts explicitly acknowledge the impossibility of impartial observation—for all analytical approaches. If language choices are sociologically and ideologically shaped, then analysts’ own understandings and interpretations are also inextricably partial” (21). We approach this work as white, highly educated, queer scholars who all work in higher education in the United States. Joshua and Shawn identify as white and queer and use he/him pronouns. Justin identifies as white and non-binary and uses they/them pronouns. While Justin’s gender identity is directly targeted by the rhetoric in the Project 2025 document,[4] they write from a position of relative privilege as someone who can be perceived as male. They align with the worldview of Alabanza (2022) that they “don’t want to start with all the things taken from [them] by being gender non-conforming: [they] want to contemplate what has been granted [them] instead” (128). As authors, we frame our positionality not as queer identities to be tokenized in relation to our work, but as identities that expand and enrich our analysis. We concur with Alabanza (2022) that “Living in the accepted reality of both the gender binary and the transphobia that inherently follows, we lose our imagination of what a world without sacrifices to our personhood could look like” (165). By purposefully interrogating our positionalities, we seek to rekindle our collective imagination for a world free from violence—real or phantasmic—against LGBTQA and TGX identities. We believe that a more expansive worldview is possible when the societal construct of gender has transcended a limiting binary (Alabanza 2022).
Therefore, our various identities, including our political inclinations, shaped our views on this analysis and recommendations. We all share a deep concern for the rising tide of populist authoritarianism in the US at the time of this writing, which is having a direct and deleterious impact on TGX people—our queer brethren. We aim to use our LGBTQA positionality and privilege to bring attention to the very real harm caused by the implementation of the Project 2025 report in US education spaces. We are clear-eyed about the fact that our claims are not neutral or merely informative. To make such a claim would ignore the core tenets of critical feminist discourse analysis (Sunderland and Litosseliti 2002), especially those related to how covert language choices reinforce notions of power.
Conceptual Framework
The conceptual framework for our study combines two constructs, one philosophical (Butler 2024) and one methodological (Fairclough and Fairclough 2012) in dialogue with one another. First, we ground our work in Butler’s (2024) conception of modern gender discourse as needing to fight a “phantasm”—an artificial fear that has been constructed through a variety of means—socially through media discourse, politically through legislative hearings and written policy, as well as other forms. Butler (2024) wrote, “the word ‘gender’ apparently itself casts a spell, and so anything associated with the word must be dispelled” (27). Further, Butler (2024) observed that the construction of this phantasm involves the denial of any concept outside of the dominant, heteronormative perspective. Butler wrote that: “denial of human possibilities becomes, paradoxically, a requirement of normative selfhood under such conditions, and so these lives over there, they are living out what has been established as unthinkable for oneself. To make them unthinkable means that they cannot be imagined, so when they do appear, they appear as phantasms with the power to destroy a heteronormative self anchored in a primary sex assignment that has grounded itself on their denial” (253). Organizations like the Heritage Foundation advocate for laws and policies that would deny TGX rights—often couched in inflammatory rhetoric designed to inspire political support (Crasnow 2021).
Burke (2023) framed “gender theory” as violating “parental rights” (344), illuminating the panic that those on the US political-right feel about the concept—and even the word—gender. Butler (2024) noted that terms like gender “are blamed for the very disorienting fears that many people across the world now feel about the future of their ways of life. For gender to be identified as a threat to all of life, civilization, society, thought, and the like, it has to gather up a wide range of fears … and subsume them under a single name” (5). More broadly, Butler asserted that anti-gender rhetoric is a proxy for anti-critical inquiry: “the opposition to including books on gender in schools and universities, the new efforts to expunge the curricula of such topics, rests on a certain distrust of reading and its capacity to open the mind to new possibilities” (20). Butler’s notion of gender rhetoric as a phantasm thus became part of the theoretical grounding of this analysis.
While Butler’s (2024) work is rooted in the creation of a phantasm around gender, Fairclough and Fairclough (2012) articulated the political layers of discourse and what happens when certain words or phrases are operationalized. Operationalization could mean discourse has been “enacted as new ways of acting and interacting,” “inculcated as new ways of being (new identities),” or “physically materialized” (84). By adding these forms of operationalization to our conceptual framework in conversation with Butler’s (2024) conception of a phantasm, we sought to bring clarity to the nuances of how much power exists in the discourses that make up the Project 2025 Education chapter, and in what ways. For example, is Burke’s (2023) political discourse referring to interaction between stakeholders (enactment), or is it focused on articulating a completely new way of being (inculcation)? We posit that putting Butler (2024) and Fairclough and Fairclough (2012) in conversation with one another can bring clarity to the ways that words can be leveraged in various contexts. We align this dialogue with the observations of Beauchamp (2018), and strove “to unravel the ways that terminology … can turn against us” (30).
Our theoretical framework (Butler 2024; Fairclough and Fairclough 2012) is directly connected to the choice of critical (feminist) discourse analysis as method of analysis because this approach allowed us to identify and deconstruct the phantasmic elements of current discourse around gender in education in an effort to better equip music educators to support TGX students throughout the 47th president’s term. We sought to understand the language patterns present (Fairclough and Fairclough 2012) in the education chapter of the Project 2025 document (Burke 2023). The connection between framework and method is grounded in Butler’s (2024) observation that “we must distinguish between actual harms and those that grip the imagination as imminent possibilities, manufactured by those in the business of inciting hatred. But we cannot learn how not to cause harm if freedom itself is regarded as harm, or if we become convinced that struggles for equality, freedom, and justice are hurting the world” (260). We seek to distinguish between actual harm and manufactured, phantasmic harm and propose implications of this process for the music education profession.
The worldview we hold as authors is reflected in our analysis and recommendations. We do not, however, believe that all students in music programs support gender diversity and the rights of TGX students or that all music educators support TGX students. US music classrooms are made up of groups of students with differing perspectives and worldviews, situated in unique school, district, community, and state-level contexts. We acknowledge our perspective as scholars in imagining a US music education landscape that is more inclusive of gender diversity.
