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Lyle Denniston

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Constitution Check: If DOMA Falls, Must States Opposing Gay Marriages Accept Them?

Posted: 06/01/2012 4:09 pm

The statement at issue:

"In allowing one state to hold the federal government, and potentially other states, hostage to redefine marriage, the First Circuit [Court] attempts a bridge too far. Under this rationale, if just one state decided to accept polygamy, the federal government and perhaps other states would be forced to accept it, too."

- Dale Schowengerdt, a lawyer on the "marriage litigation team" of the Alliance Defend Fund, in a comment to The New York Times on May 31, reacting to the First Circuit's decision striking down the federal Defense of Marriage Act's ban on any federal marriage benefits for same-sex couples who are legally married under state law.

We checked the Constitution, and...
For as long as the issue of same-sex marriage has been debated in legal and political circles, a seldom-interpreted provision of the Constitution has been a part of the debate, sometimes prominently, sometimes lurking in the background. It is in Article IV, the so-called Full Faith and Credit clause. And that presumably is what attorney Schowengerdt had in mind in voicing concern about the potential spread of gay marriage -- and, he added, plural marriage (polygamy).

He may have been premature, because the court fights so far have focused on whether there is any right, wide or narrow in scope, for gays and lesbians to get married. The First Circuit Court's ruling on Thursday did not establish any such right, but it did declare that, if a state has chosen to allow such marriages, Congress will have to come forward with stronger reasons than it has so far for denying those who marry under such a state law the federal employment, insurance and tax benefits that are available to opposite-sex couples.

The reasons Congress gave for enacting such a ban in 1996 in the federal Defense of Marriage Act, the Boston-based Circuit Court said, were not sufficient to justify a deep intrusion into the states' traditional control over marriage. As a result, it struck down DOMA's benefits ban, in Section 3.

But the decision emphasized that the court was not dealing with a separate part of DOMA. That is Section 2, in which Congress -- invoking its powers under the Full Faith and Credit clause -- declared that no state or territory could be required to honor a same-sex marriage performed in another state. Section 2's validity was not challenged in that case, the court noted.

That, of course, is the next-phase dispute, and it definitely will arise if this decision, or any other decision providing legal protection for gay marriage, is ultimately upheld by the Supreme Court. (Most courts that issue such rulings are likely to put them on hold until the Supreme Court can act, as the First Circuit did Thursday.)

The dispute probably will get started when a legally married same-sex couple moves to another state, one that forbids such marriages, and wants to remain eligible for federal benefits won in the First Circuit decision. Most of those benefits, though, are provided directly by the federal government, so the state of residence of gay spouses would not affect those provisions.

There are, however, some other federal benefits that are keyed to state-provided benefits, and those, too, are forbidden by DOMA. With the Circuit Court's new ruling, those, too, presumably would have to be provided to a legally married same-sex couple. Would those travel with them to a no-gay-marriage state? That will be the constitutional issue under the Full Faith and Credit clause, and it probably would require the courts to decide whether Section 2 of DOMA is, itself, unconstitutional as too deep an intrusion into states' prerogatives or as discrimination based on hostility to homosexuals.

As for attorney Schowengerdt's concern about polygamy spreading if one state should uphold such plural marriages, that touches on a form of union to which -- so far -- no state and no court decision has given its blessing. It is true that, in a federal court in Utah, there is a lawsuit pending by the Kody Brown family -- the polygamist family that stars in the reality TV program, 'Sister Wives' -- and that lawsuit is moving ahead despite state officials' attempts to get it dismissed.

Once again, though, that is a first-round test of a right to enter a particular kind of marriage, and the potential future spread of that legal concept to other states would, also, depend upon the outcome of the Full Faith and Credit issue.

The Supreme Court has not dealt with polygamy in 134 years, and that 1878 decision (Reynolds v. U.S.), upheld government power to punish plural marriages as a crime. The constitutional issues might be different now, and that, it appears, is what worries attorney Schowengerdt.

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Lyle Denniston is the National Constitution Center's Adviser on Constitutional Literacy. He has reported on the Supreme Court for 54 years, currently covering it for SCOTUSblog, an online clearinghouse of information about the Supreme Court's work.

