JONES-NORWOOD_PP_FINAL (DO NOT DELETE) 7/25/2017 11:44 PM Aggressive Encounters & White Fragility: Deconstructing the Trope of the Angry Black Woman Trina Jones* & Kimberly Jade Norwood** ABSTRACT: Black women in the United States are the frequent targets of bias-filled interactions in which aggressors: (1) denigrate Black women; and (2) blame those women who elect to challenge the aggressor’s acts and the bias that fuels them. This Article seeks to raise awareness of these “aggressive encounters” and to challenge a prevailing narrative about Black women and anger. It examines the myriad circumstances (both professional and social) in which aggressive encounters occur and the ways in which these encounters expose gender and racial hierarchies. It then explores how the intersectional nature of Black women’s identities triggers a particularized stereotype or trope of the “Angry Black Woman” and explains how this trope is often invoked in aggressive encounters to deflect attention from the aggressor and to project blame onto the target. After discussing the harmful effects of aggressive encounters and the absence of effective legal mechanisms to address them, the Article sets forth tangible steps that individuals can take to minimize their incidence. I. INTRODUCTION ........................................................................... 2018 II. WHY FOCUS ON BLACK WOMEN? THE NECESSITY OF INTERSECTIONAL ANALYSES ........................................................ 2022 A. HISTORICAL ERASURE ........................................................... 2023 B. CONTEMPORARY EXAMPLES ................................................... 2026 * Professor of Law, Duke University School of Law. I would like to thank my research assistants, Kevin Zhao and Gloria Liu, for their excellent contributions to this Article. I am also grateful to D. Wendy Greene, C.T. Woods-Powell, and my amazing sisters in Ladies Who Love Books for their probing insights and generous guidance. ** Henry H. Oberschelp Professor of Law and Professor of African & African American Studies, Washington University. I want to thank my husband, Ronald Alan Norwood, Esquire, for his insights and editing. I also want to thank all of the Black women whose stories appear here, for their willingness to have their stories told. 2017 JONES-NORWOOD_PP_FINAL (DO NOT DELETE) 7/25/2017 11:48 PM 2018 IOWA LAW REVIEW [Vol. 102:2017 III. AGGRESSIVE ENCOUNTERS: DEATH BY A THOUSAND CUTS ......... 2030 A. COMMERCIAL ESTABLISHMENTS AND PRIVATE SPACES ............ 2031 B. PROFESSIONAL SETTINGS ....................................................... 2034 C. INTERACTIONS WITH LAW ENFORCEMENT ............................... 2038 D. CROSS-GENERATIONAL EXPERIENCES ...................................... 2041 E. A BRIEF SUMMARY ................................................................ 2044 IV. (DE)CONSTRUCTING THE TROPE OF THE ANGRY BLACK WOMAN ....................................................................................... 2045 V. WHITE FRAGILITY AND PSYCHOLOGICAL PROJECTION: THE BLAME GAME ............................................................................... 2051 A. WHITE TRANSPARENCY, WHITE FRAGILITY, AND AGGRESSIVE ACTS .................................................................................... 2052 B. PSYCHOLOGICAL PROJECTION ................................................ 2055 C. THE DECISIONAL MOMENT AND CONSEQUENCES ..................... 2057 VI. SEARCHING FOR SOLUTIONS: IS THERE RELIEF IN SIGHT? .......... 2059 A. COALITION BUILDING IN THE NEW MILLENNIUM .................... 2059 B. LEGAL INTERVENTIONS .......................................................... 2063 1. Constitutional and Statutory Claims .......................... 2063 2. Tort Claims .................................................................. 2065 C. CHANGING THE NARRATIVE AND A CALL FOR INDIVIDUAL ACTION ................................................................................ 2066 VII. CONCLUSION .............................................................................. 