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Geoffrey R. Stone

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Same-Sex Marriage and Judicial Responsibility

Posted: 05/31/2012 1:14 am

Earlier this week, Lambda Legal and the ACLU of Illinois filed separate lawsuits challenging the constitutionality of the Illinois law that denies gay men and women the right to marry. There is little doubt among constitutional experts that the challenged law is unconstitutional. The central question is whether our Illinois judges will have the courage to say so.

More than most Americans today realize, throughout much of our history gay men and women have been branded as criminals, sexual psychopaths and perverts. They have been imprisoned, beaten, sterilized, ostracized, castrated, psychoanalyzed and publicly humiliated. They have been compelled to hide an essential facet of their nature, to deny who they are and to pretend to be what they are not. They have been shadowed by fear, fired from jobs, shunned by family members and friends and forced to live lives of shame. The history of our nation's treatment of gay men and women is a national tragedy.

Over the past forty years, however, we have made remarkable progress. As gays and lesbians have tentatively but courageously revealed themselves to friends and family, the views of most Americans have gradually changed. Most Americans have come to realize that gay men and women are not creepy degenerates, but people "just like us." We have discovered, often to our surprise, that they are our sons and daughters, our brothers and sisters, our neighbors and friends. With that knowledge has come greater tolerance and understanding. For most Americans, it has been an extraordinary journey of enlightened thinking and moral progress.

But we still have a way to go. The most important remaining remnant of an era now largely behind us is the continuing denial to gay men and women of the freedom to marry. This is not a mere technicality, as some would have us believe, but a grievous insult to the dignity of good and decent people and to the inherent worth of their loving commitments to one another. Indeed, from a moral and legal perspective, the refusal to recognize gay and lesbian marriage today is no more defensible than the refusal to recognize interracial marriage fifty years ago.

In an editorial on May 14, the Chicago Tribune applauded both the shift in American public opinion on this issue and President Obama's public declaration that he supports same-sex marriage. The Tribune went even further and endorsed legislation in Illinois that would recognize the right of gay men and women to marry. At the same time, though, the Tribune cautioned that courts should stay out of this matter and should "defer to the voters and their elected representatives." This is flat-out wrong.

Courts have a fundamental responsibility to enforce the Constitution. It is not their job to make political judgments about whether it would be good or bad policy for them to hold an unconstitutional law unconstitutional. If they conclude that a law is unconstitutional, then it is their duty to say so and to declare the law null and void. They have no legal authority to deprive individual citizens of their fundamental constitutional rights until "the voters" decide to grant those rights on their own. Such an approach is incompatible with the very idea of constitutional freedoms.

Before any state legislature voted to enact same-sex marriage, five state supreme courts (Hawaii, Massachusetts, Connecticut, California and Iowa) first had to hold the denial of marriage equality unconstitutional. As in so many areas of individual liberty, it took courts to lead the way. Without the constitutional foundation and legal momentum generated by those judicial decisions, it is doubtful that any state legislature would have had the courage to take on this issue. It is the very independence of courts from the electoral process that gives them the authority and responsibility to protect rights otherwise denied by "the voters."

To wait on the outcome of the electoral process to protect the constitutional rights of a group that has for so long been demonized in our society would be especially problematic. Although opinion polls show that a majority of Americans now support same-sex marriage, that is no guarantee that reform will come through the electoral process. As we have seen repeatedly in state-wide referenda on this issue, single-issue, single-minded voters, well-funded by religious organizations and driven by religious fervor, can effectively block the will of the majority. In our constitutional system, this is precisely when courts must intervene.

This situation is not dissimilar to that facing the United States Supreme Court in 1967 when it held in Loving v. Virginia that marriage is a fundamental right and that state anti-miscegenation laws prohibiting marriage across the color line violate the constitutional guarantee of "equal protection of the laws." The justices unanimously understood that they could not legitimately "defer to the voters" and hold off reaching the correct constitutional decision while the nation waited for those who feared and despised interracial marriage to catch up with the Constitution. The same is true here and now.