 

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The statement at issue: "In allowing one state to hold the federal government, and potentially other states, hostage to redefine marriage, the First Circuit [Court] attempts a bridge too far. Under...
The statement at issue: "In allowing one state to hold the federal government, and potentially other states, hostage to redefine marriage, the First Circuit [Court] attempts a bridge too far. Under...
 
 
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HUFFPOST SUPER USER
SeanMartin
Everything in moderation.
03:29 PM on 06/04/2012
More marriage drama from the "Leader of the Free World". C'mon, America, put your Big Boy pants on and join the rest of us who've moved on from this issue.

Fondly,

Canada
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HUFFPOST SUPER USER
JohnSawyer
arglebargy
05:37 AM on 06/04/2012
While the argument presented by Schowengerdt is a reference to the theoretical problems (at least as he sees it) of the Full Faith And Credit clause, in his attempt to "protect" anti-gay marriage states, the issue isn't really whether one state can impose its will on all other states--it's an issue of whether the federal government, or any individual state, can impose something that's unconstitutional on any state. As CRandallB says in his comments below, the 14th Amendment is totally clear on this point--states (and the federal government) can't enact laws that deprive people of their rights (at least not forever). Currently we're in the odd (but not at all without precedent) situation where we do have unconstitutional laws, both federal and in most states, which deprive gay people the right to marry. Since these laws are unconstitutional, no state needs to honor those laws, but states that unconstitutionally deprive people of this right, are nevertheless required to honor all the other rights of already-married gay couples.
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HUFFPOST SUPER USER
JohnSawyer
arglebargy
05:46 AM on 06/04/2012
This doesn't mean that the fish and game laws, for example, of one state are supposed to be enacted by all other states--it means that even though there may be different fish and game laws in each state, including laws that make illegal some things that are legal in other states (which is not automatically an unconstitutional situation), that someone from a state in which something is legal, can't be fined, arrested, or otherwise penalized for those actions when they travel to another state where doing that thing is illegal, as long as they don't do that thing in that state. This means that people who get married in a state where it's legal, aren't to be discriminated against and denied rights (financial, etc.) if they travel to a state where gay marriage itself isn't legal. The idea is that no matter which state one is in, one's gender is irrelevant when it comes to deciding whether that person is eligible for rights, entitlements, etc.--the act of getting married to someone of the same sex is the only thing they can be prohibited (for now) from exercising in particular states, but since, in this example, they're already married to someone of the same sex, they're unlikely to face that problem unless they get divorced and wish to marry someone else of the same gender.
01:16 AM on 06/04/2012
oh yes, one more thing. As a constitutionalist, WHY are you attempting to distract everyone with this irrelevent Article IV argument? Federal constitution has prominence over state constitutions. If the federal constitution were being enforced, specifically the 14th Amendment, then Article IV would be satisfied as a mere side-effect.
You are helping to maintain the smoke-and-mirrors distraction designed to keep gay Americans from their right to equal protection under the law.
01:13 AM on 06/04/2012
As a constitutional advisor, why did you go for Article IV? Article IV is NOT the problem. The problem is those who swore to uphold the Constitution have virtually committed treason by refusing to acknowledge the 14th Amendment which clearly defines a citizen without mention of gender or any other modifier based on personal physicality of any kind, and then states unequivocably that every citizen is guaranteed equal protection under the law.
Every citizen. Therefore, if a law grants one citizen the right to do something, then ALL citizens have the right to do the same thing. This isn't arguable. It's right there. Spelled out very simply. And yet, we have a President, V-President, Senators, Congresspersons, all who took an oath to uphold and enforce the Constitution completely ignoring THE part of the constitution which answers the question. If ANY citizen of the United States can marry another citizen of the United States, than EVERY citizen of the United States can marry another citizen of the United States, as defined by the 14th Amendment.
As a constitutionalist, how do you rationalize this behavior?
07:12 PM on 06/03/2012
It's the same as interracial marriage. Does one state have to recognize an interracial marriage performed in another state? The Supreme Court says yes, so the same applies for any two consenting adults.
04:28 PM on 06/03/2012
I've always wondered about the full faith and credit clause and medical marijuana.
compro01
Conservatism : Policy-based evidence making
09:28 PM on 06/03/2012
What about it? State laws WRT that don't mean anything, since Gonzales v. Raich ruled that federal law prohibiting any use of marijuana overrides state laws allowing it.
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HUFFPOST SUPER USER
racmd
Just riding the wave of life
03:17 PM on 06/03/2012
The final say will come from the SCOTUS...and the deicision will be the "law of the land".
I appreciated your discussion of the hows and the whys but just like "inter-racial" marriage...the final action on "marriage equality" will come from the SCOTUS.
With the continual testing of DOMA by the GOP, TP and the right, the SCOTUS will probably have its first encounter with this very soon.
If this fails..who will take down the Constitution and Declaration of Independence? Who will remove the sign from the bottom of the Statue of Liberty?
The religious right and their backers either PAY TO PLAY by paying taxes at their religious sites, etc...or they keep their noses out of MY CIVIL RIGHTS. For as Moss III said.. this is about civil rights..not religious rites.
We are 20,000,000+ strong in the U.S. and we are NOT going away and we will NOT be silenced by ignorance.
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HUFFPOST SUPER USER
rextrek
50yr old, Moderate-liberal in S.NJ/Phila
10:04 AM on 06/03/2012
Wow- Canadians must read this news and THINK what the hell is wrong with America...isn't THAT country SUPPOSED to be the one with Liberty & justice for ALL??? Really???
HUFFPOST SUPER USER
Original Intent
Because "Shall" is a directive, not a suggestion.
01:19 PM on 06/03/2012
Liberty and Justice for all.... hahahahaha.... Don't you know the whole Pledge is about "Under God"?
HUFFPOST SUPER USER
LadyMorganDA
01:45 PM on 06/03/2012
Actually, the "Under God" par of the pledge was not part of the original pledge.
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HUFFPOST SUPER USER
AdamWest1313
Hardcore Agnostic
04:43 PM on 06/03/2012
Under god was not a part of the original pledge, it was added in 1948.