2068 I. INTRODUCTION May 24, 2016, approximately 11:00 a.m. CDT (as posted on Facebook by Professor Norwood): So, I go to Home Depot today to get some paint. When I get to the paint station, there is a couple sort of hanging back between the aisle and the station. Another guy is at the station. I say “Hi,” and ask him if he has been helped. He says “Yes, thank you, but you should check with that couple over there.” What??????????? Yeah. He thought I worked at Home Depot despite the fact that (1) I DID NOT have on one of those bright ass orange vests, and (2) I LOOKED like the OTHER people in Home Depot: t-shirt and jeans. Ok. I smile. I whisper to him, “I don’t work here; no need to check with them. . .” Then another man comes over. He looks at me and the dude I am standing behind. He proceeds to stand at a different part of the station. Paint person arrives. He helps the guy I originally spoke with. Then he asks, “Who is next?” The couple says nothing. I raise my hand to say me, and the guy last on the scene says “No, I’m next.” JONES-NORWOOD_PP_FINAL (DO NOT DELETE) 7/25/2017 11:48 PM 2017] AGGRESSIVE ENCOUNTERS & WHITE FRAGILITY 2019 So, I say, “Wait, not true. I was . . .” THEN DUDE COMES OVER TO ME, while I am in MIDsentence, GETS IN MY FACE—he is a white male, both older and ALOT shorter than me—and YELLS IN MY PERSONAL SPACE that he was there first and I need to wait my turn. Wait, did you read that? GETS IN MY FACE?????????? YELLS????? MY???????????? PERSONAL?????????? SPACE??????????????? At this point in the story, I won’t share the exact words or tone or volume of my response because I don’t want to lose some of you FB fam who think so highly of me . . . but suffice it to say, I DO owe some context (and maybe a piece of apology) to all in West County who unwittingly became a part of my response. . . . I will say that I demanded to see a manager. Poor sales person. He was like, “I’m sorry! I didn’t know.” I assured him that I had no beef with him. He did the right thing by asking who was next. The problem was with the customer. Indeed, what should be done in those situations? Maybe you call for backup immediately. I don’t know. What I do know is that I was NOT about to be ignored and made to wait. I know that. So, after demanding to see a manager, I decided, hell with this, I am leaving. As I am about to walk away, crazy man comes back near me and says: “Look! I got here 20 minutes ago! No one was here so I got other stuff I needed and now I’m back so I was here and I am next!” Read that sentence again. “Look! I got here 20 minutes ago! No one was here so I got other stuff I needed and now I’m back so I was here and I am next!” WHAT????? WHO in the world can LEAVE a line, go get other shit, and then come back and tell the people who were not there before that they were there first???????????? WOW. Kicker: He adds: “I didn’t even see you. You were NOT here.” Hmmm. . . I didn’t even see you. So, (1) he looked at me when he arrived. I KNOW he saw me. (2) I am just under 6 feet tall. Tall girl! (3) I have beautiful chocolate skin. Beautiful! (4) I have beautiful locs (thanks Michelle Yikhenah Jamillah Borland). Locs! (5) I have really powerful eyes! Powerful! (6) I am a “healthy” child as my mom would say. Big! And DESPITE ALL THAT, he didn’t SEE me? Really? So - Yes, an angry black woman was in Home Depot on Manchester in West County today. BUT she had a RIGHT to be angry. . . And please, don’t write a comment telling me that I spent more time on this post than it is worth. I get to decide what parts of my life I want JONES-NORWOOD_PP_FINAL (DO NOT DELETE) 7/25/2017 11:48 PM 2020 IOWA LAW REVIEW [Vol. 102:2017 to share. This is a message I wanted my FB fam to know and it is therapeutic for me to write. Not a waste of time for me.1 May 24, 2016, approximately 7:30 p.m. EDT (Experienced and recounted by Professor Jones): On the same day as Professor Norwood’s encounter in Home Depot, I was flying back to my home in North Carolina from Atlanta. I was well rested, but a bit travel weary as my travel day had begun earlier in the Dominican Republic. I am a frequent traveler and had chosen a bulkhead seat for the extra legroom. (Bulkhead seats are on the first row in each cabin of an airplane. As there is either a wall or empty space immediately in front of these seats, they lack floor space for the storage of personal items like a purse. One must store these items in overhead compartments during takeoff and landing.) As I entered the economy plus section of the cabin, I immediately noticed the limited storage space in overhead bins and that the space above my seat was occupied by safety equipment. I therefore placed my bag in the overhead bin that was diagonally across the aisle and one row ahead of my seat.2 Enter trouble in the form of a White businessman, in a designer suit, and fancy shoes. He appeared to be in his late 30s or early 40s. Businessman