Black and White Women Athletes within Traditional Hegemonic Discourse of Femininity, Heterosexuality, and Race in the Media

by Shelby Mack

The domain of athleticism has typically held women athletes to certain standards when it comes to performance, appearance, and body type.  These standards can be especially attributed the societal pressure to achieve hegemonic femininity and heterosexuality.  Being an avid weightlifter/powerlifter/bodybuilder and former track and field athlete,  I consider athleticism as central to my identity.  This has shaped many of my daily activities, interactions, and experiences.  I am very aware of the ideological norms that objectify and hinder women within the field of athletics.  Within my history of athleticism I have acknowledged the normativity and acceptability in which I am supposed to remain.  Whether this involves adhering to gendered, heterosexualized, and racialized norms to gain tolerance and approval, “transgressing” norms of gender, heterosexuality, and race through my body presentation, or a mix in between of adherence and subversion, I have always had to struggle to project an image of myself that I find satisfying, which I often present through social media.

My experience as a women athlete has been intense as I have been bombarded with standards of hegemonic femininity, heterosexuality and whiteness within society, represented through acceptable images that reinforce these structures within the media.  While these constrict and apply to all women athletes, I am very aware of my positionality as a generally privileged athletic woman: I am muscular, but not to the extent where I am unattractive to men; I am slightly masculine, however not to an insufferable degree where my gender is ambiguous (although this may become more questionable a buzz cut), and very important to my analysis; I am white, which plays a key role in my acceptability and popularity within the field of athletics, as well as the way in which I am able to represent myself.

These are normative constraints to which all women are judged harshly for their bodies within heteropatriarchal, white supremacist society.  Women athletes are no exception to this rule: their bodies are read through their experiences within athletics, to which hegemonic femininity, heterosexuality, and race are enacted and inscribed within them to create an idealized and acceptable image indubitably illustrated within the media, bearing the ultimate representation that viewers observe of these athletic women.  Being aware of my own positionality as an athletic woman, I seek to delve further into the area of the standards set forth by society in order to police and define women’s athletic bodies to gendered and racialized normativity, especially within media depictions of acceptability of athletic women.  Secondly, I will analyze media depictions of white and Black women athletes, wherein white women athletes are held to a much different standard and positionality in sport than Black women athletes in regards to race, femininity, and heterosexuality that differentiates their images and athletic careers.

Vikki Krane (2001) has stated that the arena of sports has been historically dominated by men, wherein the heavily masculinized sphere of sports reflects male patriarchal domination in outer society.  Women’s admittance and participation within the domain of sports has been questioned and restricted due to its highly masculine gendered nature.  However the prevalence and popularity of women’s athletics is increasing (Krane 2001).  Nonetheless, women athletes are still very prone to the societal forces that remain a hindrance to women’s participation in public life: athletic activities and the bodies and appearances of women athletes are often altered to be able to adhere societal adequacy (Krane 2001).  Athleticism is usually processed as the antithesis of  femininity: athletics often require masculine traits such as aggressiveness, violence, strength, and competitiveness, traits that are often considered unfeminine and manly, framing women’s participation within them as inappropriate (Krane 2001).  Women often have to exonify the feminine aspects of sports to utilize their sexuality in order to become upstanding athletes worthy of praise (Krane 2001).

Women athletes who are considered too masculine, too muscular, and too manly pay heavy consequences, such as prejudice, stereotypes, discrimination, and labels such as “butch,” “tomboy,” “mannish,” and  “lesbian,” among others (Krane 2001).  These stigmatizations can lead women to face harsh calls from officials, violence, anger from fans, career restraints, lower pay, and more (Krane 2001, Abdul-Jabbar 2015).  Gender, gender roles, and heterosexuality are often used as key principles in organizing and examining women’s sport when deciding what is suitable and acceptable for men and women in athletics (Krane 2001).  Gender dictates the femininity and masculinity in which one’s identity expresses itself, and gender roles attribute gender into the activities taken by women (for example, ice hockey for men, figure skating for girls) which determines normality or abnormality within our endeavors, in which case we tend to associate gendered sports with their appropriate genders (Krane 2001).  Heterosexuality maintains a sizeable function in policing women’s athletic bodies additionally.  In order to maintain social acceptability, women athletes must maintain their heterosexual attractiveness: they must be small, thin, sexy, “toned,” wear makeup, have long hair, etc. (Krane 2001).  This maintains the sphere of women’s sports as socially acceptable, wherein feminine capability influences one’s ability to be heterosexually attractive, wherein all of women’s worth as individuals lies in the ability to be commodified by men, which transcends through the public realm into the notion the marketability of women’s athleticism to benefit men all the while not threatening their masculinity.

