Wednesday, September 10, 2014

Banning SSM Is Not The Same As Not Getting Around To Authorizing SSM

by Michael Dorf

In my latest Verdict column, I discuss last week's same-sex marriage (SSM) rulings: Judge Feldman's district court opinion upholding Louisiana's SSM ban; and Judge Posner's 7th Circuit opinion invalidating the Indiana and Wisconsin SSM bans. My column praises Posner's opinion overall but especially for his injection of a new argument into the growing genre of opinions striking down state SSM bans. As he foreshadowed during the oral argument, Posner performs a kind of judicial jujitsu. He turns the state claim that it is concerned about the consequences of accidental heterosexual procreation against the state: If the state were really concerned about those consequences, he says, it would permit same-sex couples to marry, because they are raising thousands of adopted children who were born as a result of such accidental heterosexual procreation.

That's a very nice move, but as I note in the column, it is potentially vulnerable to a rejoinder by the state: Rational basis scrutiny permits the state to tackle a problem one step at a time; here the state is tackling the problem for the heterosexual couples who keep their offspring; it need not also tackle other aspects of the problem. I say in the column that this is not a persuasive rejoinder but I do not elaborate at length why. Consider this blog post an extended footnote to the column.

The state rejoinder can only get off the ground if laws that facially disadvantage people based on sexual orientation are subject to mere rational basis scrutiny, rather than to heightened scrutiny. For the last 18+ years (since Romer v. Evans) the Supreme Court has found it unnecessary to decide what level of scrutiny applies to such laws, invalidating laws disadvantaging gays and lesbians even under rational basis scrutiny. There is a robust academic literature that argues about whether those decisions apply conventional rational basis scrutiny or a kind of covert heightened scrutiny. When I teach the relevant line of cases, I call this, tongue in cheek, "extra crispy rational basis scrutiny." (Occasionally students, to my horror, write that phrase on an exam as though it were an actual legal term of art.)

Meanwhile, precedents in some states and circuits say that sexual orientation is not a suspect or semi-suspect classification, so that judges in these states and circuits take the position that conventional rational basis scrutiny is the correct standard. I think those precedents are wrong for two reasons. First, sexual orientation is, or should be understood as, a form of sex discrimination, both literally and substantively. It is literally a form of sex discrimination because, in the case of SSM, whether a marriage license will issue depends on the sex of the applicants. It is substantively a form of sex discrimination because prejudice against sexual minorities relies on impermissible stereotypes about sex roles--the very evil that is at the core of what makes sex discrimination constitutionally objectionable.

Second, even if one thinks that sexual orientation should not be considered sex discrimination, standing alone it bears the hallmarks of a suspect (or semi-suspect) classification. Judge Posner summed up the reasons matter-of-factly and pithily when he wrote that "homosexuals are among the most stigmatized, misunderstood, and discriminated-against minorities in the history of the world ...." Only an unprincipled commitment to the notion that the Supreme Court is done recognizing suspect classifications--a kind of arbitrary numerus clausus--can support the view that sexual orientation is not a suspect classification.

But let us suppose for the sake of argument that the SSM bans were subject only to rational basis scrutiny. Even so, the one-step-at-a-time defense would fail as a response to Judge Posner's argument about adoption. To see why, one needs to examine exactly what the state is saying in its accidental procreation argument. The state is not saying that preventing same-sex couples from marrying in some way prevents accidental procreation by unmarried heterosexuals. And for apparently good reason, because that would be both illogical and, as Judge Posner shows, counter-factual. There is absolutely no evidence that permitting same-sex couples to marry in any way discourages opposite-sex couples from marrying.

Now maybe . . . just maybe . . . the state could argue that permitting same-sex couples to marry does discourage opposite-sex couples from marrying. Sure, there's no evidence for this supposed phenomenon, but traditional rational basis scrutiny does not require evidence. As expressed in the most forgiving formulation, if a court can conceive of a state of facts in which the state's law would further the state's goals, then the law satisfies rational basis scrutiny. Can we conceive of such a world? Sure, but the problem is that the only rational way of conceiving such a world is itself constitutionally problematic.