demands that I move my bag so that his companion (note not him, but his companion) could place his travel bag in the compartment my bag was occupying. He curtly tells me to place my bag in the compartment behind my seat as there was more space in the rear of the plane. I pause in the process of sitting, while he is glaring at me and waiting with the expectation that I would immediately comply with his demand. I then quietly, but firmly say to him, “I prefer not to have my handbag behind me.” (This preference exists not only because I like to keep an eye on my personal effects, but also because it is more difficult to exit a plane if your luggage is located behind you.) Instead of making a scene, however, I move my bag. In the process, I notice Businessman (who was still standing facing the rear of the cabin) looking at travelers in the rows immediately behind him with a long- suffering gaze, and rolling his eyes as if to say “this stupid, inexperienced woman.” At this point, I’m fuming. I’m mad at Mr. Arrogant because of his condescending manner. But I’m also mad at myself because I moved the dang bag and did not deliver a lecture on patriarchy (assumptions of male superiority and female inferiority), implicit bias, intersectionality, etc. As I settled in for the flight, I was stunned by his sheer presumption and I struggled to recapture my Caribbean-inspired joie de vivre. I kept asking myself: Would he have made the request had I been a White male business 1. Kimberly Jade Norwood, FACEBOOK (May 24, 2016, 11:00 AM). 2. On this particular plane, bulkhead seats on the left side of the plane faced a wall, while the right bulkhead seats faced empty space reserved for emergency exits. JONES-NORWOOD_PP_FINAL (DO NOT DELETE) 7/25/2017 11:48 PM 2017] AGGRESSIVE ENCOUNTERS & WHITE FRAGILITY 2021 traveler – or any White male? a Black man? a White woman? Maybe. But would he have made the request in the same demanding and patronizing fashion – or would he have been too threatened by a Black man and too solicitous of a White woman to dare suggest that either was so beneath him that they were not entitled to a modicum of respect?3 This Article is about the invisibility and dehumanization that Black4 women experience on a daily basis and the psychological and material harms that result. It is about how society does not recognize these injuries and therefore leaves Black women without any form of redress. It is about the complexity of that fleeting moment when Black women must decide whether and how to challenge another’s assumptions about Black women’s status and “place.” It is about the consequences of exercising voice, whether in angry or moderated tones, and how that exercise can render one hyper visible and threatening. It is about the phenomenon of displaced blame and how any response to an aggressive encounter immediately risks deflecting attention from the aggressor and placing blame squarely on the target. It is about how in an instant, a reasonable Black woman, who is just going about her business, gets transformed into the trope of the Angry Black Woman. It is about intersectionality and what Black women, because they are Black and female, experience at the hands of White men, Black men, and White women. It is about White fragility and how very far the United States has to go to escape the shackles of patriarchy and White supremacy. As used herein, aggressive encounters are bias-filled interactions in which aggressors: (1) denigrate Black women; and (2) blame women who elect to challenge the aggressor’s acts and the bias that fuels them. This term captures both micro-aggressive as well as macro-aggressive behavior.5 Some aggressive 3. Trina Jones, Experienced on Delta Flight 1753 in seat 20A from Atlanta, Ga. to Raleigh- Durham, N.C. (May 24, 2016). 4. This Article uses the word Black instead of African American. African American generally refers to Black people in the United States who trace their ancestry to persons who were enslaved and forcibly brought to this country from the African continent. Black is a more universal term, including not only African Americans, but any brown descendent of the African diaspora, regardless of whether they were born in the United States or in some other place (e.g., Brazil, the Caribbean, the African continent). Black thus includes persons described as Colored, Negro, African American, persons of color, etc. 5. For a definition of these terms, see Anthony V. Alfieri, Community Prosecutors, 90 CALIF. L. REV. 