Method of Analysis
As exemplified by the Project 2025 report’s title, Mandate for Leadership: The Conservative Promise, the document is inherently political. As noted earlier, our analysis specifically focuses on Burke’s (2023) “Department of Education” chapter. Engaging with this text required a research design that would allow us to negotiate the discordant values of the authors and those of Burke. During this negotiation, we continually faced ideas that are in stark contrast to our worldviews—a process that was challenging emotionally—evoking a notion that Wozolek and Carlson (2023) refer to as queer battle fatigue. Our sustained analysis of this chapter allowed us to recognize our own lenses and biases and to examine the assumptions behind Burke’s arguments. We employed tenets of critical (feminist) discourse analysis (CFDA), which allows for analysis of overt and covert language patterns that are directly associated with gendered language (Sunderland and Litosseliti 2002) and feminism (Lazar 2005), interweaving our theoretical and methodological framings. CFDA necessarily problematizes power relations and “is concerned not only with social injustice, inequality, power and power struggles, but also with exposing the often subtle role of discourse in the construction and maintenance of injustice, inequality and domination” (Sunderland and Litosseliti 2002, 19). This method is directly connected to our conceptual framework and the source of data for the study, given the often subversive and implied meanings present in language espoused by the Heritage Foundation and DCL legislation (Burke 2023; Sunderland and Litosseliti 2002). As Fairclough and Fairclough (2012) noted, “Re-describing or re-framing reality in a rhetorically convenient way is part of a strategy of action” (93). Burke’s (2023) chapter can certainly be read as a call to action for US conservatives (Crasnow 2021; Cruz et al. 2025).
We organized our codes using three main elements of CFDA outlined by Sunderland and Litosseliti (2002): “(a) recurring lexical items (e.g., ‘sexist’ language…), (b) lexical absences… and (c) ‘one-off’ words or phrases salient in content” (22). Recurring lexical items are words, phrases, or ideas that are repeated throughout the text. Lexical absences refer to the intentional or conspicuous omission of a certain word, phrase, or idea, which may result in varying impacts. For example, Burke (2023) uses binary language, such as “male and female students” and references medical and social gender transition but never uses the word “transgender.” One-off words and phrases occur only once in the document and often have socially or emotionally charged connotations (e.g., “woke ‘diversicrats’” and “illiberal chill”).
Employing Sunderland and Litoselliti’s (2002) elements of CFDA, we undertook several rounds of individual coding and debriefed after each round. We used the qualitative data analysis software ATLAS.ti to collaboratively code, review, and analyze. We began with a round of eclectic exploratory coding, combining elements of descriptive, in-vivo, and concept coding (Saldaña 2013). We organized our inductive list thematically and applied Sunderland and Litosseliti’s (2002) three elements of discourse analysis (recurring lexical items, lexical absences, and one-off words or phrases) to collapse and group this initial list of codes into broader themes. Then, two members of the team re-coded the chapter using this provisional code-book, adding new codes as needed. Our third collaborator reviewed, consolidated, and re-categorized the codes. The research team reviewed the final codes for internal agreement before final analysis.
Findings Recurring Lexical Items
Within the chapter, there are several repeatedly referenced concepts, terms, or phrases (i.e., recurring lexical items). We detail those most closely related to Butler’s gender phantasm in Table 2.
| Code | Frequency |
| Parental rights | 29 |
| Gender ideology | 10 |
| Title IX | 12 |
| Use of “Scare Quotes”a | 14 |
| Radicalism and Special-Interest Groups | 14 |
| Diversityb | 6 |
| CRT (or Critical Race Theory)c | 8 |
| DEI (or Diversity, Equity, and Inclusion) | 5 |
a The term “scare quotes” are defined by Doose (2019), on behalf of the Modern Language Association, as a means to “convey an ironic, skeptical, or even derisive stance toward the word or phrase they enclose” (para 1).
b Diversity, for this code, refers specifically to non-identity uses of diversity, generally in relation to intellectual and educational opportunity diversity. When diversity is used in the context of identity and DEI, that text is coded only as DEI.
c We use Critical Race Theory and the acronym “CRT” interchangeably throughout the document.
Table 2. Excerpted recurring lexical item codes.
We observed that Burke’s (2023) choice of language occasionally contained several of our recurring lexical item codes within a single sentence. Notably, the author conflated gender ideology, CRT, and DEI: “The next President should issue a series of executive orders requiring: An accounting of how federal programs/grants spread DEI/CRT/gender ideology” (358). This commingling indicates that Burke did not discern a difference between these terms—or that each of these phrases holds the same level of phantasmic harm. We argue that such rhetorical construction contributes to a greater phantasmagoria. Butler (2024) described this saying, “this sliding from one topic to another belongs to the metonymy of the phantasmatic scene that lets associations take precedence over what we might still call ‘facts’” (256). Below, we describe the rhetorical instances of several recurring lexical items in further detail.
Parental Rights
Nods or direct references to “parental rights”—a phrase that has several accepted definitions in global and disciplinary contexts—appeared twenty-nine times in Burke’s (2023) chapter. “Parental rights,” as a global framework, is established by the United Nations (1948) Universal Declaration of Human Rights: “Parents have a prior right to choose the kind of education that shall be given to their children” (Article 26, para. 3). Such language (e.g., “parents’ rights” and “parents bill of rights”) is used in neutral procedural settings across the public education sphere and maintains a civil connotation in many settings. However, the American conservative right has adopted this language and dubbed it the “New Parent’s Right Movement,” to distinguish it from earlier less radical/political efforts, and sought to disrupt over a century of educational law and policy, which would then allow “some parents to impose anti-egalitarian values broadly within public schools” (Bowman 2024, 435). For example, Burke (2023) praised several states that enact Parents’ Bill of Rights legislation originating from conservative ideologies (such as Colorado House Bill 20-1144). Proponents of “anti-woke” state legislation (Schoorman 2024) frame gender, sexuality, and race using terms like “freedom” and “parental rights” (Giles 2024) that often mask the true intent of these policies—to dehumanize and deny the personhood of TGX individuals.
Burke advocated for a federally legislated “Parental Bill of Rights,” which contradicts her assertion that “federal education policy should be limited” (2023, 319). Proponents of these so-called “Parents’ Bill of Rights” bills represent, as Fowler and Mountz (2024) noted, a “broader legislative mission aimed at protecting parents’ rights and introduces central symbolic indicators that rhetorically frame the legislation: rights-based language is centerstage, violence-invoking rhetoric of assault and protection operatively relate to the parents—not children—as the primary recipients (and likely constituencies) of concern” (28). Burke (2023) asserted that parents should be allowed to choose the school their child attends (including private and charter schools) and these schools should be funded with public monies. Further, Burke (2023) suggested that parents should have the ability to review and authorize all learning experiences for their child, and that no part of a child’s life at school should be private. This posture of surveillance under the guise of student safety is inconsistent with the inherent rights of TGX students who, we posit, are entitled to autonomy and privacy regarding their identity. Burke’s argument is that the safety of TGX students is less important than the religious ideals of adults in public schools. For example, Burke (2023) wrote, “No public institution may require an education employee or contractor to use a pronoun that does not match a person’s biological sex if contrary to the employee’s or contractor’s religious or moral convictions” (346, emphasis added). Following this logic, Burke (2023) argued that protecting the “religious or moral convictions” of an adult would take precedence over the well-being and safety of TGX youth.