What would be the mechanism by which permitting same-sex couples to marry discourages opposite-sex couples from marrying? In a word, homophobia. Some number of opposite-sex couples who would otherwise marry would see that marriage ain't what it used to be now that those disgusting people can git married, so they would decide instead just to shack up. Then, when their fornicatin' led to babies, they would be less likely to stay together than if they had married. Presto! Permitting same-sex marriage would have undermined traditional marriage and thus contributed to the problem of accidental procreation by unmarried heterosexuals.

Let me emphasize that, to their credit, Indiana and Wisconsin did not make this argument. And to the credit of heterosexuals in Indiana and Wisconsin (and so far as I am aware, the rest of the country), homophobia is not so extreme that it actually leads to the foregoing hypothetical scenario. But again, traditional rational basis scrutiny does not require actual facts, only those that can be "conceived" (pun foreseen but not intended). Suppose that some other state were to advance the hypothetical scenario as an ostensible rational basis for a SSM ban. Surely a judge could conceive the hypothetical facts that I just conceived, right?

Yes, but whatever else the extra-crispy cases mean, at a minimum, they stand for the proposition that animus cannot be the basis for legislation, and in the imagined scenario the heterosexuals who are discouraged from marrying are discouraged because of animus: they are so disgusted by the prospect of SSM that they forgo marriage themselves. To be sure, the state would say that it doesn't share the animus; it is merely taking account of it for the benefit of the children. But that option is foreclosed by Palmore v. Sidoti, which held that, even in determining the best interest of actual children in a custody case, a judge could not in effect incorporate private bias. As the Court said there: "Private biases may be outside the reach of the law, but the law cannot, directly or indirectly, give them effect." Palmore involved race discrimination, but nothing about its logic would make it inapplicable to other constitutionally forbidden motives, such as the general prohibition on animus.

Accordingly, Indiana and Wisconsin were right to place no reliance on the imagined scenario in which straight people don't marry because they are demoralized by gay people marrying. It doesn't happen; it is an offensive claim; and even if the state were to advance the argument, it would fail under the logic of the animus cases and Palmore.

So what is the argument that the states advance regarding accidental reproduction? Their argument is not that that they need to ban SSM to mitigate the harm of accidental reproduction by unmarried heterosexuals. Their claim is simply that they do not need to extend marriage to same-sex couples because same-sex couples do not accidentally procreate.

At this point I want to make one very, very, very simple observation: The laws being challenged in the SSM litigation do not simply fail to extend marriage to same-sex couples. They ban SSM. So even if mere rational basis scrutiny should apply to such laws (and it shouldn't), the argument that there is a rational basis for failing to extend the institution of marriage does not explain why it is rational to ban SSM, rather than merely to fail to extend it.

Here we can use a variant on a hypothetical example offered by Judge Posner to illustrate the point. A state issues driver's licenses, initially simply for the purpose of ensuring that people operating motor vehicles can do so safely. If that is all that a driver's license does, then the state has a rational basis for failing to issue "non-driver's licenses" to people who don't drive. But over time, the driver's license begins to play multiple other functions. Private firms like banks, airlines, and bars demand to see a driver's license as identification; the government itself does the same in various contexts; perhaps even hospitals demand to see a driver's license as a condition of visiting a sick relative. Eventually, the driver's license comes to be a kind of universal ID card. Now imagine that non-drivers (including people who are physically unable to drive for various reasons such as blindness) organize to seek non-driver's licenses. If at that point the state passes a law or a state constitutional amendment forbidding the issuance of non-driver's licenses, the state can no longer rely on the original reason for issuing licenses only to drivers. The original distinction--between people who might endanger the public by operating motor vehicles and those who don't--has no bearing on all of the collateral benefits conferred by having a govt ID which are sought by the non-drivers. So even though the state may have originally had a rational basis for failing to issue non-driver's licenses, it lacks such a rational basis for banning them once the collateral benefits are clear.