1465, 1503 (2002). Professor Alfieri notes: Critical race theory delineates two kinds of aggression: micro and macro. Racial aggression differs from racial violence in its sparing use of material force and physicality. Exerted by individuals and at times groups, microaggression aims chiefly at the individual person of color: his or her state of mind, language, and daily act of being in the world. Macroaggression, in contrast, points to the collective community of color. Enacted by groups, often in concert with the state, or by the state itself, macroaggression unleashes cultural, economic, and political forces of harm. Those forces may cause cultural degradation, economic hardship, or political disenfranchisement. Id.; see also Derald Wing Sue et al., Racial Microaggressions in Everyday Life: Implications for Clinical Practice, 62 AM. PSYCHOLOGIST 271, 271 (2007) (“Racial microaggressions are brief and JONES-NORWOOD_PP_FINAL (DO NOT DELETE) 7/25/2017 11:48 PM 2022 IOWA LAW REVIEW [Vol. 102:2017 encounters, like those described earlier in the Home Depot and airplane examples, are initiated without Black women doing anything other than just being. Other aggressive encounters occur when Black women speak in opposition to an injustice that has been done to another person (e.g., object to the unfair treatment of a family member). In both scenarios, aggressors respond by shifting attention from their underlying acts and deflecting blame to Black women. This Article seeks to raise awareness of aggressive encounters and to change the narrative concerning Black women and anger. The analysis proceeds as follows: Part II explains why this Article focuses on Black women as opposed to other targets of aggressive encounters. Part III examines the myriad circumstances (both professional and social) in which aggressive encounters occur and then analyzes the ways in which these encounters expose gender and racial hierarchies. Part IV explores how the intersectional nature of Black women’s identities triggers a particularized stereotype or trope of the “Angry Black Woman.” Part V examines White fragility, explains how it factors into the moment when Black women must decide whether to respond to aggressive acts, and analyzes the ways in which the exercise of voice by Black women leads to psychological projection and displaced blame. Part V then discusses some of the very real and harmful effects of aggressive encounters. Part VI explores implications of this analysis and sets forth possible solutions. II. WHY FOCUS ON BLACK WOMEN? THE NECESSITY OF INTERSECTIONAL ANALYSES Black women are not the only targets of aggressive encounters. White women and Black men, among others, also experience macro- and micro- aggressive behaviors. Without seeking to diminish the significance of White women’s and Black men’s experiences, this Part explains why Black women merit separate analysis. In short, this Part explains that Black women’s realities and the stereotypes to which they are subject overlap with, but sometimes differ from, those of their allies in struggles for racial and gender justice. Thus, conflating the experiences of Black women with those of Black men or White women—or assuming that Black women’s concerns will be addressed in one-dimensional discussions of race or gender—renders the harms that Black women face invisible.6 commonplace daily verbal, behavioral, or environmental indignities, whether intentional or unintentional, that communicate hostile, derogatory, or negative racial slights and insults toward people of color.”). 6. As Professor Paulette Caldwell has noted: [B]lack women’s invisibility serves to blind all women and all blacks to the interactive relationship between race and gender, leads to the development of legal theories and social policies directed at either race or gender without fully considering the implications of such theories and policies, and ultimately assures the perpetuation of domination on the basis of race and gender for all women and members of subordinated races. JONES-NORWOOD_PP_FINAL (DO NOT DELETE) 7/25/2017 11:48 PM 2017] AGGRESSIVE ENCOUNTERS & WHITE FRAGILITY 2023 A. HISTORICAL ERASURE For centuries, Black women have pointed to the ways in which they are differently situated from Black men and White women. For example, in 1851, Sojourner Truth—a Black female civil rights advocate—disrupted and ultimately saved a Women’s Rights Convention, when she famously asked “Ain’t I a Woman?”7 The White suffragists who had