Burke’s policy suggestions regarding parental rights contradict scholarship in various fields, including education (Mols, Campos and Pridmore 2023), philosophy (Lone 2021), law (Dailey and Rosenbury 2021), public policy (Melton 1983), and developmental science (Levesque 2016). Parentally enacted surveillance functions as censorship in schools and places professional educators under intense scrutiny based on family ideologies rather than research-based practices in education (Bylica, Hawley, and Lewis 2024). Furthermore, this surveillance of TGX students—particularly policies that compel schools to disclose a student’s gender identity to parents without the student’s consent—not only places young people at risk of harm in unsupportive home environments but also stands in direct contradiction to established legal precedents. Such mandates undermine protections guaranteed under Title VII of the Civil Rights Act of 1964, which prohibits discrimination based on sex (and, by extension, gender identity, as clarified in Bostock v. Clayton County, 2020), and Title IX of the Education Amendments of 1972, which prohibits sex discrimination in federally funded educational programs, as well as the First Amendment rights of students to privacy, free expression, and freedom from compelled speech. By forcing educators into the role of enforcers of surveillance, these policies erode the trust necessary for effective teaching and learning and risk positioning schools in violation of federal constitutional and statutory protections.
Burke (2023) situated this censorship in a contradiction, noting that “education freedom and reform… will shine brighter when regulations and red tape from Washington are eliminated” (320). Burke (2023) continually argued that parental rights and their religious beliefs reign supreme—for example: “The federal government could demand that schools include curriculum or lessons regarding critical race or gender theory in a way that violates parental rights, especially if it requires minors to disclose information about their religious beliefs, or beliefs about race or gender in violation of the Protection of Pupil Rights Amendment[5] (20 USC Sec. 1232h)” (342, emphasis added). Burke’s (2023) framing of religious freedom versus “regulations and red tape from Washington” (320) and “[violating] parental rights” (344) implies a clear hierarchy—that the “religious or moral convictions” of one group is more important than the safety and comfort of another group (Crasnow 2021).
As noted above, Butler (2024) shared that the very notion of the word “gender” now encompasses other implied meanings, as evidenced by several of Burke’s (2023) suggestions. Parents’ Bill of Rights legislation, per Burke (2023), would require educators to disclose any knowledge of a child’s sexuality or gender identity to the child’s parents and would not require educators to acknowledge asserted names or pronouns if they conflict with an educator’s personal values or religious beliefs. Burke supports the narrative of phantasmic harm by referring to the increase of trans people seeking medical care for gender transition, referring to this increase as a “social contagion” (345). Further, Burke stated that, “under the Biden Administration’s proposed Title IX regulations, schools could be required to assist a child with a social or medical gender transition without parental consent or to withhold information from parents about a child’s social transition (e.g., changing their names or pronouns). The federal government could demand that schools include curriculum or lessons regarding critical race or gender theory in a way that violates parental rights” (343–44). While some state laws and policies (such as those from California and New Jersey that Burke chastised) would indeed support a TGX child’s social transition at school, to say that public schools have anything to do with medical transition is, we posit, simply panic-inducing rhetoric—and another manifestation of the phantasm.
Discourses seeking to restrict classroom curricular content directly affects faculty and students by shaping what can be taught and, in many cases, threatening student well-being. Some professors and teachers benefit from contractual provisions safeguarding academic freedom and some are in a far more vulnerable position. Legal scholars have discussed the potential impacts of related state legislation on legal precedent and student well-being. Giles (2024) noted, “if legislatures across the United States continue codifying these bills, their implementation could have dangerous impacts on public school students” (1188). For example, a 2023 bill in Iowa restricts instructional content on gender identity and sexual orientation in grades K–6 and requires school administrators to “out” TGX youth to their parents if they request to use their real name and pronouns at school (McFetridge and Fingerhut 2023). As this Iowa law demonstrates, TGX youth are actively being harmed as a result of the current political climate, and not just in the phantasmic sense. Consider, for example, the dramatic 33% uptick in calls to the Trevor Project’s suicide hotline—aimed crisis/suicide prevention for LGBTQA youth—following the inauguration in January 2025 (Migdon 2025).
Title IX
Title IX is a US federal civil rights law, enacted in 1972, that prohibits sex-based discrimination in education programs or activities receiving federal financial assistance. Under the Biden administration, the protections under this law were expanded to interpret “on the basis of sex” to also include sexuality and gender identity (Rogers 2021)—a change that Burke (2023) claimed has “no scientific or legal basis” (333). Burke (2023) referenced Title IX at least sixteen times, including references like, “on its first day in office, the next Administration should signal its intent to enter the rulemaking process to restore the current Administration’s Title IX regulation, with the additional insistence that ‘sex’ is properly understood as a fixed biological fact” (334). This framing of sex “properly” being understood as a “fixed biological fact” has been refuted by several gender scholars (e.g., Garofalo and Garvin 2020) and draws upon the fallacy that “asserting the right to one’s own sex requires that others lose theirs” (Butler 2024, 9). This is a common theme in the Department of Education chapter. For example, Burke (2023) wrote, “With its Notice of Proposed Rulemaking published on July 12, 2022, the Biden Education Department seeks to gut the hard-earned rights of women with its changes to the department’s regulations implementing Title IX” (332). Whereas discourses of Title IX reference something concrete (the statute’s text), Burke (2023) employed other gender-related terminology that is far more amorphous and opaque.
