Although Upton’s ideas were discriminatory, they were representative of the ideas shared by society at the time. Upton provided “reasons” for the gender disparity including: woman’s inability to endure struggles and cope with criticism, a lack of objective thinking to accurately understand and compose music, and emotional incapacity (Upton, 1895, p. 23,25,30). However these “reasons” were counterfactual, and the disparity was actually the result of society’s ideology similar to that of Upton’s that perpetuated and enforced gender roles that limited women’s ability influence