Goodridge v. Department of Public Health

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Following is the case brief for Goodridge v. Department of Public Health, 798 N.E.2d 941 (Mass. 2003)

Case Summary of Goodridge v. Department of Public Health:

  • Seven same-sex couples were denied marriage licenses in the State of Massachusetts. They sued the government, stating that denying marriage to same-sex couples violates Massachusetts law.
  • The state Superior Court granted the government’s motion for summary judgment.  It held that allowing marriage only for opposite-sex couples furthers the primary purpose of marriage laws — procreation.
  • On direct appeal, the Supreme Judicial Court of Massachusetts vacated the judgment for the government.  The Supreme Judicial Court held that denying same-sex marriage violated equal protection of the laws and due process, thereby violating the Massachusetts Constitution.

Goodridge v. Department of Public Health Case Brief

Statement of the Facts:

Plaintiffs are seven same-sex couples who were denied marriage licenses in Massachusetts. The defendant, the Massachusetts Department of Public Health, is charged with, among other things, overseeing the issuance of marriage licenses.  Plaintiffs sued in state Superior Court. They alleged that refusing to allow same-sex couples to marry violates Massachusetts law. Both parties filed cross motions for summary judgment.

Procedural History:

  • The Superior Court granted summary judgment to defendant and dismissed plaintiffs’ complaint.
  • The court held that the Massachusetts Constitution does not guarantee a fundamental right to same-sex marriage.  It further concluded that Massachusetts’ policy of only allowing opposite-sex couples to marry furthers the primary purpose of marriage — procreation.
  • Both parties requested direct appellate review to the Supreme Judicial Court of Massachusetts.  Direct appellate review was granted.

Issue and Holding:

Is the denial of marriage to same-sex couples a violation of the Massachusetts Constitution?  Yes.

Judgment:

Summary judgment for defendant is vacated, and the case is remanded for a judgment consistent with the Supreme Judicial Court’s opinion.

Rule of Law or Legal Principle Applied:

Barring a person from the benefits and obligations of civil marriage solely because that person wishes to marry someone of the same sex violates the Massachusetts Constitution.

Reasoning:

  • The current marriage license laws cannot be read to include same-sex couples.

Plaintiffs argue, as a threshold matter, that the Massachusetts marriage license laws do not actually discriminate against same-sex couples.  A reasonable reading of the marriage license laws, however, demonstrates that the Legislature intended to allow only opposite-sex couples to marry.

  • It is unfair to exclude people from the many benefits of marriage.

Civil marriage enhances the welfare of a community by encouraging stable relationships, allowing for the ordered distribution of property, and the caring of young and old family members.  It also confers valuable property rights to married individuals.  The benefits of marriage touch virtually every aspect of life and death.  Accordingly, it is not fair to deny those benefits to otherwise eligible people who wish to marry.

  • Marriage laws have evolved over the course of history.

Up until the 1960s, white and African-Americans were not allowed to marry in this country. That change demonstrates that marriage laws yield to a better developed understanding of invidious discrimination in society.  Further, the Massachusetts Constitution is more protective of individual liberty than the Federal Constitution.  Here, this case involves freedom from government intrusion into a protected sphere of life, and freedom to partake in benefits for the common good of the State.

  • The government’s three rational-basis arguments are without merit.

The appropriate standard of review for plaintiffs’ equal protection and due process challenge is rational basis review, i.e., whether discrimination against same-sex couples is rationally related to a legitimate government purpose.  The three arguments advanced by defendant are unpersuasive.  First, procreation has never been the primary, or only, purpose for marriage. Second, there is no real evidence showing that children raised by opposite-sex parents are better off than children of same-sex parents.  Third, marriage has never been allowed for only those couples who would benefit each other, or the State, economically by being married.

  • Same-sex marriage strengthens, rather than undermines, the institution of marriage.

The fact that same-sex couples seek to be married shows how important the institution of marriage is to peoples lives.  Moreover, the history of constitutional law is a path to extending rights to people once excluded or ignored.  The marriage ban argued by defendants puts a substantial portion of the community at a disadvantage for no rational reason.  The idea that a ban on same-sex marriage reflects society’s view that homosexuality is immoral belies Massachusetts’ laws against discrimination based on sexual orientation.

For all of the above reasons, barring the benefits and obligations of marriage to same-sex couples violates the Massachusetts Constitution.

Concurring and Dissenting Opinions:

Concurring Opinion (Greaney):

The denial of marriage licenses for same-sex couples is gender discrimination.  Under the current law, a person’s choice of spouse is limited by the person’s gender.

Dissenting Opinion (Cordy):

The legitimate state purpose of providing the optimal environment for children militates against allowing same-sex marriage.

Dissenting Opinion (Spina):

The power to regulate marriage lies with the Legislature, not the courts.

Dissenting Opinion (Sosman):

The State does not have to support every variation of household structure.  Until there is a consensus or unanimity of scientists that same-sex households are not detrimental, it is appropriate to wait on the issue of allowing same-sex marriage.

Significance:

Goodridge v. Department of Public Health is truly a landmark decision in the United States.  It is the first case in the highest court of any State to declare that marriage (rather than civil unions) should be permitted for same-sex couples, and that denying marriage to same-sex couples violates equal protection and due process.  The U.S. Supreme Court eventually followed Goodridge v. Department of Public Health twelve years later in the case of Obergefell v. Hodges, 135 S. Ct. 2584 (2015), making same-sex marriages legal throughout the country.

Student Resources:

http://caselaw.findlaw.com/ma-supreme-judicial-court/1447056.html

https://www.glad.org/cases/goodridge-et-al-v-dept-public-health/