Unlike most racial minorities, women, and individuals with disabilities, most gays have (in fact or in the imagination of others) a panoply of options for assimilation. These forms of assimilation include conversion, passing, and covering. The history of gay rights can be retold as a history of
resistance to these three kinds for assimilation.

Through the middle of the twentieth century, gays were routinely asked to convert to heterosexuality, whether through lobotomies, electroshock therapy, or psychoanalysis. As the gay rights movement gained strength, the demand to convert gradually ceded to the demand to pass. This shift can be seen in the military’s adoption in 1993 of the “Don’t ask, don’t tell” policy, under which gays are permitted to serve so long as they agree to pass. Finally, at millennium’s turn, the demand to pass is giving way to the demand to cover -- gays are increasingly permitted to be gay and out so long as they do not “flaunt” their identities. The contemporary resistance to gay marriage can be understood as a covering demand: Fine, be gay, but don’t shove it in our faces.

Gays routinely cover along all four axes: appearance (“acting straight”); affiliation (not making references to gay culture); activism (avoiding the charge of being militant or strident about gay rights); and association (eschewing public displays of same-sex affection).

Notable instances in which gays who resisted the demand to cover lost their cases include Shahar v. Bowers (1997), in which a lesbian attorney was fired for engaging in a private same-sex commitment ceremony, and Lundin v. Lundin (1990), in which a gay couple was denied custody of a child because they engaged in displays of affection.