In addressing the fundamental constitutional issues posed by these lawsuits, our Illinois judges -- like the judges in Hawaii, Massachusetts, Connecticut, Iowa and California -- must not "defer" to the vagaries of the political process. If they conclude that it is unconstitutional for the state of Illinois to deny its gay and lesbian citizens the freedom to marry, then it is their constitutional responsibility to so rule. I predict that they will. It will be a proud day for Illinois.

This appeared in the Chicago Tribune on May 31, 2012.

 
 
 
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Earlier this week, Lambda Legal and the ACLU of Illinois filed separate lawsuits challenging the constitutionality of the Illinois law that denies gay men and women the right to marry. There is little...
Earlier this week, Lambda Legal and the ACLU of Illinois filed separate lawsuits challenging the constitutionality of the Illinois law that denies gay men and women the right to marry. There is little...
 
 
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10:38 PM on 06/03/2012
Someone needs to bring me up to speed. I don't remember anything in the US Constitution regarding marriage. Is someone wanting to add it in now?
02:42 AM on 06/04/2012
Pick up a book about constitutional law and read it. Bring yourself up to speed.
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Angel1999
Microbiologist & Historian
11:22 AM on 06/04/2012
Your asking the wrong question. The real question is: Does the Constitution allow the government to treat people differently under the exact same circumstances?

More specifically: Does the Constitution allow the government to deny benefits to one married couple while it grants benefits to a different married couple?
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11:01 AM on 06/03/2012
You're right the judiciary does have to take the lead. But not every state has a truly independent judiciary. In Iowa, Supreme Court judges are confirmed by an up or down vote every several years. Until they declared gay marriage a constitutional right this has largely been symbolic because no judge has ever been voted down or had to campaign. Until the outside haters came in and drove the justices who legalized gay marriage out of office. The only one who remains because he was on a different cycle is actively campaigning to keep his post. Also a first in Iowa but he is not repeating the mistake his colleagues made in still thinking that it was undignified to fight to keep their jobs. They could not have made a bigger mistake for the people of Iowa

"In the end, the aggressive campaign to misuse the judicial retention vote, funded by out-of-state special interests, has succeeded," Drake University Law School Dean Allan Vestal said. "The loss of these three justices is most unfortunate, and the damage to our judicial system and the merit selection of judges will take much to repair."

http://www.desmoinesregister.com/article/20101103/NEWS09/11030390/Iowans-dismiss-three-justices

I suspect other states have similar set-ups so that lofted independent judiciary in other states may be as subject to attack by idealogues and outsiders as have been the legislators. Meanwhile I am proud to live in Iowa where Gay marriage is legal.
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thehuff
05:56 AM on 06/03/2012
Yes, there are a few dinosaurs still rambling around (you can read their scratchings in these pages here) but history marches on.
It will be nice when EVERYONE has the same RIGHTS, once and for all.
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Leboazz
03:27 AM on 06/03/2012
Nothing new to Geoffrey Stone’s article…… the same tired and worn canards invoking Loving v Virginia, the false comparison of same-sex marriage to anti-miscegenation, the false moral equivalency of gay couples to opposite-sex couples…… YAWN!

Gay marriage must have as a prerequisite, a certain moral affirmation, that there is nothing wrong with homosexuality. From this, arguments in its favor can then proceed. But, in a morally relativistic universe, who is to say what is universally moral or not?

That being the case, can anyone please tell us what relationships, then, are not morally equivalent to others. If marriage should now be based on a relationship's moral status and not its effects, and morality is relative to each person, then what relationship if any, can be denied marriage?

That is wrong with the entire same-sex marriage question: the contradictory moral foundation upon which it rests.
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LeftRight
TANSTAAFL
10:34 AM on 06/03/2012
In other words, you've got nothing, so you try to claim that HE'S got nothing...