convened the conference feared that their message would be eclipsed or harmed if it were intertwined with abolitionist efforts.8 Indeed, Sojourner’s presence set off a wave of panic and nervous energy amongst the assembly, with several women anxiously beseeching the chair of the convention, Frances Dana Gage, to prevent Sojourner from speaking.9 After sitting silently and listening to White women describe the discrimination to which they were subject, and more importantly, when White male theologians assailed these women, Sojourner stood and shared the following: Well, children, where there is so much racket there must be something out of kilter. I think that ‘twixt the negroes of the South and the women at the North, all talking about rights, the white men will be in a fix pretty soon. But what’s all this here talking about? That man over there says that women need to be helped into carriages, and lifted over ditches, and to have the best place everywhere. Nobody ever helps me into carriages, or over mud- puddles, or gives me any best place! And ain’t I a woman? Look at me! Look at my arm! I have ploughed and planted, and gathered into barns, and no man could head me! And ain’t I a woman? I could work as much and eat as much as a man––when I could get it––and bear the lash as well! And ain’t I a woman? I have borne thirteen children, and seen most all sold off to slavery, and when I cried out with my mother’s grief, none but Jesus heard me! And ain’t I a woman?10 Paulette M. Caldwell, A Hair Piece: Perspectives on the Intersection of Race and Gender, 1991 DUKE L.J. 365, 395. 7. The story of what transpired at this Convention is recounted in several places, with different spellings used to capture Sojourner’s words. This Article uses language set forth on the Sojourner Truth Memorial website. Sojourner’s Words and Music, SOJOURNER TRUTH MEMORIAL, http://sojournertruthmemorial.org/sojourner-truth/her-words (last visited May 2, 2017) (“‘Ain’t I a Woman?’ as recounted by Frances Gage, in 1863”); see also NELL IRVIN PAINTER, SOJOURNER TRUTH: A LIFE, A SYMBOL 164–75 (1996) (using different spellings). 8. PAINTER, supra note 7, at 166 (recounting events at the Convention as told by Frances Dana Gage). Painter notes, however, that Gage may have overemphasized the anti-black sentiment in her account. Id. at 169. 9. Id. at 166–67. 10. SOJOURNER TRUTH MEMORIAL, supra note 7. Sojourner also offered a powerful rebuttal (reportedly with some success) to the theologians’ assertions that women were too mentally feeble to vote, and inferior to men because God/Jesus was a man. Sojourner observed: Then they talk about this thing in the head; what’s this they call it? [member of audience whispers, “intellect”] That’s it, honey. What’s that got to do with women’s JONES-NORWOOD_PP_FINAL (DO NOT DELETE) 7/25/2017 11:48 PM 2024 IOWA LAW REVIEW [Vol. 102:2017 In this powerful speech, Sojourner not only proclaimed Black women’s womanhood, she also called attention to Black women’s history of oppression and the fact that in key respects this history differed from that of White women. Unlike White women, who allegedly had been placed on a pedestal (which was revealed to be a cage)11 and who had been assumed too delicate to exercise basic civil rights like the right to vote, Sojourner noted that Black women had plowed and planted and endured the ravages of slavery.12 Yet, they too were denied the right to vote. In short, Sojourner revealed that arguments used to subordinate White women were different from and at times contradicted by arguments that were used to subordinate Black women. This formerly enslaved woman and itinerant preacher clearly saw the intersectional nature of women’s experiences and the ways in which recognition of this multidimensionality could counter arguments made to oppress all women (e.g., Black women’s experiences in 1851 countered the narrative that women were too delicate to exercise basic rights of citizenship). In her vulnerability, Sojourner exercised her powerful voice to expose and to resist: (1) the prioritization of White women’s needs; and (2) the assumption that White women’s experiences represent the experiences of all women, when in fact they do not.13 A similar challenge to the erasure of Black women’s history, the prioritization of White women’s objectives, and the assumption of a universal women’s experience has been made by women of color in the academy. In 1982, in a powerful collection of essays entitled All the Women Are