While Vikki Krane does a fantastic job highlighting the feminine and heterosexual expectations women athletes must endure for social acceptability, she fails to incorporate race into her equation.  Stephanie L. Young (2015) does a superb job of analyzing the intersections of women’s athletic bodies, femininity, heterosexuality, and race in the way she writes of the discourse surrounding Caster Semenya, a Black South African woman who is a legend on the national track team of her country.  She is a phenomenal athlete, however, upon winning the IAAF Championship over her competitors, complaints (by mostly white women athletes) arose over her unduly masculine appearance, stating how competing against someone who was “like a man” in their minds was unfair and, in many regards, cheating (Young 2015).  Such complaints led to Semenya being subjected to sex testing, wherein it was found that she has hyperandrogenism, a form of intersexuality within the body (Young 2015).  Caster Semenya’s case came into the public eye when conversation began around about stripping her of her victories and the right to compete at an international level among women (Young 2015).  Notwithstanding this public discourse, her fans and supporters began to fight back, claiming that Semenya’s circumstances had less to do with her sex identity and more to do with policing Black women’s bodies as masculine and abnormal (Young 2015).  Media outlets discussed the situation in terms of evoking the painful racist history of the Black female body, comparing Semenya’s bodily examinations and public attention to another famous South African woman, Saartjie Baartman, the ‘‘Hottentot Venus,”  whose body was sexualized, probed, prodded and spectacularized for scientific and public curiosity (Young 2015).  Having Semenya’s body examined by medical professionals to verify her femaleness echoed the Baartman case, again publicly humiliating and dehumanizing an African woman to the curiosity of white people (Young 2015).

Caster Semenya’s body and sexuality became a site of control and discipline within the media, who referred to “medical discourses about ‘‘normal’’ sexed (gendered) bodies in sports,” reinforcing the gender binary and normative bodies while outcasting her from normalcy (Young, 2015, pg. 332). Semenya then had to reconfigure her entire image within the media to fit socially acceptable standards: an image of hegemonic white femininity (wherein the dominant and superior form of femininity includes notions of whiteness from a Western superiority point of view) in order to reinstate her career and repudiate claims of her being male and a man.  Semenya was turned into a “real girl,”  conforming to female gender norms of hegemonic femininity and non threatening heterosexuality (Young 2015).  She appeared in You magazine as an image of ultra femininity: her standard cornrows traded in for a combed out hairstyle that is reminiscent of long hair, she donned makeup, a black feminine pantsuit, and golden jewelry (Young 2015).  This image exceptionally contrasts with her usual extremely muscular, makeup free, cornrowed, track uniform/masculine athletic clothing that is her conventional appearance (Young 2015).  It is believed that Semenya refined her image to fit within the confines of hegemonic white femininity and heterosexual attractiveness, wherein she could be considered discernibly more acceptable if she played on these normative expectations, than had she remained masculine appearing and repugnant to the male gaze.  Caster Semenya is a fierce example of where gender, heterosexuality, race, and the athletic body intersect to control and surveille, and sanction women’s athletic bodies.


Caster Semenya, Getty Images

Black women athletes are also policed and restricted in other ways as well.  Kevin Michael Foster (2003) studies the surveillance and control of Black collegiate women athletes in Midwestern University in his article “Panopticonics: The Control and Surveillance of Black Female Athletes in a Collegiate Athletic Program.”  Utilizing the Foucauldian term panopticon, Foster (2003) describes the situation of athletes within Midwestern University as a form of “surveillance, control, and discipline” in “order to maximize participants’ athletic and academic potential” (Foster, 2003, pg 301).  This type of discipline is inflicted upon all student athletes, but none as thoroughly as the Black women athletes, wherein the department of women’s athletics, whose “ staff members routinely ascribed black student athletes with a racial identity that characterized them as immature, academically deficient, and sexually overactive. Like many other students, many black female athletes came to campus with poor academic skills and with social skills that were not appropriate to the college environment” (Foster, 2003, pg 303).  These stereotypical assumptions stripped Black women athletes of their autonomy and decision making processes that categorically framed them as rambunctious sexual deviants with no academic drive, producing the potentiality that may lead to stereotype threats.