I'm pretty sure that the whole "I'm rubber you're glue" defense ended in grade school....
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Leboazz
03:43 PM on 06/04/2012
I am not responsible for your inadequacies. If you cannot properly infer any meaning, then too bad.
12:41 PM on 06/03/2012
"That being the case, can anyone please tell us what relationships, then, are not morally equivalent to others. If marriage should now be based on a relationship's moral status and not its effects, and morality is relative to each person, then what relationship if any, can be denied marriage?"

You're trying to sound intelligent, but your only real point is that if gay couples can get married, then supposedly other relationships can be solemnized in a marriage as well. That argument was demolished in the Prop 8 decision, but you're bringing it up again because you have no reasonable basis for your position.

Here's the answer to your question. Letting gay couples marry will have no effect on any other relationship. There's no "contradictory moral foundation" because equality under the law is grounded in the constitution, not in the moral beliefs of any group.
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Leboazz
03:54 PM on 06/04/2012
I sound a lot more intelligent than you, that’s for sure. Doesn’t it bother you that you so woefully miss the point?

What do “moral beliefs” have to do with the moral status of a relationship? You missed that also. Listen, if you don’t understand something, just ask, instead of coming off like a fool.

Someone marrying his parakeet will have no effect on any other relationship, so let them marry also! That is the absurd implication of your argument. And then you invoke equality under the law, which returns to my original point: you mean to imply, evidently, a moral equality, which is the basis for a legal equality.

Now, go back and work it through again.

(Boy! The things I have to put up with!)
12:25 AM on 06/03/2012
We have to get to work and make sure gay marriage is banned in every state in the union. It is already banned in 30 states, so we have 20 more to go.
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cdncommentator
03:20 AM on 06/03/2012
You are fighting a losing battle. It's a generational issue, and your generation is on its way out. In 20 years, if there isn't same sex marriage in every state, then there will only be a few dinosaurs left.
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Zilo
Indie--The GOP opposes critical thinking
08:07 AM on 06/04/2012
The amazing thing is these people think we should have a choice in everything but who we marry. Aren't they such unbelievable hypocrites?
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LeftRight
TANSTAAFL
10:34 AM on 06/03/2012
Wrong again sparky! See the Constitution prohibits that.
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68Namvet
Sioux, French, German, Jew, American mutt
07:35 PM on 06/02/2012
The article is well thought out, beautifully presented, legally sound and presents a case for certain victory as a constitutionally protected right. Then again, our illustrious Supreme Court has recently ruled that corporations are people, have the right to "donate" (purchase) in unlimited amounts for their political needs, can keep those donations (including from foreign entities) secret, and will probably overturn the Affordable Patient Care Act (Obamacare), returning the country to denied insurance for those with pre-existing conditions, caps on insurance payouts, no continued insurance for students over 18, sky rocketing premiums with reduced coverages, increased healthcare costs and decreased Medicare coverages. Let's not forget, in a 5 to 4 decision, they ruled that votes did not need to be counted and appointed bush (the lesser) President. Oh well.
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Mickey Hayes
Just a Texas boy
08:51 AM on 06/02/2012
Let us ask ourselves the question. Why? What makes homosexuality repulsive to so many around the globe? Better yet, narrow down the conversation to Illinois but keep in mind that the people there are no different than any others.

Is it a matter of religion? Well, yeah... especially in nations where Christianity is the predominant faith. Note the term, faith as opposed to the religious practice and traditional observance of the industry of religion. What I am writing about is where religion is social, faith is personal. This addresses the hypocritical factors of imperfect human characters no matter what faith and how diligently practiced.