You are clueless.
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HUFFPOST SUPER USER
SeanMartin
Everything in moderation.
03:25 PM on 06/04/2012
What of course makes it even funnier is when the GOP stands there and says "We're all about PERSONAL FREEDOM! We want INDIVIDUAL LIBERTY!"... and then quietly whispers, "Certain restrictions may apply."
HUFFPOST SUPER USER
ThomasRyanAlex
03:25 PM on 06/02/2012
Perry v Brown will win marriage equality nationwide per the 14th Amendment of Equal protections clause within a year.
HoosierInMaryland
HuffPo says my 'micro-bio is empty'
07:45 PM on 06/02/2012
Actually, Perry v Brown is ONLY about whether a right under the state's Constitution can then be withdrawn by the public. It is NOT about equal protection for anyone outside the state of immediate consideration (in the Perry v Brown case, California).
08:42 PM on 06/02/2012
No, Perry v Brown is about whether gay couples in California have a right to equal protection under the Federal Constitution, specifically including the right to be married, and whether prop-8 violates that right. The appeals court chose to make their decision on the narrowest possible grounds, but that does not change the subject of the original suit. The supreme court may very well make a de-novo decision, on grounds completely different from the narrow grounds that the appeals court chose.
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03:03 PM on 06/02/2012
Since when is marriage a "public act"? I think that's the key issue right there. A "public act" is one which affects the general public; such as raising taxes, repairing roads and determining state funded school curriculum.

But we've gotten so used to the government determining every aspect of our lives, we don't even question it any more. Who we may marry, what sort of contraception we can use, what size drink can we buy, the list goes on. Bah.

The Constitution also states in Article 6 that the Constitution and laws made in "pursuance thereof" is the supreme Law of the Land (Supremacy clause) and no individual stae constitution or law shall supercede it. Nowhere does the Constitution gives authority to the government to determine who may marry whom. In fact, one could argue that one's religious practice, protected under the First Amendment, allows alternate forms of marriage.

So if your neighbor wanted to have 4 wives or 9 husbands or marry a person of the same gender, just how will that affect You? Will it change your property taxes? Will it stop you from coaching Little League? Will it suddenly force you to marry against your wishes? Nope.