Due to the heavy sexualization of Black women athletes on the track team (male athletes both lusted after or despised these women for seeming “full of themselves”), they drove themselves to achieve a tremendously physically fit physique, both to excel at their sport and become heterosexually attractive to men (Foster 2003).  These women also sought to dispel myths of being regarded as lesbians and mannish, consequently enabling them to adopt the jezebel stereotype to downplay beliefs of same sex desire, which were expressed through the dress, discourse, and behaviors of these Black women athletes (Foster 2003).  Here, heterosexuality, gender, sexual expression, race, and athleticism collide to produce a subjugated Black athletic woman’s body that control is inscribed upon to downplay and restrict Black women’s successfulness in the sphere of sports.

Black women’s athletic bodies are often placed within stark contrast to white women’s athletic bodies in terms of gender, sexuality, and race, which we often drastically see within media representations of women athletes.  Black women are often depicted as more masculine, more muscular, and sexually abnormal (in relation to sexuality and biological sex) in comparison to white women. This can lead one to believe that Black women athletic representations and discourses exist as an enhancer of white athletic heterosexual femininity.  Black women athletes (and Black women in general) are masculinized, muscularized, and sexualized to increase the popularity and acceptability of white women athletes.  Wherein Krane (2001) proposes that nonconformity to femininity brings negative treatment, verbal harassment, lack of media attention and endorsements, sexist and heterosexist prejudice (stigmatization of women perceived as manly and/or lesbians), and negative biases to all women, this is especially true for Black women, who do not meet society’s perceptions of femininity or beauty standards.  Toni Morrison formulates this notion when she writes, “Along with the idea of romantic love, she was introduced to another—physical beauty. Probably the most destructive ideas in the history of human thought. Both originated in envy, thrived in insecurity, and ended in disillusion. In equating physical beauty with virtue, she stripped her mind, bound it, and collected self-contempt by the heap” (Morrison, 1970, pg. 122).

The ideologies of physical beauty, along with hegemonic femininity and heterosexuality, are excessively prevalent within women’s sport, that wherein women athlete’s success, athletic ability, and athletic career depend upon appearance.  If a woman athlete fails to meet the suitable standards she either dissipates her time, resources, and body trying to achieve them, or is berated by the media for her deficiency.  According to Kareem Abdul-Jabbar (2015), “we have established a definition of beauty so narrow that almost no one can live up to it.  Women struggle to fit within the constrictions of social expectations of thin, youthful, sexuality as constricting as a Victorian corset…  Some of the body shaming of athletic black women is definitely a racist rejection of black women’s bodies that don’t conform to the traditional body shapes of white athletes and dancers… The body shaming of [Serena] Williams and [Misty] Copeland is partly because they don’t fit the Western ideal of femininity. But another cause is our disrespectful ideal of the feminine body in general.”  Abdul-Jabbar (2015) extends upon Krane’s (2001) analysis of the struggle of women with normative ideals of beauty within our society, however, he additionally proposes an analysis of how Black women struggle extensively to fit this mold of beauty that was never made to accommodate their bodies and beauty, which offers a unique vision of our perception of sports and athletic bodies.

Women athletes are often rewarded and endorsed for their adherence to Western notions of  hegemonic femininity (read: white, skinny/toned, heterosexually attractive), and sanctioned heavily when they do not meet these standards.  Within the media these women have to market their image to appeal to these hegemonic ideals and discourses of femininity, heterosexuality, and whiteness in order to maintain popularity, endorsements, and fans.  Abdul-Jabbar (2013) mentions this phenomenon in stating “beauty standards translate in sports to women being more concerned with a marketable image than athletic ability.”  Young (2015) confirms this phenomenon in stating “‘glamour’ is a more valuable asset for a woman than athletic ‘power’” one is first a woman, then an athlete, degrading women’s abilities and athleticism to a prospect of marketing and the male gaze (Young, 2015, pg 338).