Gender Ideology
Burke (2023) never defined the terms “gender ideology” and “gender theory,” evoking the phantasm described by Butler (2024), who wrote: “The contradictory character of the phantasm allows it to contain whatever anxiety or fear that the anti-gender ideology wishes to stoke for its own purposes, without having to make any of it cohere” (16). Furthermore, Burke’s (2023) use of terms like “gender ideology” seemingly become imbued with immense fear. As Butler (2024) noted, “The [anti-gender ideology] movement taps into a sense of a world on its way to immolation and incites that fear to rally support for its ‘moral’ plan for destruction…. The movement finds, stokes, and organizes that fear wherever it can” (249). Sunderland and Litosolliti (2002) discussed “Foucault’s stress on the importance of timeliness in the emergence of a ‘new’ discourse relevant both to contemporary discourses such as ‘feminist’, ‘anti-racist’ and ‘environmentalist’ discourses” (10). Because discourse is constantly evolving, it is imperative that scholars and practitioners alike continue to scrutinize the way that gender-related terms are used in the educational context.
The use of “gender ideology” and “gender theory” to vilify TGX people who, despite the best efforts of organizations like the Heritage Foundation, are not going away and have always been part of society, is a Trojan horse. Burke (2023) evoked such vilification when she wrote that: “research from the Claremont Institute used documents provided by a whistleblower demonstrating how educators at Department of Defense schools around the world are using radical gender theory and critical race theory in their lessons. This instructional material discards biology in favor of political indoctrination.…” (348). Classifying the amorphous term “gender theory” (which Burke never defined) as “radical” and resulting in “[discarding] biology in favor of political indoctrination” assumes that gender identity is not an identity, but a “political” project that flies in the face of science (in this case, biology). Operating under the guise of safety in order to rise to prominence in an overly saturated media ecosystem, authors like Burke (2023) are, in essence, targeting a small subset of the population to exert control over an already marginalized population—namely TGX youth (Christensen et al. 2023).
Burke (2023) repeatedly employed the phrases “gender ideology” and “gender theory” to advocate for policies such as those related to Title IX and parental rights—illustrated in a call for an accounting of how much the government spends on “federal programs/grants [that] spread DEI/CRT/gender ideology” (358) and also noted that “Enforcement of civil rights should be based on a proper understanding of those laws, rejecting gender ideology and critical race theory” (322). This framing of gender as an ideology “is an example of the kind of externalization, projection, and inversion of meanings that take place in the zone of the phantasmic” (Butler 2024, 261). But we posit that this villainizing language represents something far more sinister. In an interview with David Remnick (2023), political science and gender scholar Masha Gessen stated: “Gender ideology is the spectre of a totalitarian regime that will enforce gender fluidity. Best as I can interpret it. But gender ideology is a term that appears in Brazil, and in Hungary, and in Russia. It is heavily weaponized by autocrats. I don’t know if you remember, some years ago, there was footage of Judith Butler being attacked, I think, at an airport in Brazil [in 2017]. They were attacked by some person. There was some protest with a placard saying ‘Down with your gender ideology.’ That was, I think, the first time I heard the term” (para. 27). The weaponization of “gender ideology” inspired someone to inflict physical harm on a scholar for simply employing a term in their work (Butler 2024). This is not phantasmic harm.[6] Using ambiguous, undefined terms masks Burke’s (2023) intention—to solidify firmly held conservative beliefs that can be used to deny rights to Americans whose identities offend the so-called “traditional values” of organizations like the Heritage Foundation and the individuals who support them (Corvino, Anderson, and Girgis 2017; Crasnow 2021; Reid 2013).
In Part 1 of the film version of the musical Wicked, the wizard notes that “the best way to bring folks together is to give them a really good enemy” (Chu 2024). We posit that Burke (2023) has attempted to give readers a “really good enemy” in taking direct aim at the two largest teacher unions in the US: the American Federation of Teachers (AFT) and the National Education Association (NEA). For example, she claimed that the AFT “promotes radical racial and gender ideologies in schools that parents oppose according to nationally representative surveys” (342)—a claim made without any citation of AFT policy documents or the “nationally represented surveys” mentioned. We assume that Burke (2023) is drawing on a 2021 study commissioned by the Heritage Foundation (on which Burke is the lead author), using a survey tool which includes blatantly biased prompts such as “Should high school boys be allowed to compete on girls’ sports teams if they identify as girls?” (Burke et al. 2021). Burke and colleagues (2021) provided no accounting of methods or analysis in the online summary of their research. We reviewed the extant literature and were unable to find any research not funded by the Heritage Foundation that supports the claim that US parents writ large oppose gender diversity.
Lexical Absences
According to Sunderland and Litosollei (2002), lexical items are those “which were not included, but logically and syntactically could have been, and from an indicated critical standpoint would be expected to have been” (22). In other words, lexical absences do not make explicit the constructs that they reference, and do not name them in the text. In Burke’s (2023) chapter, we noted lexical absences in the realm of implicit “traditional” values, the absence of words to describe gender-sexual diversity. As Sunderland and Litosollei (2002) wrote, “Without a particular discourse… something cannot be talked about” (9). Bearing in mind that discourse informs reality (Fairclough and Fairclough 2012), something that remains unnamed cannot be discussed, and this intentional silence can inspire a fear of the unknown.
Implicit “Traditional” Values
The Heritage Foundation authors do not define “traditional” values, however, they are implied throughout the report. The Heritage Foundation’s mission is to advance policy ideas grounded in free-market economics, small government, individual liberties, so-called “traditional” social values, and a robust national defense. Such values are implied in Burke’s (2023) chapter, with 170 appearances of the word “should” in reference to policy reform. Burke’s use of “should” is not just stylistic—it is a rhetorical tool that signals her vision of tradition as normative, natural, and obligatory—while simultaneously softening the prescriptive force so that it feels less like ideology and more like common sense. Burke describes the Department of Education (2023) as “promot[ing] [a liberal] agenda more effectively” (321), inhibiting education freedom with “regulations and red tape” (320), and being influenced by “radical special interest groups” (342)—specifically national teachers’ unions such as AFT and NEA. Burke also labels higher education institutions as “hostile to free expression” and as inhibiting “intellectual diversity,” especially related to faith-based institutions (320). Without an explicit statement, the report can be read as promoting principles of limited federal government, anti-intellectualism, and bolstering a case for the exitance of an anti-Christian sentiment (e.g., Green 2025). Throughout the chapter, Burke (2023) portrayed the Department of Education as a hostile entity. This seems worth noting, as it illustrates how word choices reinforce so-called traditional values while simultaneously sidestepping any concrete definition of those values.
