She Who Shall Not Be Named: The Women That Women's Organizations Do (and Do Not) Represent in the Rulemaking Process

Abstract

Though the concept of intersectionality has been in circulation for nearly 30 years and women's organizations have long been criticized for failing to prioritize the concerns of women of color, poor women, and LGBTQ women, more research is needed to determine precisely why women's organizations do and do not discuss those intersectional identities during policy debates. This study analyzes 1,021 comments that women's organizations submitted to rulemakers to test a series of hypotheses about how women's organizations’ references to women's intersectional identities increase or decrease depending on the organization's primary constituency and ideology, the proposed rule's target population, and other features of the policy-making context. Using automated text analysis and a series of models, it shows that women's organizations do discuss intersectionally marginalized women in their comments. However, not all subgroups of women are equally represented during the process. Women's organizations focus on women's sexual orientations and gender identities more than their races, ethnicities, nationalities, or socioeconomic statuses. Intersectionally marginalized women also tend to receive the most attention when commenters are from organizations that are explicitly focused on representing intersectionally marginalized women and when bureaucrats include references to intersectionally marginalized women in their proposed rules.

Coalitional Lobbying and Intersectional Representation in American Rulemaking

“…When are intersectionally marginalized individuals represented in politics? In answering this question, scholars have long considered the formal and informal activities of citizens, protest movements, and elected officials, with occasional reference to interest groups (Brown et al 2017; English 2019a; 2020; Gershon et al 2019; Laperrière and Lépinard 2016; Marchetti 2014; Purdie-Vaughns and Eibach 2008; Reingold, Widner, and Harmon 2019; Skrentny 2002; Strolovitch 2007). Others have noted that collaborative lobbying is conducive to the nature of intersectional advocacy, comprises the majority of interest group activity, and can yield influence over policy making (Hula 1999; Nelson and Yackee 2012; Strolovitch 2007); however, this body of work remains limited.…”

“…While many of these groups are prominent and influential actors, they too are plagued by barriers to their political influence and biases in their representation (English 2019a; 2019b; 2020; Marchetti 2014; Martinez 2009; Strolovitch 2007). Organizations representing socially and politically marginalized individuals have smaller budgets, memberships, and staff and more-limited advocacy agendas than do private and professional groups (Schlozman, Verba, and Brady 2012; Strolovitch 2007).…”

“…This framework describes the manner in which different biological, cultural, and social categories—such as race, gender, and class—intersect to create compounding systems of discrimination and oppression. Scholars including English (2019a; 2020), Marchetti (2014), and Strolovitch (2006; 2007) have applied this framework to the study of interest group advocacy, emphasizing that intersectionality structures every facet of individuals’ life experiences and manifests in “interlocking” or “simultaneous” oppressions. Their works note that the representational choices of interest groups—even those that represent marginalized individuals—can reinforce or mediate these oppressions, leading to majoritarian bias in interest group advocacy (English 2019a; 2020; Marchetti 2014; Strolovitch 2006).…”

“…Coalitions also offer lower-profile opportunities for interest groups representing the marginalized to engage with intersectional policy issues. As noted earlier, interest groups representing the marginalized limit their advocacy on these particular issues (English 2019a; 2020; Marchetti 2014; Strolovitch 2006), as key actors within such organizations often frown upon expending scarce resources on “controversial” or “narrow” policy topics (Staggenborg 1986; Strolovitch 2006). This pattern is linked to the disproportionate resource limitations faced by these organizations and largely a function of ambivalence, disinterest, or disapproval on the part of their active members and patrons towards such advocacy—as many of these actors are both influential in funding and shaping organizational agendas and do not often share the identities or priorities of the groups’ multiply disadvantaged constituents (Strolovitch 2007).…”

“…These structural limitations have important implications for the lobbying strategies of interest groups representing marginalized communities. Existing research has found that interest groups representing the marginalized prioritize broad-reaching issues at the expense of intersectional issues in lobbying, and overrepresent class-based issues while underrepresenting gender-based issues relative to the proportions of poor and female members of their constituencies (English 2019a; 2020; Marchetti 2014; Strolovitch 2007). Through in-depth interviews, these studies also report that many of these groups highlight intersectional advocacy as central to their goals but note that it is difficult to pursue alone (Strolovitch 2007).…”