58 F. Supp. 3d 499
D.S.C.2014Background
- Plaintiffs Katherine Bradacs and Tracie Goodwin, same-sex spouses married in D.C. in 2012, sued South Carolina officials under 42 U.S.C. § 1983 seeking recognition of their out-of-state marriage and injunctive/declaratory relief for alleged Fourteenth Amendment due process and equal protection violations.
- Plaintiffs allege concrete harms from nonrecognition (e.g., inability to be designated on employer health plan, VA survivor/benefit effects, tax filing differences, and stigmatic harms).
- Defendants are Governor Nikki Haley and Attorney General Alan Wilson in their official capacities; defendants moved for judgment on the pleadings asserting Eleventh Amendment immunity, lack of standing, and federalism/Tenth Amendment arguments.
- The court stayed proceedings pending Fourth Circuit guidance in Bostic; after Bostic and denial of certiorari, the stay was lifted and dispositive motions were briefed.
- At the Rule 12(c) stage the court considered standing, sufficiency of pleadings, and Ex parte Young immunity; it concluded Plaintiffs pleaded plausible due process and equal protection claims and have standing, but dismissed Governor Haley on Eleventh Amendment grounds while denying dismissal of Attorney General Wilson.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to sue state officers for recognition of out-of-state same-sex marriage | Plaintiffs allege concrete, traceable injuries from nonrecognition (benefits, VA, tax, stigma) redressable by injunction | Defendants contend Plaintiffs lack Article III standing | Held: Plaintiffs pleaded injury-in-fact, traceability (at least to AG Wilson), and redressability; standing satisfied |
| Sufficiency of pleading for Due Process claim | Plaintiffs assert liberty interest in marriage; nonrecognition deprives them of fundamental right | Defendants argue Plaintiffs failed to plausibly plead constitutional violation | Held: At pleading stage, allegations suffice to state a due process claim; claim may proceed |
| Sufficiency of pleading for Equal Protection claim | Plaintiffs allege disparate treatment versus opposite-sex couples and intentional discrimination | Defendants argue no viable equal protection claim pleaded; standard of review unsettled post-Windsor | Held: Amended complaint pleads a plausible equal protection claim under either rational-basis or heightened scrutiny |
| Eleventh Amendment / Ex parte Young applicability to named officials | Plaintiffs seek prospective injunctive relief against officials enforcing state law; AG has specific enforcement role | Defendants assert sovereign immunity; Governor has only general enforcement authority; AG similarly immune | Held: Ex parte Young bars suit against Governor Haley (dismissed); AG Wilson falls within Ex parte Young because his actions (filing for injunction to stop same-sex licenses) demonstrate specific enforcement nexus, so suit may proceed against him |
Key Cases Cited
- United States v. Windsor, 570 U.S. 744 (2013) (federal recognition of same-sex marriages and discussion of constitutional harms from unequal treatment)
- Bostic v. Schaefer, 760 F.3d 352 (4th Cir. 2014) (Virginia marriage bans violated Due Process and Equal Protection; relevant Fourth Circuit precedent)
- Ex parte Young, 209 U.S. 123 (1908) (authorized prospective injunctive suits against state officers enforcing unconstitutional statutes)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Article III standing requirements)
- Waste Mgmt. Holdings, Inc. v. Gilmore, 252 F.3d 316 (4th Cir. 2001) (Ex parte Young proximity requirement; general enforcement statements insufficient)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard: plausibility)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard and treatment of legal conclusions)