So what does this minority hope to offer the greater community by liberalization of their prerogatives? Will redefinition of the concept of marriage lessen the biases and suspicions surrounding homosexuality? As much as it is hoped, that likelihood isn't probable. And, again we must ask why? To get started on a debate, the protagonist must not assume that they are justified simply because they are human. This argument did not work for other minorities and the circumstances are clearly different for this class of citizens. Why is this so? Simple answer is because the vast majority of the proponents are the children and entitled inheritors of the antagonist they oppose. Now, let the arguments begin with truer perspectives.
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03:28 PM on 06/02/2012
WE have no expectation of making either heads or tails of this comment.
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68Namvet
Sioux, French, German, Jew, American mutt
04:41 PM on 06/02/2012
I was beginning to wonder if I was missing something - or failing to understand. Then, I too realized - you can't make sense out of nonsense.
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Margot707
"Liberal" is not a dirty word
04:51 PM on 06/02/2012
Double huh. I read it twice and had the same response both times: "Huh?"
07:43 PM on 06/02/2012
You ask, "So what does this minority hope to offer the greater community..?" Most straight couples don't marry for the purpose of, or even in consideration of, offering something to the greater community, so why should same-sex couples.

"...majority of the proponents are the children and entitled inheritors of the antagonist they oppose." By proponents I assume you mean gays, and since you refer to them as "the children and inheritors of the antagonist," I assume that by "antagonist" you mean the parents of gays. So I think what you are saying is "Ha! If your parents had been gay you wouldn't have been born." Cute, but irrelevant to the debate.
02:56 PM on 06/03/2012
Most straight couples do indeed marry to serve the purpose of offering something to the greater community.
07:54 AM on 06/02/2012
Mr. Stone is probably overreaching when he analogizes gay marriage with the Loving Case.

First, the law in the Loving case discriminated based on race. Classification based on race had long been a suspect classification (which subjects it to the high bar of strict scrutiny analysis) and laws based on race (e.g. the old Southern Black Codes) were the original basis for the Equal Protection Clause. In contrast, sexual orientation has never been considered a suspect classification (it is currently analyzed under rational basis like other criteria e.g. age) and there is no justification in the text or history of the Constitution to change that.

Second, although Loving declared marriage a fundamental right it didn’t need to do so. There was clear evidence that the law was passed to harm blacks by maintaining “white supremacy”. In other words, a racially discriminatory purpose is always sufficient to subject a law to strict scrutiny even if it’s facially neutral.

However, the Court did go farther and declare that heterosexual marriage was a fundamental right. The term “fundamental right” is a term of art in law. It means a practice that is deeply rooted in the Nation’s history and tradition (the Court’s words). But it would be nonsensical to conclude [heterosexual] marriage is a fundamental right- because its deeply rooted in our nation’s history/traditions- and then try to bootstrap gay marriage into the term marriage since up until recently gay marriage was nonexistent in our Nation’s history.
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Margot707
"Liberal" is not a dirty word
04:58 PM on 06/02/2012
#1: Homosexuality is a suspect class and the analogy is perfect.
#2: Anti-gay marriage laws and constitutional bans aren't meant to be harmful and discriminatory towards gays?
#3: The Court affirmed that "marriage" is a fundamental right. The word "heterosexual" did not appear in the majority opinion.
10:29 PM on 06/02/2012
You may think homosexuality is a suspect class but the Supreme Court has never classified it as such. The court in this case is bound by Supreme Court decisions.

This section of DOMA wasn't an "anti-gay" law. Any state that wanted to pass a gay marriage bill was still free to do so. Section 3 just defines marriage for federal law.

True. in the Loving case (the one defining marriage as a fundamental right) they never mentioned the term heterosexual marriage. However, the term fundamental right is a term of art in law. It means a right deeply rooted in our nation's history and traditions (the Court's words). It would be rediculous to conclude that gay marriage should be included in this definition since for most of our history it didn't exist i.e. gay marriage is not deeply rooted in our nation's history and traditions and thus doesn't qualify as a fundamental right.
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LeftRight
TANSTAAFL
10:37 AM on 06/03/2012
You're failing to understand the whole point of Loving. Yes, it was NOT about same-sex couples, but IN that case the justices said "Marriage is a basic civil right of man"! That means that under the 9th Amendment it's Constitutionally protected, and no states can make laws banning marriage.