Maria-SharapovaMaria Sharapova

Our societal standards and representations within the media has detrimental effects that impact women athletes’ economic capacities, careers, bodies, and popularity.  While these circumstances affect all women, not all women are impacted equally, as those who conform to socially acceptable notions of gender, sexuality, and race tend to fare better, at least in terms of monetary gain, popularity, and privilege.  This is prevalent in the case of many Black women athletes, such as Serena Williams.  “Serena Williams won her 21st Grand Slam title at Wimbledon this month. This marks the 17th time in a row that she has defeated Maria Sharapova. Yet Williams, who has earned more prize money than any female player in tennis history, is continually overshadowed by the woman whom she consistently beats. In 2013, Sharapova earned $29 million, $23 million of that from endorsements. That same year, Williams earned $20.5 million, only $12 million of that from endorsements. How’s that possible? Because endorsements don’t always reward the best athlete” (Abdul-Jabbar 2015).  Maria Sharapova is a beautiful, toned, blonde white woman, which becomes evident of her successes over Williams in regard to popularity and endorsements.

The media constantly bombards us with negative images within regards to Serena Williams, who is consistently framed as an angry, aggressive, muscular, butch Black woman.  As Claudia Rankine (2014) describes, “neither her father nor her mother nor her sister nor Jehovah nor God nor NIKE Camp could shield her from people who felt her black body didn’t belong on their court, in their world” (Rankine, 2014, pg 26).  Williams was a constant looming aura of blackness within the white world of tennis: she refused to play by their rules, from showing anger, bitterness, and frustration at being robbed of her accomplishments in bad calls made by racist officials who were distracted by her Black body, to sportscasters referring to Serena as an immature, classless gangbanger, to racial slurs and negativity from sports fans, to racist portrayals of her Black body by competitors- Serena Williams had “abandoned all rules of civility required to be a silent subjugated player complicit in the sport’s white supremacy” (Rankine, 2014, 30).  She didn’t care about respectability politics, and that was powerful.

Black women athletes are continuously scrutinized for their bodies not fitting into the narrow mold of hegemonic White femininity.  As Serena’s body was scrutinized by sports broadcasters and media outlets, “distracted” officials who poorly officiated her matches, and parodied by competitors like Dane Caroline Wozniacki, who mocked Serena’s body in a way stereotypically likened to Black women’s bodies, other Black female athletes have also faced this conflict as well (Rankine 2014).   Serena Williams, Misty Copeland and Simone Biles are three extraordinary Black women athletes, who compared to media depictions of white athletes (Maria Sharapova, Shawn Johnson, and Alex Morgan are used in this analysis) we can see the true disparity in representation between Black and white women athletes, wherein the media ultra feminizes white women athletes while masculinizing Black women athletes, who then attempt to reconfigure their own images through adherence to femininity.

As previously stated throughout this analysis, athletic women’s bodies are held to impossible standards throughout our society, and they are replicated through the images we see within magazines, sports broadcasting, marketing images, and other forms of media that are used to continuously construct and rectify hegemonic white femininity within the domain of athletics.  This can especially be seen within media advertising campaigns towards athletic women who are coerced into maintaining a certain standard of beauty, while also replicating femininity and heterosexuality,  that are sometimes built off of the images of other women athletes.

Beginning with Serena William’s Nike Unlimited (2016) commercial, one can observe the different aspects of both masculinity and femininity inscribed upon her body.  Serena displays her intense drive, competitiveness, athleticism, protruding muscles, and strength, all of these being characteristics of masculinity, and in the case of men are vital to a successful athletic career (Nike 2016).  However, these traits are not consistent with successful femininity, especially women’s athleticism.  Media characterizations that portray Serena in this light continuously recreate the stereotype of Serena being an angry, aggressive Black woman, which in turn harms her image and career, as well as perpetuates her as an unattractive, manly, overtly masculinized, and in some cases, lesbian woman.  However, Serena does make an effort to confront and contrast against these negative impressions by perpetuating elements of femininity. She achieves this feat with subtle hints of makeup, long, straight hair, engages in intense physical activity, but physical activity that mostly includes low resistance and cardio, a signifier of acceptable feminine activity, and exhibits feminine clothing that includes dresses and skirts in the form of athletic wear (Nike 2016).  This is a possible attempt on behalf of Serena to subvert racist, sexist, and homophobic remarks and images that are exacerbated by the media, as she strives to reclaim her image and her body.  This reclamation of femininity was also highlighted in 2017 with her pregnancy photographs in Vanity Fair, her wedding in Vogue’s pages, and her commercial for Gatorade, featuring her in her new role as mother.


