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analysis of the closet symbol may be concretely tethered to judicial outcomes. In both Sipple and Coors, the rule of law at issue was ostensibly neutral on its face. The Sipple court operated on a premise of neutrality, implicitly finding that the rule should not be group sensitive. Thus, it suggested that the efforts of a person attempting to maintain a public and private identity should not be protected even where there were valid motives particular to his group for doing so. The Coors court rejected that premise of neutrality, emphasizing that civil suits (and specifically the ostensibly neutral discovery rules used therein) could be used as "coercive devices to cripple, or subdue, vocal opponents," 2 89 and noting that the need of many gays for anonymity makes them peculiarly vulnerable in this regard. The Coors court recognized that to allow the discovery motion could, in essence, end the case, as avoiding forced disclosure might be worth more to the defendants than defending the suit. Even a conservative approach to these cases shows that to overcome a court's default presumption that neutrality means applying rules against 287. Id. at 209 n.24 (citation omitted). 288. Cf. Baker v. Wade, 553 F. Supp. 1121 (N.D. Tex. 1982) (giving detailed narrative of gay plaintiff's struggle with his sexual identity), rev'd en banc, 769 F.2d 289 (5th Cir. 1985). 289. Coors, 570 F. Supp. at 209. 1996] 1815 HeinOnline -96 Colum. L. Rev. 1815 1996

Suspect Symbols: The Literary Argument for Heightened Scrutiny for Gays