You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Bishop v. United States ex rel. Holder

Citations: 962 F. Supp. 2d 1252; 2014 WL 116013; 2014 U.S. Dist. LEXIS 4374Docket: No. 04-CV-848-TCK-TLW

Court: District Court, N.D. Oklahoma; January 13, 2014; Federal District Court

Narrative Opinion Summary

The case involves two same-sex couples challenging the constitutionality of federal and state laws restricting marriage to opposite-sex couples. The Barton couple and the Bishop couple filed a lawsuit against Sections 2 and 3 of the Defense of Marriage Act (DOMA) and the Oklahoma Constitutional Amendment. The District Court, presided over by Judge Terence C. Kern, determined that the Bishop couple had standing to challenge Part A of the Oklahoma amendment, which was found to violate the Equal Protection Clause of the Fourteenth Amendment. The Barton couple's challenge to Section 3 of DOMA was deemed moot following the Supreme Court's decision in United States v. Windsor. Additionally, the Court ruled that Section 2 of DOMA and Part B of the Oklahoma amendment did not cause the Barton couple's injuries, thus dismissing their claims for lack of standing. The Court granted summary judgment in favor of the Bishop couple, permanently enjoining the enforcement of Part A against same-sex couples seeking marriage licenses, although this decision was stayed pending appeal. The ruling emphasized that moral disapproval of same-sex relationships does not constitute a legitimate governmental interest. The case reflects the evolving legal landscape regarding same-sex marriage rights and the application of equal protection principles.

Legal Issues Addressed

Equal Protection Clause of the Fourteenth Amendment

Application: The Court ruled that Oklahoma's constitutional amendment limiting marriage to opposite-sex couples violates the Equal Protection Clause.

Reasoning: The Court, led by District Judge Terence C. Kern, rules that Oklahoma's constitutional amendment limiting marriage to opposite-sex couples violates the Equal Protection Clause of the Fourteenth Amendment.

Mootness Doctrine

Application: The Barton couple's challenge to Section 3 of DOMA was deemed moot following the Supreme Court's decision in Windsor.

Reasoning: The Barton couple's challenge to Section 3 of the Defense of Marriage Act (DOMA) is deemed moot following the Supreme Court's decision in Windsor, which effectively resolves the issue and removes the court's jurisdiction over this challenge.

Permissive Nature of DOMA Section 2

Application: Section 2 of DOMA does not mandate states to refuse recognition of same-sex marriages but allows them discretion, thus not directly causing the Barton couple's alleged injuries.

Reasoning: It determines that Section 2 is permissive, allowing states to choose whether to recognize marriages from other states, and does not remove state discretion.

Rational Basis Review in Equal Protection

Application: Part A of the Oklahoma Constitutional Amendment was reviewed under rational basis scrutiny and found to lack a legitimate justification for denying marriage licenses to same-sex couples.

Reasoning: The Court confirms that Part A of the Oklahoma Constitutional Amendment has been deemed an arbitrary and irrational exclusion of same-sex couples from obtaining marriage licenses, violating the Equal Protection Clause of the Fourteenth Amendment.

Standing to Sue

Application: The Barton couple lacked standing to challenge certain sections of DOMA and the Oklahoma amendment due to insufficient causation of injury by these provisions.

Reasoning: The Court rules that the Barton couple lacks standing to challenge Section 2 of DOMA and Part B of the Oklahoma Amendment, finds their challenge to Section 3 moot, but confirms the Bishop couple has standing to challenge Part A.