Page:Adams ex rel. Kasper v. School Board of St. Johns County, Florida (2022).pdf/56

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USCA11 Case: 18-13592 Document: 304-1 Date Filed: 12/30/2022 Page: 56 of 150

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Lagoa, J., Specially Concurring
18-13592

than females, run (11%) faster than females, and accelerate (20%) faster than females” on average. Jennifer C. Braceras, et al., Competition: Title IX, Male-Bodied Athletes, and the Threat to Women’s Sports, Indep. Women’s F. & Indep. Women’s L. Ctr. 20 (2021) (footnotes omitted). The largest performance gap may be seen “in the area of strength.” Id. Studies also have shown that males “are able to lift 30% more than females of equivalent stature and mass,” as well as punch with significantly greater force than females. Id.

Importantly, scientific studies indicate that transgender females, even those who have undergone testosterone suppression to lower their testosterone levels to within that of an average biological female, retain most of the puberty-related advantages of muscle mass and strength seen in biological males. See generally, e.g., Hilton & Lundberg, supra. As such, “trans women and girls remain fully male-bodied in the respects that matter for sport; [and] because of this, their inclusion effectively de-segregates the teams and events they join.” Coleman et al., supra, at 108. This is because:

[F]emale sport is by design and for good reasons, a reproductive sex classification. These reasons have nothing to do with transphobia and everything to do with the performance gap that emerges from the onset of male puberty. Whether one is trans or not, if one is in sport and cares about sex equality, this physical phenomenon is undeniably relevant. Changing how we define “female” so that it includes individuals