White, All the Blacks are Men, But Some of Us are Brave,14 Gloria Hull and other Black feminists rights or negroes’ rights? If my cup won’t hold but a pint, and yours holds a quart, wouldn’t you be mean not to let me have my little half measure full? Then that little man in black there, he says women can’t have as much rights as men, ‘cause Christ wasn’t a woman! Where did your Christ come from? Where did your Christ come from? From God and a woman! Man had nothing to do with Him. If the first woman God ever made was strong enough to turn the world upside down all alone, these women together ought to be able to turn it back, and get it right side up again! And now they is asking to do it, the men better let them. Id. 11. As Justice Brennan famously noted, the “romantic paternalism” justification for sex discrimination put White women in a cage, rather than on a pedestal. Frontiero v. Richardson, 411 U.S. 677, 684 (1973) (“Traditionally, [sex] discrimination [in the United States] was rationalized by an attitude of ‘romantic paternalism’ which, in practical effect, put women, not on a pedestal, but in a cage.”). 12. PAINTER, supra note 7, at 167. 13. These challenges not only affected first-wave feminism, they also plagued second-wave feminism. For a discussion of the ways in which first- and second-wave feminism failed to address the specific needs of women of color see ANGELA Y. DAVIS, WOMEN, RACE & CLASS 110–26 (1981); ESTELLE B. FREEDMAN, NO TURNING BACK: THE HISTORY OF FEMINISM AND THE FUTURE OF WOMEN 91–93 (2002); PAULA GIDDINGS, WHEN AND WHERE I ENTER: THE IMPACT OF BLACK WOMEN ON RACE AND SEX IN AMERICA 159–70, 299–311 (1996); and Kirsten West Savali, ‘When and Where I Enter’: The Racist Expectations of Whites-Only Feminism, ROOT (Apr. 23, 2016, 3:00 AM), http://www.theroot.com/when- and-where-i-enter-the-racist-expectations-of-whit-1790855079. 14. See generally ALL THE WOMEN ARE WHITE, ALL THE BLACKS ARE MEN, BUT SOME OF US ARE BRAVE: BLACK WOMEN’S STUDIES (Gloria T. Hull et al. eds., 1982). JONES-NORWOOD_PP_FINAL (DO NOT DELETE) 7/25/2017 11:48 PM 2017] AGGRESSIVE ENCOUNTERS & WHITE FRAGILITY 2025 examined how discussions of gender and race often exclude the voices of Black women. In other words, the essays explore how Black women are rendered invisible in both dialogues about race and dialogues about gender.15 In the legal academy, Professors Kimberlé Crenshaw and Angela Harris have offered similar critiques to Hull. In her seminal article, Demarginalizing the Intersection of Race and Sex: A Black Feminist Critique of Antidiscrimination Doctrine, Feminist Theory and Antiracist Politics,16 Professor Crenshaw critiques the “tendency to treat race and gender as mutually exclusive categories of experience and analysis.”17 She notes: [D]ominant conceptions of discrimination condition us to think about subordination as disadvantage occurring along a single categorical axis. . . . [T]his single-axis framework erases Black women in the conceptualization, identification and remediation of race and sex discrimination by limiting inquiry to the experiences of otherwise-privileged members of the group. In other words, in race discrimination cases, discrimination tends to be viewed in terms of sex- or class-privileged Blacks; in sex discrimination cases, the focus is on race- and class-privileged women. This focus on the most privileged group members marginalizes those who are multiply-burdened and obscures claims that cannot be understood as resulting from discrete sources of discrimination. . . . [T]his focus on otherwise-privileged group members creates a distorted analysis of racism and sexism because the operative conceptions of race and sex become grounded in experiences that actually represent only a subset of a much more complex phenomenon.18 Importantly, Professor Crenshaw maintains that Black women’s experiences are not merely additive (Black men’s experience + White women’s experience = Black women’s experience). Rather, Crenshaw’s insight is that race and gender are always interconnected and never exist as separately distinct, disaggregated identities.19 15. The anthology provided materials for courses in the nascent field of Black women’s studies. In speaking to the need to study Black women’s experiences, Hull notes that “[w]omen’s studies courses . . . focused almost exclusively upon the lives of white women, [and] Black studies, which was much too often male-dominated, also ignored Black women.” Id. at xx. 16. See generally Kimberlé Crenshaw, Demarginalizing the Intersection of Race and Sex: A Black Feminist Critique of Antidiscrimination Doctrine, Feminist Theory and Antiracist Politics, 1989 U. CHI. LEGAL F. 139. 