"Prior to the nineteenth century - or, some will say, the eighteenth - homosexuality in the western world was a practice, not an identity" (Garber, p. 213). The use of the term to describe who a person is, is to attach the negative stigma of an unacceptable behavior to the individual, thereby making the person unacceptable. This is also done as a means to sanction and prohibit the behavior. Who wants to be called a "homo" or "fag?" Being labeled a homosexual is society's way of determining what type of person you are and how you should be treated. What is also powerfully realized is that definitions of deviance and labels are handed down by those in society who decide "the norm" based on the current trend and philosophy of the time and their culture. This is important for two reasons. First, it affirms the sociological issue of power in constructing deviance. Secondly, it challenges the notion of gender being immutable and invariable over time and culture. Woodhouse excellently states this in her discussion of sex, gender, and appearance in relation to transvestites (cross-dressers). "The realization that gender is not a fixed entity, that gender roles and expectations can be questioned, attacked and changed, emphasizes the significance of viewing both gender roles and gender identity as social constructs whose meanings are continually affirmed and reaffirmed, negotiated and renegotiated through the social process of human communication and interaction" (Woodhouse, p. 119). An example of the idea that gender is fixed is shown here from NARTH's School Sex Education Guidelines: "This impression of having always "felt different" is a reflection of childhood gender nonconformity" (NARTH, p. 2), arguing it is not the case that you were born homosexual. Here again is the assumption that sex, gender role, and gender identity exhibit a conformity to, and an identity with one of two possibilities: masculinity (being primary) or femininity (being secondary).