Serena Williams in Vanity Fair (2017)

One of Serena’s biggest “rivals,” Maria Sharapova, whom as previously mentioned Williams has championed over 17 times (and yet still makes less money due to endorsements), is also featured in a Nike (2009) commercial.  Maria Sharapova definitely comes off as competitive and driven, however these qualities are chastised to a lesser extent and are more acceptable for her to enact than in Black women athletes, like Serena Williams.  One can truly observe her adherence and acceptability within hegemonic white femininity: she is heterosexually attractive, thin yet toned, blonde with long hair, and her lack of desire to be muscular and strong is not threatening to men (Nike 2009).  Her words are almost mirrored within Abdul Jabbar’s (2015) article when she says “I can’t handle lifting more than five pounds. It’s just annoying, and it’s just too much hard work. And for my sport, I just feel like it’s unnecessary” and speaks of how being strong and muscular is unnecessary, but maintaining a small, flexible body is ideal in the sport of tennis to be successful (a phenomenon which Serena Williams proves false, and seems to have more to do with feminine aesthetic) (Nike 2009).  While this may not have been a direct insult to Serena Williams, it is implied that her power, strength, muscularity, and assumed masculinity stand in heavy contrast within the white, feminine arena of women’s tennis, and that true success (popularity and money, not athleticism) is dependant upon these standards.

Misty Copeland is another Black woman athlete whose body and career is impacted by images and representation evoked through the media.  In her Under Armour (2016) commercial, Misty Copeland is espied performing a ballet routine while a narrator recites the letter that she received from the ballet academy in which she applied when she was a thirteen (Under Armour 2016).  The note reads: “Dear candidate, Thank you for your application to our ballet academy. Unfortunately, you have not been accepted. You lack the right feet, Achilles tendons, turnout, torso length, and bust.  You have the wrong body for ballet. And at 13, you are too old to be considered…” (Under Armour 2016)  The expectations and stereotypical depiction of this Black athletic woman’s body is astounding, that at the age of thirteen she was rejected due to racist implications of her body type as being inappropriate for the (white dominated) world of ballet, where, like Serena, she would participate with great contrast to her associates.  The conventional corporeality to which Misty Copeland’s body was distinguished was based upon notions of acceptable white hegemonic femininity and heterosexual appeal.  The racialized, gendered, and sexualized body (yes, even at the age of thirteen) of Copeland were weighed upon to produce an imagery in which the white patriarchal institution of ballet would come to reject.  Even after proving wrong those who doubted and rejected her, media images still perpetuate Copeland in a slightly masculinized, muscular light: muscles and striations are considerably visible upon her body within the Under Armour (2016) commercial, as well as powerfulness, which contrasts against our typical notions of ballet dancers as lithe and graceful.  However, with her heterosexual attractiveness, feminine dress, and long, straight hair, Copeland does do well in replicating the models of hegemonic femininity, race, and male seductive capability to a great degree (Under Armour 2016).


Misty Copeland in “Under Armour” ad

Simone Biles, an Olympic Gold Medalist for gymnastics, was described within her Nike (2016) commercial through narration as hyperactive, competitive, driven, and stubborn, all traits with potent ties to masculinity, as well as to blackness.  Black women are characteristically stereotyped as hyperactive and stubborn, which hold possibility as masculine traits, along with drive and competitiveness.  These traits masculinize the image of Simone Biles before we even observe the athleticism in her body, which unsurprisingly carries drastic signs of muscularity: her muscles bulge with every move, intense training scenes are captured that portray Biles as powerful, and a body that until recently we have not seen represented within the world of gymnastics (Nike 2016).  Simone Biles’ body definitely attracts attention among the white background of her slender, lithe, white competitors.  Meanwhile, Simone Biles does hold some markers of femininity: her bodysuits are very feminine in appearance, she has long, straight hair, and the narrator of the commercial (her mother) speaks on Simone making time for fun in her sport, laughing, giggling, and having a good time (Nike 2016), which introduces the feminine aspects of sports such as teamwork, friendship, and fun that make athletics a socially acceptable activity for women to participate in (Krane 2001).  Both characteristics of femininity and masculinity are demarcations of how Simone Biles presents her body versus how the media chooses to represent her to viewers.


