Tuesday, March 5, 2013

Goodridge v. Department of Public Health case brief

Goodridge v. Department of Public Health case brief summary
798 N.E.2d 941 (Mass. 2003)

SYNOPSIS: Plaintiff marriage license applicants sued defendants, the state public health department and commissioner, in the Suffolk Superior Court Department (Massachusetts) for a judgment that their exclusion from access to marriage licenses violated Massachusetts law. The trial court granted defendants' summary judgment motion and denied that of the applicants. The applicants appealed, and the state supreme court granted direct appellate review.

-The applicants could not obtain marriage licenses because same-sex marriages were not recognized.

-The state supreme court held Mass. Gen. Laws ch. 207, the marriage licensing statute, did not permit same-sex couples to marry.

-Denials of the applicants' attempts to marry involved individual liberty and equality safeguards of the Massachusetts Constitution, protecting freedom from unwarranted government intrusion into protected areas of life and freedom to partake in state benefits.
-Under the equality and liberty guarantees, regulatory authority had to be rationally related to a permissible legislative purpose.
-Chapter 207 was not rationally related to the Commonwealth's asserted rationales for prohibiting same-sex marriage: (1) providing a favorable setting for procreation; (2) ensuring a two-parent family with one parent of each sex for child rearing; and (3) preserving state and private financial resources. -Procreation was not a necessary component of civil marriage, forbidding same-sex marriage would not increase opposite-sex marriages in which children were raised, and a ban on same-sex marriage was not justified by the alleged financial independence of same-sex couples.

OUTCOME: The trial court's summary judgment was vacated, and the matter was remanded to the trial court for entry of judgment, which was stayed for 180 days to allow the legislature to take such action as it deemed appropriate.


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