Absence of the Term “Transgender”
Additionally, Burke (2023) explicitly used gendered language (e.g., “his or her” and “biological sex at birth”) and actively discusses social and medical gender transitions, using inflammatory language such as “remove or alter vital body parts” (345) and “Facilitating social gender transition without parental consent” (333). TGX scholars, including Serano (2013), Wilchins (2004), and Zimman (2014), have argued that cisgender academics can perpetuate this type of hurtful rhetoric that often reduces the TGX experience to being solely about body parts. Burke (2023) specifically advocated for the removal of the term “non-binary” from federal forms and to use “sex” instead of “sexual orientation and gender identity” (333). However, the report never explicitly mentioned the term “transgender” (or derivative terms). This could be viewed as a refusal to affirm the existence of trans identity and encouraging the limitation of federal protection for those individuals. Similarly, Burke (2023) never used the words “gay,” “lesbian,” or “bisexual.”
One-Off Words or Phrases
Sunderland and Litosseliti (2002) advised exploring “‘one-off’ words or phrases salient in content” (22). The following examples from the Project 2025 Education chapter illustrate how language is used to negotiate and contest in a way that exacerbates the phantasm—making a concept seem scarier and more threatening than it actually is (Butler 2024). Said differently, these are the “Fox News chyrons” of the analysis: phrases designed to elicit an exaggerated emotional response by intentionally omitting key contextual information and emphasizing specific words that have been co-opted to seem egregious or inflammatory. Examples of these include: “Ambiguous concept of ‘gender,’” “radical gender theory,” and “political indoctrination” used in describing: “Department of Defense schools around the world [that] are using radical gender theory and critical race theory in their lessons. This instructional material discards biology in favor of political indoctrination and applies critical race theory’s core tenets, advocating for more racial discrimination. Such ideas are highly unpopular among parents, according to nationally representative surveys, and the course material attempts to indoctrinate students with radical ideas about race and the ambiguous concept of ‘gender’” (Burke 2023, 348). Besides the use of scare quotes, “ambiguous” seems ironic considering that “It is probable that all language is ambiguous” (Robinson 1942, 106). Ambiguity can, in this instance, evoke the fear of the unknown—in this case, a terrifying future in which biological sex means nothing (Butler 2024). Furthermore, the use of “radical” implies what Merriam-Webster (n.d.) defines as “favoring extreme changes in existing views, habits, conditions, or institutions.” Here Burke employed the phantasms of “radical” and “gender theory” to encourage readers to yearn for a time when gender was perceived as “simple.” Gender discourse in the US has evolved rapidly since Time magazine’s discussion of a “transgender tipping point” (Steinmetz 2014). A recent Gallup poll revealed that “More than one in five Gen Z adults—those born between 1997 and 2006, who were between the ages of 18 and 27 in 2024—identify as LGBTQ+” (Jones 2024, para. 2) and that nationally, 3% of American high school students identify as trans (Ghorayshi 2024).
Under the heading “Attacking the Accreditation Cartel,” Burke (2023) invoked the term “Ideological preferences,” saying, “For a college to participate in federal financial aid programs, it must be accredited, but accreditors have been abusing their quasi-regulatory power to impose non-educational requirements and ideological preferences on colleges” (355). The term “ideological preferences” remained undefined and amorphous. One might assume that Burke (2023) is referring to the notion that US universities are a bastion of liberal ideas (e.g., Zipp and Fenwick 2006)—a framing that seems ironic considering that, at the time of this writing, the current presidential administration has publicly attacked US universities including Columbia University—an Ivy League institution that capitulated to the administration’s demands to monitor or eliminate programs that it deems as being “DEI-related”: “Legal scholars and advocates for academic freedom expressed alarm on Friday over what they described as Columbia’s dangerous surrender to the 47th president at a perilous moment for higher education” (Closson 2025, para. 14). Recently, the administration also has taken on other flagship higher education institutions in the US including Harvard University (Saul 2025).
Two final examples of one-off phrases are “Woke diversicrats” and “accreditation cartel.” Burke (2023) advocated strongly for “Prohibit[ing] accreditation agencies from leveraging their Title IV[7] gatekeeper role to mandate that educational institutions adopt diversity, equity, and inclusion policies” (352) and argued against agencies denying accreditation to faith-based institutions, writing, “rather than continuing to buttress a higher education establishment captured by woke ‘diversicrats’ and a de facto monopoly enforced by the federal accreditation cartel, federal postsecondary education policy should prepare students for jobs in the dynamic economy, nurture institutional diversity, and expose schools to greater market forces” (320). By simply using the term “woke,” Burke evoked the phantasm by employing a term which has roots in Black vernacular that US conservatives use as a “derisive stand-in for diversity, inclusion, empathy and, yes, Blackness” (Robinson 2022, para. 25). We posit that “woke” has been co-opted by US conservatives as a proxy for ideals that they dislike about those on the ideological left—as exemplified by the fact that the term is now being legislated, with politicians like Florida Governor Ron DeSantis declaring a “war on woke” (Giroux 2024). How do the policies, laws, and executive orders that we have discussed influence music education? How can music educators, professional organizations, and the field writ large respond? We explore these questions in the next section.
Discussion and Implications for Music Education
The Project 2025 report is a symptom of a more treacherous agenda that is having direct impacts in US schools at the time of this writing.[8] The national education system makes a significant impact on US education discourse, however it is not the only contributor. US schools continually are impacted by top-down and bottom-up policy and rhetoric. Recalling that Fairclough and Fairclough (2012) wrote that “discourses provide reasons for action” (95), and that “through our language and other social practices, we can and do rework and often contest the assumptions embedded in discourses” (Sunderland and Litosollei 2002, 18), in this section we discuss what Burke’s (2023) work could mean for the music education profession.
Implications for Music Education Scholars
Music education scholars should recognize our analysis as a call to action for an intentional response given the uncertainties of the current sociopolitical climate. Examples could include researchers choosing to introduce new critical methodologies to the field, disseminate their work to practitioners and policymakers, and interrogate the use of language and rhetoric in these unprecedented times. With regard to new methodologies, critical discourse analysis offers robust means of analyzing text and speech. Within music education research, critical discourse analysis has rarely been utilized (e.g., Caithaml 2024; Talbot and Millman 2011). The Project 2025 report relies heavily on the obfuscation, misrepresentation, and exclusion of scholarship. For example, Burke (2023) employed fear-mongering terms like “gender ideology” and vilified research and scholarship in Critical Race Theory. Scholars might consider how the research they conduct is made accessible to practitioners and policymakers in ways that allow those stakeholders to access knowledge for their own advocacy work and protection. Publishing in accessible locations (e.g., National and State MEA websites or open access journals) and in accessible formats (e.g., via podcast, social media posts, or conference sessions) could encourage further critical engagement of scholarship from practitioners. Finally, Burke (2023), as we have noted, intentionally employed inflammatory and fear-instilling language. She actively omitted references to established scholarship and hid her own positionality. Music education scholars must continue to be conscious of how tone, rhetoric, and citational practices impact their publications.