If the government wants to debate on individual rights according to the Constitution, then they jolly well better start following it.
11:04 AM on 06/03/2012
The issuing of a license by the State, is an act of the State. The State acts to issue the license. The issuance is a public act, and the license itself is a public record.
02:49 PM on 06/02/2012
The lawyer quoted is waxing hyperbolic. IMHO, this ruling could end up being a boon to supporters of traditional marriage, especially if it gets to the Supreme Court first - if the Court rules that states have the right to refuse to accept other states' marriages that fail to meet its own standards, then obviously the 14th Amendment doesn't apply to those marriage standards. It can then simply require lower courts to retry other cases based on that ruling.
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HUFFPOST PUNDIT
BlackJAC
It's better to be a black king than a white knight
06:46 PM on 06/02/2012
And, conversely, car theft becomes legal provided the car's license plate is an out-of-state one because you've just established that a legal contract made in one state doesn't have to be recognized in another.
08:06 PM on 06/02/2012
Wrong comparison, legally wedded spouses don't own each other. A better comparison are business licenses, and licenses to practice law or medicine. A license to practice in one state does not confer the right to practice in all states. Likewise, states are free to determine under what conditions it will accept other states' licenses as proof of competence. For instance, the requirements to obtain a license to sell life insurance are more stringent in Nevada than in Utah. In Utah, if you have a Nevada license all you need to do is pay a fee to gain a Utah license. In Nevada, if you have a Utah license you still have to pass a test along with paying a fee to gain a Utah license. In none of these cases does the Full Faith and Credit clause apply.
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10:14 PM on 06/02/2012
It's article IV not the 14th amendment that's in question.
12:51 AM on 06/03/2012
Not in this case, seeing how the Court just ruled that Washington's regulations interfered with each state's 10th Amendment right to determine its own laws for marriage.
10:25 AM on 06/02/2012
Gay marriage is old hat. Here's the latest:

Is self-marriage for you?
By Craig Johnson
June 01, 2012

Only for the lonely? Many singles have walked the aisle
It's a reminder 'not to betray myself,' says one bride-groom

"With this ring I me wed."

Jennifer Hoes just celebrated her ninth wedding anniversary -- to herself.

On her 30th birthday in 2003, the Dutch woman had a self-wedding, complete with cameras. While it would be premature to call it a trend, several people since then have taken the vows of self-marriage as a way of contractually binding themselves to matrimonial values.

Anderson Cooper’s talk show recently featured a woman who had wed herself, and even took herself out on dates. “I started discovering that the love I need, it’s in here,” Nadine Schweigert said, pointing to her heart.
09:25 AM on 06/02/2012
It might be helpful to read the actual text of the Constitution, here. Article IV, Section 1, says: "Full faith and credit shall be given in each state to the public acts, records, and judicial proceedings of every other state. And the Congress may by general laws prescribe the manner in which such acts, records, and proceedings shall be proved, and the effect thereof."

The part about "Congress may...proscribe... the effect thereof" could be interpreted as allowing Congress to proscribe how States shall give effect to marriage licenses issued by other states.

The actual text of DOMA section 2, does not quite do that. Instead of proscribing the effect of a "marriage license", or "marriage", it attempts to distinguish between a marriage "between persons of the same sex", and other marriages. That is, exactly, the same distinction that has been struck down, twice now, by federal appeals courts.

So, of course, there would be further litigation. It seems, there is always further litigation.
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HUFFPOST SUPER USER
ESerafina42
Abandoned by wolves, raised by Republicans.
09:07 AM on 06/02/2012
Well, if I marry my first cousin in Kentucky and move to New York, does New York care? Somehow I don't think so.
11:59 AM on 06/02/2012
>Well, if I marry my first cousin in Kentucky and move to New York, does New York care?

A better question would be "if I marry my first cousin in Kentucky, would she still be my sister?"
HUFFPOST SUPER USER
Conuly
11:09 PM on 06/03/2012
You've got that backwards. NYS allows cousin marriages. Kentucky does not allow first cousins to marry.
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HUFFPOST SUPER USER
ESerafina42
Abandoned by wolves, raised by Republicans.
12:13 AM on 06/04/2012
My mistake, but the point still stands. Will the state in which it's not legal invalidate my marriage?
IMOPINIONH8D
because I want it empty...
09:04 AM on 06/02/2012
Isnt there a saying about the rights of a few cant be restricted by the many?