Thanks for this post. I’d be interested to see what your research comes up with.

A couple of notes.

1. The decision that you pointed to isn’t actually about the cartoons that Hustler published, it’s about a short passage printed in Hustler after she filed suit over the cartoons, which read:

His client is “little guy” militant lesbian feminist Andrea Dworkin, a shit-squeezing sphincter in her own right. In her latest publicity-grab Dworkin has decided to sue Hustler for invasion of privacy among other things.

Dworkin seems to be an odd bedfellow for “just folks,” “family values” Spence. After all, Dworkin is one of the most foul-mouthed, abrasive manhaters on Earth. In fact, when Indianapolis contemplated an antizorn ordinance co-authored by Dworkin, she was asked by its supporters to stay away for fear her repulsive presence would kill the statute * * *. Considering that Dworkin advocates bestiality, incest and sex with children, it appears Gerry “this Tongue for Hire” Spence is more interested in promoting his bank account than the traditional values he’d like us to believe he cherishes.

This case is a nuisance suit initiated by Dworkin, a crybaby who can dish out criticism but clearly can’t take it. The real issue is freedom of speech, something we believe even Dworkin is entitled to, but which she would deny to anyone who doesn’t share her views. Any attack on First Amendment freedoms is harmful to all [,] Spence’s foaming-at-the-mouth client especially. You’d think someone of Spence’s stature would know better than to team with a censor like Dworkin.

Again, we’d need to see the briefs. But given the comments in the decision and the facts about Andrea, it’s likely that what she was complaining about as libelous was probably (1) the claim that her suit was a “publicity-grab” and a “nuisance suit” (the latter admits of a technical definition that the Court seemed to contort itself a bit to avoid dealing with); (2) the claim that “when Indianapolis contemplated an antizorn ordinance co-authored by Dworkin, she was asked by its supporters to stay away for fear her repulsive presence would kill the statute”, and (3) the claim that “Dworkin advocates bestiality, incest and sex with children”. The rest seems to be just garden-variety abuse and sleaze, with the exception of the description of Dworkin as a “militant lesbian feminist”, but none of those are terms that she ever hesitated to apply to herself (except when, as in Biological Superiority, she felt she was being bullied).

1. In 1977, Dworkin wasn’t a lesbian separatist, but lesbian separatism wasn’t what she was attacking in Biological Superiority. She footnotes the passage that you cite:

SuperWomon’s ideology is distinguished from lesbian separatism in general (that is, lesbians organizing politically and/or culturally in exclusively female groups) by two articles of dogma: (1) a refusal to have anything to do with women who have anything to do with males, often including women with male children and (2) the absolute belief in the biological superiority of women.

(1) and (2) are what Dworkin is characterizing as “ideological rot”, not “lesbian separatism in general”. You can be a lesbian separatist without committing to (1) or believing in (2), and in fact many (probably most, but I haven’t taken any surveys) lesbian separatists weren’t committed to either.

I think you are reading too much into it.

The ruling doesn’t indicate that Dworkin’s brief singled out the description of her as a lesbian as libelous (indeed the ruling says she doesn’t challenge that description in her brief). I’d have to see the appellate briefs (which may be out there, but which I can’t find on the Internet) to know for sure, but it looks pretty likely that Dworkin identified the whole passage as libelous, and that the four claims considered by the court were what the judge parsed out as the statements of fact contained in the passage, not anything that Dworkin singled out. It’s a short passage, and the claim that she’s a lesbian is contained in a single adjective rather than so much as a whole sentence, so it would have been hard to complain about a libel in it without including the sentence in which she is described as a lesbian—even if the description of her as a lesbian is not what she was calling libelous.

Andrea was, incidentally, openly a lesbian, as she attests not only in her address but also e.g. in her memoir, Heartbreak and in numerous interviews. (John Stoltenberg’s essay about living with Andrea recounts how the editor of the New York Times Style page refused to allow the writer to identify them as gay and lesbian, as they had asked to be identified, in 1985.) You might think that the fact that they thought of each other as “life partners” and “in love” with each other tends to disqualify her as a lesbian and him as gay. Without prying unnecessarily into their sex lives, this at least seems like good reason to think that they were intensely romantically connected. But that’s only true if you think that “lesbian” means “a woman only romantically involved with other women” and gay means “a man only romantically involved with other men.” Some people use the words that way and other people don’t; it’s important, if nothing else, to know that a lot of women in the lesbian and radical feminist communities in the 1970s didn’t use the word that way. So it’s not weird or unusual that Andrea Dworkin would describe herself that way.