The line of scholarship on TGX topics in music education is relatively new—built upon the work of feminist scholars like Elizabeth Gould, Roberta Lamb, Julia Koza, and Patricia O’Toole. In an era in which the attempted dismantling of DEI programs at US universities (e.g., Saul 2025) is commonplace, it would be logical that young scholars (especially those that are pre-tenure) could fear pursuing TGX topics that are considered controversial by some (Rabban 2024). If scholarship on TGX topics in music education slows, our field could backslide. The gender phantasm could convince music educators and music education scholars that discussing gender-sexual diversity is not important—or even worse—a liability (Bohn 2023).
We, as music education scholars, must continue to question tradition and resist relying on, and citing, problematic ideas simply because of ubiquitous “traditions” within our field such as using vague, coded language rather than speaking directly about gender and sexuality (e.g., McBride and Palkki 2020). Music education scholars can also center the voices and experiences of persons from historically marginalized communities (e.g., Hess 2018; Lechuga and Schmidt 2017). Broadly, we must continue to question tradition and resist relying on, and citing, problematic ideas simply because of ubiquitous “traditions” within our field (e.g., O’Toole and Palkki 2025). The reality is that adherence to these traditions continues to cause both TGX scholars and TGX students (Hess 2023; Palkki and Caldwell 2018) harm within various music education settings.
The music education profession has continually failed to respond to federal policy initiatives in a timely manner (Branscome 2012). Mindful of this eagerness by the music education “old guard” to just teach the music and leave the politics at the door (Hess 2019; O’Toole and Palkki 2025), we hope our work can serve as a call to action and not be met by the same tired refrain of judgmental resistance from those who choose to ignore the threats this policy agenda poses to all TGX music education teachers, students, and their allies. We share the sentiment that it has been “too easy to make the person offering new ideas the problem, not the privilege of those who stand in judgement” (O’Toole and Palkki 2025, 276). The inflammatory rhetoric of policy has reached a fever pitch. Will the music education profession stand in judgement against those who advocate for the safety of all students by insistence on clinging to tradition? Or will we as a profession finally work together to create a more equitable and just music education community?
Implications for Preservice/In-service Music Educators
Several music education scholars have contended that students who feel safe and supported are more likely to succeed both in and out of school (Clark 2020; Edmonson et al. 2016). Burke’s (2023) policy suggestions contradict extant scholarship on safety for trans and gender-expansive students in music programs (e.g., Garrett and Palkki 2021; Shouldice and Timmer 2025; Stapleton n.d.), which is concerning considering the fact that a significant number of LGBTQ youth enroll in school music programs (Kosciw et al. 2014). Music education scholars have provided guidance for music educators wishing to facilitate support and safety for TGX students. For example, “Music teachers can make small changes in classroom guidelines and policies to honor [TGX] students’ chosen names and pronouns” (Garrett and Palkki 2021, 146). Music educators who lead public performances often need to publish students’ names in public-facing documents like concert programs which easily could place an educator in the position of keeping “secrets about a child from that child’s parents” (Burke 2023, 346)—a policy which may or may not be a part of a state law (Bylica, Hawley, and Lewis 2024; Salvador 2023). Music educators wishing to support TGX students may need to do so in more covert ways during the reign of the current political regime. The consequences of being overt are not theoretical. One school district in Florida “chose not to renew [a teacher’s] contract because she called a student by their preferred name without parental permission” (Elassar 2025, para. 1). Music educators with tenure and political capital in their school/district might advocate for policies that honor TGX identities. Teachers without tenure can observe and document potentially troublesome policies, find colleagues who could be allies, and learn the context of these policies in their specific school or district context. All teachers, regardless of tenure status, can remain abreast of the rapidly shifting legal and political environment in the US that impacts TGX students in schools.
Music education scholars have written about the importance of creating a sense of community and safety within school music programs (e.g., Adderley, Kennedy, and Berz 2003; Hendricks, Smith, and Staunch 2014; Morrison 2001), especially for LGBTQA students (Cates 2022; Garrett 2012; Garrett and Spano 2017). Music educators face unique challenges pursuant to decisions that have gender-related implications, including uniform choices (Blaisdell 2018; Lamartine 2020), choral ensemble names (Hill 2021; McKiernan and McNickle 2023), and healthy vocal pedagogy for TGX singers (Cooper, Manion, and Harrison 2024; Sauerland 2022). Music educators seeking to make gender-inclusive curricular decisions (Beede 2025; Cates 2022; Garrett 2012; Palkki and Sauerland 2019; Shouldice and Timmer 2025) should consult policies at all levels (school-level to federal level) to ensure that their actions will not put them in legal jeopardy. For example, book bans are becoming increasingly prominent (e.g., Grote-Garcia and Ortlieb 2024) and the construct on which these bans are based could very well influence music choices. For example, in Arkansas, state officials pulled a piece from the All-State Choir program because the poet is trans (Smittle and Grear 2025). In the current political climate, some teachers need to now have their repertoire choices approved by administrators (Salvador 2023; Taylor, Nápoles, and Powers 2025). This oversight of music selections is indicative of the broader deprofessionalization and surveillance of teachers under the 47th president’s administration (Brett 2025).