17. Id. at 139. 18. Id. at 140 (emphasis added). 19. Other scholars have employed different terminology in critiquing a single-axis framework. See, e.g., Devon W. Carbado, Black Rights, Gay Rights, Civil Rights, 47 UCLA L. REV. 1467, 1518 (2000) (describing the problem as one of “compound discrimination”); Darren Lenard Hutchinson, Out Yet Unseen: A Racial Critique of Gay and Lesbian Legal Theory and Political Discourse, 29 CONN. L. REV. 561, 633–34 (1997) (employing the term “multidimensionality”); Mari J. Matsuda, When the First Quail Calls: Multiple Consciousness as Jurisprudential Method, 14 WOMEN’S RTS. L. REP. 297, 297–99 (1992) (employing the phrase “multiple consciousness”). JONES-NORWOOD_PP_FINAL (DO NOT DELETE) 7/25/2017 11:48 PM 2026 IOWA LAW REVIEW [Vol. 102:2017 Professor Angela Harris has added to the analysis by pointing out that there is nothing “essential” about gender that causes all women to share the same experience of sexism. There is no monolithic or universal “women’s experience.” Rather, “sexism” is always mediated by racism, classism, homophobia, etc.20 Harris explains: [T]he result of th[e] tendency toward gender essentialism . . . is not only that some voices are silenced in order to privilege others (for this is an inevitable result of categorization, which is necessary both for human communication and political movement), but that the voices that are silenced turn out to be the same voices silenced by the mainstream legal voice of “We the People”—among them, the voices of black women.21 Harris extends her anti-essentialism critique to race, noting that “[a] corollary to gender essentialism is ‘racial essentialism’—the belief that there is a monolithic ‘Black Experience,’ or ‘Chicano Experience.’”22 Although the majority of this Subpart has examined gender essentialism, interrogating racial essentialism is equally important because society often overlooks Black women’s contributions to racial justice struggles.23 B. CONTEMPORARY EXAMPLES The above analysis shows that for centuries mainstream feminism has asked Black women to put aside race and to focus on gender;24 at the same time, movements for racial equality have asked Black women to put their concerns about sexism on hold until racial justice is achieved.25 While 20. See Angela P. Harris, Race and Essentialism in Feminist Legal Theory, 42 STAN. L. REV. 581, 585 (1990) (defining “gender essentialism” as “the notion that a unitary, ‘essential’ women’s experience can be isolated and described independently of race, class, sexual orientation, and other realities of experience”). 21. Id. 22. Id. at 588. 23. See GIDDINGS, supra note 13, at 183–97, 302 (discussing the complex relationship of Black men and women in struggles for racial justice); Tarana Burke, History Repeats Itself: The Dangers of Erasing Women from the Movement, ROOT (Oct. 22, 2016, 6:15 AM), http://www.theroot.com/history-repeats- itself-the-dangers-of-erasing-women-fr-1790857379 (discussing history’s failure to acknowledge Black female leaders of the Civil Rights Movement like Diane Nash, Marie Foster, Ella Baker, Fannie Lou Hamer, and Johnnie Carr). 24. See Sherri Williams, Historic Exclusion from Feminist Spaces Leaves Black Women Skeptical of March, NBC NEWS (Jan. 21, 2017, 9:24 AM), http://www.nbcnews.com/news/nbcblk/decades-exclusion- leave-black-women-skeptical-womens-march-n710216 (“[T]he roots of the early feminist movement were entrenched in disregard for black women. Suffrage leader Susan B. Anthony infamously said, ‘I will cut off this right arm of mine before I will ever work or demand the ballot for the Negro and not the woman.’”). 25. See Cherise Charleswell, Herstory: The Origins and Continued Relevancy of Black Feminist Thought in the United States, HAMPTON INST. (Feb. 27, 2014), http://www.hamptoninstitution.org/black- feminist-thought.html (“All too often [during the Black Liberation Movement and Women’s Movement], ‘black’ was equated with black men and ‘woman’ was equated with white women; and the end result of this was that black women were an invisible . . . .”). Debate surrounding the controversial nomination of Judge Clarence Thomas to the United States Supreme Court illustrates this point. See Emma Coleman Jordan, Race, Gender, and Social Class in the Thomas Sexual Harassment Hearings: The