Olympic champion and gymnast Simone Biles

Shawn Johnson, another Olympic gymnast, appears in her Olympic commercial (Meyocks 2013) in a much more feminine way than Biles.  While there is discussion of her competitiveness and drive, it seems much softer, with different undertones and meanings, all the while classical music plays in the background, creating a feminine scene (Meyocks 2013).  While in a fleeting image we see a glimpse of her sizeable deltoid muscles, this does not take away from her lithe, graceful, slender image that the media wants to present her as.  She never appears to be sweating, never looks to be grimacing in pain or focus, but instead looks graceful and competent in her sport and (heterosexually) attractive while doing so (Meyocks 2013).  The commercial ends with the narrator announcing “Shawn Johnson has made us all proud, and she has done it all with a smile,” in which we focus on Shawn Johnson’s smile as an image of her adherence to hegemonic femininity and heterosexuality, wherein she distinguishes gymnastics as a fun, feminine sport that women can acceptably participate in and still look beautiful (Meyocks 2013).

Alex Morgan’s Nike Unlimited (2016) commercial can be formulated into an especially intriguing analysis.  Alex Morgan is a star on the U.S. Women’s soccer team, wherein soccer as a notable contact sport contrives much debate around femininity and women’s participation.  Contact sports go hand in hand with aggressiveness, violence, and competitiveness, which are identifiers of masculinity (Krane 2001).  This leaves women soccer players in a tough situation on how to appeal to their femininity and heterosexual attractiveness, all the while maintaining proper athleticism necessary for their sport.  Within the commercial (Nike 2016), birds, flowers, sunlight, and the ocean are the opening scene, followed by Alex Morgan narratively addressing her love for soccer Nike 2016).  Alex Morgan expresses her love for soccer in the aspects of having a team, the friendships created, the sanctuary, the self expression, clearing one’s mind, and becoming an influence to little girls as a source of empowerment (Nike 2016).  All of these reasons listed as to why Morgan enjoys her sport can be attributed to the feminine aspects attributed to athleticism that are necessary to maintain acceptance.  The birds, flowers, sunlight, and ocean also hold very feminine elements in feminizing the usually masculine domain of soccer, as does representation of Morgan’s body.  Alex Morgan is a white woman who has long hair, wears makeup, and has the small, toned body of what came to be a signifier for beautiful and sexy athleticism (Nike 2016).  Here, this media representation explicitly feminizes Morgan and formulates her appeal, which significantly contributes to her success of being a woman athlete.


Olympic champion and women’s soccer Alex Morgan

Women’s athletic bodies are a site of incredulous scrutiny within our society.  Women athletes often have to reconfigure their bodies and self representation in order to not be designated as masculine, butch, lesbians, manly, etc. so as not to face discrimination, economic disparity, and career hindrances.  Women must successfully achieve hegemonic femininity and heterosexuality in order to be considered acceptable participants within the institution of sport, restricting women to shallow beauty standards, sexualized images, and preferable whiteness.  Gender, sexuality, and race intersect strongly within athletics, working to create a feminine, sexually attractive, white athlete that work within acceptable standards to allow women’s suitable participation within the male dominated sphere.  Women athletes are exceptionally portrayed within the institution of the media, which creates images that further masculinize and/or feminize athletic women, which can either heighten or harm their careers.  Women’s participation within the public sphere has always been limited, and the field of athletics is no exception.  Athleticism holds a radical potentiality to empower women, as well as contains transformative power to change their lives when women can utilize their bodies and shape their images outside of societal constrictions.  It is only when women are given the power to construct their own images to create their bodies in how they desire that they will be able to begin emancipation from the heteropatriarchal white supremacy in which we live.  The media is an institution that plays a crucial role in this transformation, but to become a positive element of change they must reconfigure its depictions of women athletes in terms of beauty standards, representation, and formulations of acceptable womanhood that will shift us away from our narrow societal ideologies.


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Shelby Mack is a Junior and M.A./B.A. student at the University at Albany.  She is a double major in Women’s, Gender, and Sexuality Studies and Sociology, as well as the President of Gamma Mu Iota Iota Iota, the UAlbany chapter of the National Women’s Studies Honor Society. She is also an active member of the UAlbany chapter of Planned Parenthood Generation Action.