Music educators also can help to expose and dispel myths about trans exclusion “saving students from harm.” This ideological framing paints those who support TGX youth as actively supporting the oppression of non-TGX students by shielding them from the allegedly corroding thread that the mere presence of TGX people invokes. Groups like the Heritage Foundation are using TGX youth, already an extremely vulnerable population who are at great risk for depression and attempted suicide (e.g., Grossman and D’Augelli 2007) as a political punching bag. In particular, conservative groups have made TGX youth—and in particular trans girls—in sports a “political football” (Levin 2021). In a March 2025 legislative hearing, Texas Democratic Representative Jasmine Crockett illustrated this notion when she said, “According to [conservatives], the trans kids, they want to play sports…. Find the little trans child that is ruining your life. I mean, I’m just like, what are we doing?” (Adamczeski 2025, para. 3, emphasis added). Keeping in mind that “the task of feminist DCA is to examine how power and dominance are discursively produced and/or resisted in a variety of ways through textual representations of gendered social practices” and to analyze “communicative events and culturally valued genres… that can be empowering for women’s participation in public domains” (Lazar 2005, 10), the discussion about, and legislation of, trans girls/women in sports involves politicians—many of whom are cisgender, straight, white men—legislating TGX bodies. As Sharrow (2021) wrote, “Conservative political interests now seek laws that suture biological determinist arguments to civil rights of bodies” (2). Setting aside the fact that these bans affect a miniscule amount of students,[9] anti-trans political discourses are harmful to TGX students’ well-being. Music educators can continue to provide support for their TGX students and to ensure that music classrooms are spaces of safety and comfort for students of all gender identities (Garrett and Palkki 2021; Silveira and Goff 2016; Stapleton n.d.).
Discourse espoused by Burke (2023) and other colleagues at The Heritage Foundation is currently pervading through all levels of government. In resisting the characterization of TGX inclusion causing harm to cisgender students, we as music educators must be careful that the national narrative does not reinscribe and perpetuate antiquated existing gender norms in instrumental (Abeles 2009; Abeles and Porter 1978), choral (Koza 1993; McBride and Palkki 2020), and general music (Robison and Culp 2021) settings.
Implications for Music Education Organizations
Findings from this study suggest that documents published by organizations, the Heritage Foundation in this case, have the potential to pervade discourse in a variety of areas beyond the audience of a specific organization and into various levels of government. This concept, which Fairclough and Fairclough (2012) called recontextualization, has profound implications for music education organizations. If the authors of the Project 2025 report and the current president agree and promulgate specific discourses around gender and sexuality that jeopardize the physical and mental safety of students, is it not the moral obligation of music education associations to disseminate counter-discourses that reaffirm a commitment to the well-being of these students? Since discourse informs reality and varies by place and time (Fairclough and Fairclough 2012), an absence of new discourses from a variety of sources (e.g., National Association for Music Education, American Choral Directors Association, state Music Education Organizations) means that these existing, harmful discourses will continue to spread across the country unimpeded, threatening the lives of countless TGX students.
An organization-based approach would need to be coordinated between national and state organizations given incredibly varied political climates across the United States. Recent scholarship in music education has examined this “equality gap” and the implications this state-to-state variance may have on the profession in the years to come (Caithaml and Palkki 2025; Knauer 2020). For example, the recent cancellation of a choral piece on a program in Arkansas because the poet identifies as non-binary (Smittle and Grear 2025) was met with a bureaucratic response from ACDA centered around which states are officially “affiliate members” of the national organization, but not offering a direct response to the matter at hand. This anecdote could represent a broader hesitance to join the fray of national discourse for fear of legal implications, with national organizations often choosing the path of least resistance. Therefore, like higher education institutions, large professional organizations are inherently risk averse, as there is an obvious fear of increased scrutiny that could have detrimental financial implications. For example, the administration recently threatened to eliminate funding for the University of Pennsylvania over its approach to TGX athletic policies (Blinder and Bender 2025). Our work suggests that an aversion to taking a moral stance has very real consequences for the lives of individual students. If the language of Project 2025 continues to pervade state and national discourse unchecked by any institutions or organizations, who will stand up for the humanity of TGX students? We posit that a strategic, but courageous approach is necessary in order for state and national organizations to explicitly show support for TGX students. Hess’s (2019) activist framework, which emphasizes equity work, critical consciousness, and collective action may be helpful for music educators and professional organizations working for change.
At the time of this writing, NAfME has maintained its websites related to diversity, equity, and inclusion. Individual TGX musicians and educators continue to create, curate, and publish content to support TGX students in music education (e.g., Beede 2025; Cayari, Graham, Jampole, and O’Leary 2021). Some state music education associations continue to evaluate professional development sessions using a DEIA framework. For example, the Massachusetts Music Educators Association (n.d.) evaluates all conference session proposals using a rubric that “celebrates exceptionalities, identities, orientations, and cultural backgrounds”—a tangible example of how policy and discourse might support more inclusive organizational practices. However, music educators and organizations may find themselves under scrutiny because their actions might be labeled as “political.” It may be worthwhile, then, to consider how stakeholders can engage to resist the gender phantasm and, in so doing, generate new forms of discourse around gender and sexuality that are research-based, united, and unapologetic. Drawing on Sabatier’s (1993) advocacy coalition framework, we suggest that these responses be rooted in the following elements: (a) coordinated responses from state and national music education organizations, (b) a collection of actionable, best practice documents that do not hesitate to reclaim a definition of gender that is research-based, and (c) a renewed emphasis on student mental safety in light of extensive research showing increased risk for students who identify as members of the TGX community. This response framework can be utilized at all levels of the profession to ensure that all music education students are safe and valued regardless of the political affiliation of their state.
Based on this inquiry, we suggest that organizations carefully consider the stance represented by the language that they choose (or choose not) to use. Music educators and teacher educators have an active role to play in their creation and ongoing support of coalitions for transformative action. Supporting organizations whose values align with supportive teaching and learning environments can include financial contributions, speaking at and attending meetings, and promoting ethical and prompt dissemination of information. Additionally, all stakeholders might consider how the approach utilized in this document, critical discourse analysis, might inform new postures toward the critical consumption of discourse in our social reality.
Conclusion
As mentioned in the overview of our method, in this analysis, we sought to distinguish between the actual harm that is possible as a result of policies seeking to narrowly define issues of gender and sexuality and the manufactured, phantasmic harm that is disseminated in the education chapter of the Project 2025 document (Burke 2023). We have attempted to outline the implications that these various types of harm, both real and imagined, present to the music education profession.
Our analysis shows that the narrative of parental rights has become synonymous with censorship, and that in the name of preserving the rights of some students, the well-being of other students is placed in jeopardy. We call on all music educators, both scholars and practitioners, to ask: Whose rights are important? Whose safety takes precedent? For example, if it is now the right of some parents to unilaterally define the meaning of sexuality and gender identity, what harm is caused as a result? We argue that this harm to trans and gender expansive students is real, not phantasmic. It is only through purposeful examination of the differences between real harm and phantasmic harm that we can begin to imagine a way forward that ensures the true physical and mental safety of all students, some of whom already fear for their lives on a daily basis.