What they CAN do is attempt to ban certain KINDS of marriage IF they can show an overriding need to do so. Since they cannot do so in the case of gay marriage (all arguments boil down to either being disgusted at the thought of homosexual sex or religious reasons....) the states CANNOT ban same-sex marriage!
05:02 PM on 06/03/2012
Of course the states can.

And, by God, they will do so.
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broadcastair
A man like any other man...only more so.
11:52 PM on 06/01/2012
Marriage, like military service, is not a "right." If marriage IS a right, will somebody get me Catherine Deneuve's phone number? I'd like to tell her about my "right" to marry her. Marriage is not a right because it requires the consent of a willing spouse AND the permission of the state. Add the fact that it's not mentioned in the Constitution, and it's clear that, despite the self-righteous wailing of the inconoclastic left, it's NOT a right. This issue has nothing to do with "gay rights" or the sad history of gays in this (and EVERY other) society and everything to do with re-defining marriage to fit the current political climate.
07:16 AM on 06/02/2012
The point is that the state can't extend one thing, a right, a courtesy, whatever you want to call it, to one group, hetero.s, and not another, gays.
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Leboazz
03:43 AM on 06/03/2012
The right is extended not to heterosexuals, but to men and women. The right is extended to a classification based on gender and not sexual orientation. That is your first mistake.

If such a classification should favor heterosexuals and not homosexuals, then that’s just too bad. Classifying does this all of the time. There is no obligation on the state that a law has to be convenient to every classification of persons. In fact, laws are mostly designed to inconvenience certain classifications of persons. Laws against robbery is very inconvenient to thieves; laws against smoking are inconvenient to smokers; laws against driving while drunk are inconvenient to drunks, etc.

So, the law doesn’t do what you say. It’s fair the way it is.
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Angel1999
Microbiologist & Historian
08:50 AM on 06/02/2012
So are you suggesting that if a thing isn't listed in the Constitution then it's not a right? Sorry, no more going to the rest room for you.

But seriously, the constitution is not a list of our rights, but a list of things the government may not do...a non-inclusive list at that. Marriage is a fundamental right, not because of some reference in the Constitution but because the SCOTUS said it was.

Of more importance however, is that the 14th amendment requires that the government treat everyone the same. If the government chooses to subsidize a legal contract, then it can't arbitrarily decide that one group of people don't get to participate. It's even more black and white in situations where one state allows gay people to get married and the federal government decides that those married people aren't eligible for the same benefits and recognition at the federal level as married straight people from that state.

There is no redefinition beyond the decision by the federal government to treat one group of married people differently from another group of married people.
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Leboazz
03:51 AM on 06/03/2012
It is said that a rose by any other name will smell as sweet. So, it’s not that significant what a state might call a thing; it is how that thing is defined.

So, the definition of marriage among states, these being different definitions, complicates things. Which definition should the federal government abide by? It has apparently established its own, which happens to be consistent with the overwhelming majority of states and not the few contrarian outliers.

Marriage is defined as the sexual and romantic union of a man and a woman.
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broadcastair
A man like any other man...only more so.
12:39 AM on 06/04/2012
The SCOTUS has been wrong before (Dred Scott; Sedition of 1917, etc.) and they'll be wrong again.
The entire purpose of marriage is, ultimately, to encourage a stability in society. Re-defining it will serve no purpose. Marriage is most certainly NOT a fundamental right because it requires the consent of the betrothed/spouse AND the consent of the state.
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ftkl1234
06:14 PM on 06/01/2012
Fairness prevails and same-gender marriages and families can rejoice and breathe a sigh of gladness to have the wise decision made. Yay, American Justice !!
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Alisa Neely
i SUPPORT GAY RIGHTS....EQUAL RIGHTS really....i f
04:07 PM on 06/01/2012
we should NOT be putting the RIGHTS of those in this country to the GENERAL VOTE....we see what happens when we do such a thing....look at NORTH CAROLINA.....we're talking about EQUAL CIVIL "HUMAN" RIGHTS.....everyone who is a LEGAL "AGED" CITIZEN of this country should have ALL THE SAME RIGHTS AS EVERYONE ELSE....and we should NOT be making laws according to the bible.

