"In 2006, following the horrific murder of Gwen Araujo, California became the first state to pass legislation limiting the LGBTQ+ “panic” defense. The law, named in Gwen’s honor, aimed to “curtail the use of so-called ‘panic strategies’... most widely used in criminal cases involving bias based on sexual orientation and gender identity.” More specifically, The Gwen Araujo Justice For Victims Act (AB 1160) allows parties to request “the court instruct jurors not to allow bias based on sexual orientation, gender identity or other protected bases to influence their decision.” While this bill was pending in the state legislature, Vice President Kamala Harris, at that time San Francisco District Attorney, called for a national conference on combating the LGBTQ+ “panic” defense – an action that was also undertaken in Georgia a year earlier by the Fulton County District Attorney in response to the murder of Ahmed Dabarran. Despite this flurry of action regarding the LGBTQ+ “panic” defense, for years The Gwen Araujo Justice For Victims Act remained the only legislation in the country limiting the heinous defense strategy. In 2014, California further restricted use of the LGBTQ+ “panic” defense when the state legislature passed Assembly Bill No. 2501. While the 2006 Gwen Araujo Justice for Victims Act focused on juror instruction, Assembly Bill No. 2501 codified the illegality of the LGBTQ+ “panic” defense. The new law amended Section 192 of California’s Penal Code to prohibit “the discovery of, knowledge about, or potential disclosure of the victim’s actual or perceived gender, gender identity, gender expression, or sexual orientation” from being considered objectively reasonable circumstances for a sudden altercation. This means that murder charges cannot be reduced to voluntary manslaughter through the LGBTQ+ “panic” defense in California. Importantly, the law also clarifies that this ban includes “circumstances in which the victim made an unwanted non-forcible romantic or sexual advance towards the defendant, or if the defendant and victim dated or had a romantic or sexual relationship.” Assembly Bill No. 2501 was groundbreaking as the first successful piece of legislation specifically prohibiting the use and limiting the effectiveness of the LGBTQ+ “panic” defense. For three years, it was the only legislation in the nation that acted to curtail the use of this heinous courtroom tactic."