We urge music educators to consider Emejulu’s (2022) notions of care within an environment of dehumanization from a Black feminist perspective: “To safeguard the well-being of other people is to identify with and seek to be in community with them. Under these conditions, we cannot separate care from distress” (26–27). Therefore, music educators have a moral obligation to actively acknowledge the distress of the TGX community as a direct result of Burke’s (2023) discourse in the Project 2025 document. If music educators choose to ignore the very real needs of trans and gender-expansive students, Emejulu (2022) reminds us that a lack of care “is a kind of care too—a reassurance to humans that harm will come to non-human Others for the sake of their care and protection. To be outside the community of humans is to be at the mercy or the whims of those who do not consider you their equal and most likely do not consider you at all” (27). Therefore, to make any choice other than active, daily support of TGX students—including inaction—would be choosing to ignore the very real needs of students across the country, leaving all of us wandering without a clear direction through the next four years and beyond. When considering the needs of TGX students in their classrooms/programs, music educators should bear in mind the complexity of visibility and to what level TGX students are comfortable being “out and proud.” As Nicolazzo (2019) wrote: “coming out of the closet and moving visibly into society has long been a symbol of the start of something: a public life worth living. However, as time has marched forward, various queer scholars and activists have pointed out that the project of visibility has not aged well” (120). Furthermore, the quandary of whether or not TGX students choose to be “visibly trans” is a sign that cisgenderism persists in many educational contexts (Martino, Omercajic, and Kassen 2022). We, as music education professionals, can be part of creating a more gender-expansive music education in our own contexts. As Butler (2024) observes, “if we fail to come together and promote more compelling visions of the world in which we want to live, then we are surely lost” (132). Now is the time for the music education profession to create a compelling vision that can provide a clear direction for the future.
About the Authors
Joshua Palkki (he/him) is Associate Professor of Music at the Georgia Institute of Technology and co-author of Honoring Trans and Gender-Expansive Students in Music Education (Oxford University Press, 2021). He holds degrees from Michigan State University (Ph.D. music education), Northern Arizona University (M.M. choral conducting), and Ball State University (B.S. music education). Dr. Palkki is a sought-after presenter, guest conductor, and scholar on equity and justice topics. His writing appears in Arts Education Policy Review, Journal of Music Teacher Education, Journal of Research in Music Education, Routledge Companion of Jazz and Gender, Oxford Handbook of Feminism and Music Education, and Oxford Handbook of Queer and Gender Studies in Music Education.
Justin Caithaml (they/them) serves as Professional Lecturer of Vocal Music Education at the DePaul University School of Music. A passionate advocate for equity and access in music education, their current research focuses on more deeply understanding gender and sexuality discourse in the music education profession. Prior to their appointment at DePaul, they served as Assistant Professor, Chair of Music, and Coordinator of Music Education at the University of Bridgeport. They completed their PhD in music education at the University of Maryland, where they served as instructor for student teaching seminars, a research assistant in the Music and Arts Education Data Lab and were a recipient of the American Educational Research Association’s Outstanding Graduate Paper Award in Music Education. They served as choir director at Midview Local Schools outside of Cleveland for six years and hold degrees from Teachers College, Columbia University (MA in Music and Music Education) and Baldwin Wallace University (BME).
Shawn Kimbrel is a doctoral student at Arizona State University in Music Learning and Teaching and serves as a middle grades music educator in the Phoenix metropolitan area. Shawn’s research widely focuses on perceptions of mattering and human significance in music education, especially regarding historically marginalized populations. He has presented at national and international conferences on topics including interdisciplinary musical experiences, disability studies and teacher education, queer and neurodiverse identity in qualitative research, and coloniality and historical research practices.
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Notes
[1] Title VII of the Civil Rights Act of 1964 prohibits employment discrimination on the basis of race, color, religion, sex, and national origin, and it applies to most employers in the United States. It has been a central legal foundation for advancing workplace equality, including recent interpretations extending protections to LGBTQ employees.
[2] Title IX of the Education Amendments of 1972 is a federal civil rights law that prohibits sex-based discrimination in any education program or activity receiving federal financial assistance.
[3] L (lesbian), G (gay), B (bisexual), T (trans), Q (queer, questioning), and A (asexual, agender, etc.). This is the way that we have chosen to represent sub-populations of gender-sexual diversity. When used in other forms (e.g., LGBT or LGBTQ+), we are quoting the acronym used by another author to accurately represent their writing. We have chosen these six letters (representing seven terms) because, at this juncture, we consider it a fairly comprehensive representation of the many facets of the non-cisgender and non-heteronormative population currently and realize these letters are not all-inclusive.
[4] Each of us are rhetorically attacked by various parts of the Project 2025 report, not only Justin. Earlier in the full Project 2025 report, authors wrote of the “bullying LGBTQ+ agenda” (Primorac 2023, 258) and demanded that the new administration reverse the Biden administration’s focus on “LGBTQ+ Equity” (Dans and Groves 2023, 284) as examples.
[5] The Protection of Pupil Rights Amendment is a targeted statute about parent consent for sensitive surveys and certain exams/materials. Burke (2023) co-opts it as a foundation for a much broader parental-rights program—to contest gender/CRT policies, challenge Title IX-adjacent rules, and to expand enforcement by adding a private right to litigation—uses that go well beyond PPRA’s original, limited scope.
[6] This incident is reminiscent of the experiences of Dr. Magnus Hirschfeld and the book burning of his library at the Institute for Sexual Science in 1930s Berlin. For more information, see Brook (2025).
[7] Title IV refers to Title IV of the Higher Education Act of 1965 (HEA)—a section of US federal law that governs the federal student financial aid programs.
[8] For example, the current president has already signed an executive order that seeks to eliminate the Department of Education—a suggestion directly from Burke’s (2023) chapter: “Federal education policy should be limited and, ultimately, the federal Department of Education should be eliminated” (319).
[9] The current administration sued the state of Maine after the governor refused to implement the executive order banning trans students from school sports. “It is unclear how many transgender students are currently participating in school athletics in Maine. The Maine Principals’ Association, MPA, which governs the state’s athletics, has said there are just two transgender athletes involved in girls’ high school sports this year. The DOJ’s suit refers to at least three transgender athletes” (Moore 2025, para. 7, emphasis added).