alisa
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SeanMartin
Everything in moderation.
03:37 PM on 06/01/2012
And yet more drama out of the US, which styles itself the "Leader of the Free World" but seemingly has to be dragged kicking and screaming into putting any teeth behind those words "equality" and "individual liberty". I find it sadly hysterical that your GOP rants on and on about "personal freedom" — but wants the right to tell everyone what to do.

Someday your country will put on its big boy pants and accept *everyone* as a true equal. Till then, you're great at talking the talk. but walking is apparently a bit of a challenge.
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05:53 AM on 06/02/2012
The Republican party is despicable and their freedom rhetoric entails nothing more than than the freedom of corporations and the most reactionary, patriarchal and authoritarian Christians to rule the rest of us as they please.
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04:42 PM on 06/02/2012
Should have added though, Sean Martin, that no people is more responsible for spreading anti-gay bigotry around the world by way of colonialism than the British.
03:12 PM on 06/01/2012
Government has no business being in the "marriage business". Even two heterosexuals who want to get married shouldn't have to get a license.
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Angel1999
Microbiologist & Historian
08:51 AM on 06/02/2012
A different issue, perhaps. But as long as the government IS in the business, it needs to treat everyone equally, not pick and choose which married people it will recognize and subsidize.
07:58 PM on 06/03/2012
So based on your argument, the government should look upon each of these "marriages" as equally acceptable:
- First cousins
- Brother & sister
- Brother & brother
- Brother & 2 sisters
- Multiple husbands marrying multiple wives

Before anyone hysterically screams "homophobe!" please calmly and rationally give me a counter-argument. Save the name-calling for another post.

Taken to whatever reasonable or ridiculous degree someone will take this - and you know someone will always push the envelope - where does it end? When does the government say no? When should society say no?
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dm512
02:13 PM on 06/02/2012
I can agree to that if it wasn't for the fact that the government got into marriage to start protecting children.
03:00 PM on 06/01/2012
During a time of national and international economic and fiscal calamity ... it is the focus on far less critical issues like same-sex marriage that has sealed the very probable historic electoral loss of Barack Obama and his vacuous "Mommy Party" this November. The Mommy Party has chosen to specialize in pursuing the special interests of a whole host of relatively small (if not tiny) groups of their potential supporters ... rather than concentrating on the immediate economic difficulties being confronted by the vast majority of working middle Americans.

At this point ... a L-O-T of working people (very likely a majority of voters), union members, lifelong moderate Democrats and Democratic-leaning Independents no longer have any effective representation in the American political system ... and the GOP is likely to run away with the presidency, both houses of Congress, and a majority of of governorships and mayoralties. The Democratic Party of The Great American Century will have faded into history.
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AdamWest1313
Hardcore Agnostic
04:32 PM on 06/01/2012
I love how you ignore that the Republicans are playing up this issue as well. It's incredibly hypocritical.
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Ally Solver
Problem Solver Extraordinaire
01:22 PM on 06/01/2012
You can "marry" whoever you want. Forget about any economic benefits from marriage(from all marriages).

Now that the two are separated, does anybody really care anymore?

Censorship is evil.
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akmomma
04:27 PM on 06/03/2012
Good point. How about we take away tax advantages and legal protections that opposite sex couples enjoy in order to create parity.

Sort of like the old parental threat: "Stop your fussing or I will really give you something to cry about"