Caspar v. Snyder
77 F. Supp. 3d 616
E.D. Mich.2015Background
- Eight same-sex couples married in Michigan on March 22, 2014, during a brief window after a district court declared Michigan’s same-sex marriage ban unconstitutional and before the Sixth Circuit issued a stay.
- Governor Snyder and three state agency heads announced a policy refusing to recognize those marriages while the Sixth Circuit’s stay was in effect, though acknowledging the marriages had been lawfully solemnized at the time.
- Plaintiffs sued state officials in their official capacities under the Fourteenth Amendment, seeking declaratory and injunctive relief requiring recognition of their Michigan marriages and associated benefits.
- The Sixth Circuit meanwhile reversed the district court in DeBoer v. Snyder, but did not address whether a state may strip marital status previously conferred by that state when the marriages were validly solemnized.
- The district court considered plaintiffs’ preliminary injunction motion and defendants’ motion to dismiss, stay, and to consolidate with a case challenging recognition of out-of-state same-sex marriages.
- The court granted a preliminary injunction ordering recognition of all same-sex marriages solemnized in Michigan between the district court ruling and the Sixth Circuit stay, stayed that injunction for 21 days to permit appellate review, and denied defendants’ other motions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the right to maintain a lawfully acquired marital status is a fundamental liberty interest under the Due Process Clause | Plaintiffs: the continued validity of marital status once lawfully conferred is a fundamental liberty interest protected by substantive due process | Defendants: plaintiffs’ marital status is conditional on the district court ruling; if that ruling is reversed, marriages are void ab initio | Held: The right to maintain marital status once validly solemnized is fundamental; defendants offered no compelling interest to withdraw recognition; plaintiffs likely to succeed on due process claim |
| Whether marriages solemnized pursuant to an unstayed court order become void if that order is reversed on appeal (ab-initio theory) | Plaintiffs: third parties who relied in good faith on an operative judgment acquire protectable rights; reversal does not automatically erase non‑parties’ rights | Defendants: marriages were valid only while the district court’s order stood and became void if DeBoer was reversed | Held: Reversal of the underlying decision does not automatically nullify rights acquired by non‑parties who relied on the operative judgment; ab‑initio theory rejected |
| Whether Eleventh Amendment bars this suit seeking prospective relief against state officials (Ex parte Young) | Plaintiffs: Ex parte Young permits prospective equitable relief against state officers; defendants sued have connection to enforcement of non‑recognition policy | Defendants: Eleventh Amendment and lack of causal connection/ability to grant prospective relief defeat jurisdiction | Held: Ex parte Young applies; defendants have sufficient connection to enforcement; Eleventh Amendment does not bar claim |
| Whether proceedings should be stayed or consolidated pending DeBoer appeal / Supreme Court review | Plaintiffs: their claim as to maintenance of marital status differs from DeBoer and is ripe; relief is needed to prevent ongoing harm | Defendants: stay and consolidation promote judicial economy and avoid conflicting rulings; DeBoer outcome controls | Held: Stay pending DeBoer/Supreme Court denied (but injunction stayed 21 days for appeal); consolidation denied because issues in Blankenship differ (out‑of‑state recognition) |
Key Cases Cited
- DeBoer v. Snyder, 772 F.3d 388 (6th Cir. 2014) (Sixth Circuit decision upholding state same‑sex marriage bans; did not address retention of marital status after valid solemnization)
- United States v. Windsor, 133 S. Ct. 2675 (U.S. 2013) (recognized federal consequences of state‑conferred marital status; discussed status as legal acknowledgment of intimate relationship)
- Baker v. Nelson, 409 U.S. 810 (U.S. 1972) (one‑line dismissal referenced by Sixth Circuit on substantial federal question issue)
- Winter v. Natural Res. Def. Council, 555 U.S. 7 (U.S. 2008) (standard for preliminary injunctions)
- Washington v. Glucksberg, 521 U.S. 702 (U.S. 1997) (framework for identifying fundamental liberty interests under substantive due process)
- Ex parte Young, 209 U.S. 123 (U.S. 1908) (doctrine permitting prospective equitable relief against state officers despite Eleventh Amendment)
- Loving v. Virginia, 388 U.S. 1 (U.S. 1967) (Supreme Court recognition of freedom to marry as fundamental liberty)
- Lehr v. Robertson, 463 U.S. 248 (U.S. 1983) (importance of ongoing familial relationships and intimate associations under due process)
- Landgraf v. USI Film Products, 511 U.S. 244 (U.S. 1994) (presumption against retroactive application of laws)