Likewise with respect to SSM. (Indeed, even more so, because in the foregoing scenario, the non-drivers have another, albeit more expensive, option: they can obtain federal passports. But there's no way to get the state benefits of marriage by getting "federally married.") Perhaps it's true that at some point in the past state recognition of marriage for opposite-sex couples was rooted in concerns about accidental procreation. Even so, everybody knows that the SSM bans were not enacted because of a judgment that same-sex couples don't need protection against accidental procreation. My research in a news database reveals not a single reference to the phrase "accidental procreation" in connection with same-sex marriage before 2006, with nearly all of the references coming in the last couple of years.

The best that can be said for the accidental procreation argument is that it is not as ugly as some of the anti-gay arguments that have been raised in the past to defend anti-gay laws. (See, e.g., here.) Nonetheless, the sheer ridiculousness of the accidental procreation argument reveals it to be an obvious pretext, so that any judge or Justice who accepts it will likely be ridiculed, if not reviled as a bigot, in the not-too-distant future.

23 comments:

Joe said...

Turner v. Safley has a long paragraph listing the various purposes of marriage, even when prison makes procreation unlikely.

Some are now trying to single out one thread of marriage and use it to deny marriage to same sex couples that can show most of the garment. They even can show some of that very thread -- they have children etc.

The accidental procreation argument is as suggested an after the fact argument. It only should convince those who want to be. The 9CA* was more polite than Posner was during oral argument the other day but was about as unlikely to be convinced.

Finally, the very "argument" applies to some same sex couples. What about bisexuals, after all? The chance of accidents are that much more likely if the couple is not recognized by the state, thus giving their union a greater sense of permanence & reason to be monogamous.

Anyway, I think rational basis scrutiny is enough here but there really isn't a need for heavy lifting. It should be some form of heightened scrutiny and the fact marriage is involved only adds to that.

That does require us to get into definitions of marriage, but that's fine -- it is sort of a joker not to examine the full nature of the union in question, including how it fits all the tests for "marriage" in place now except for some bare gender discrimination.

Lawrence should be taken to its logical conclusion -- intimate association, including marriage, should be protected for same sex couples.

* One judge there in particular was open to the sex discrimination argument. Idaho spoke of "genderless marriages" too. Are lesbians and gays "neuters"?

Joe said...

ETA: The non-drivers license example was good but the thing is that the various aspects of marriage involved here that falls upon the non-procreative didn't just grow over time. It was there all along.

Same sex couples themselves lived in marriage type relationships for years. Some of them are now officially marrying after being together for decades. Windsor herself had such a relationship since the '60s.

On that level, it is false when people say SSM just began. Somewhat comparably, slaves often could not get legally married, but still consider themselves as such and so lived.

JHW said...

The accidental procreation theory comes in several flavors. There is argument discussed here, popular among state officials defending bans, that strives to say as little as possible: cite Johnson v. Robison and rely simply on the procreative capacity difference without claiming any specific harm. This is unlikely to get much purchase because it is so plainly evasive.

The more substantive argument is that something about marriage's norms and structure is bound up with the potential for accidental procreation. Thus, for example, you might think that sexual fidelity or the expectation of permanence are tied to the need to avoid out-of-wedlock childbirth (in the first case) and to ensure a stable household for potentially-unexpected children (in the second case). This is a pretty weird reading of marital norms (that is not its only problem) but it lets the "harm" argument get off the ground without relying on the animus of straight people.

Hashim said...

If (as you're willing to assume arguendo for purposes of this post) a State acts rationally in not extending marrriage to gays, then I think you're overlooking a pretty obvious rational basis for passing state constitutional amendments banning same-sex marriage: namely, preventing state court judges from ignoring that rational basis and extending marriage to gays based on nothing more than their own ideological preferences disguised as constitutional holdings. It's no surprise that the wave of constitutional amendments came in the wake of state-court decisions inventing a state constitutional right to ssm.

Simply put, it's obviously rational for a State's citizens to stop a State's judges from inventing rights that the public doesn't believe exist.

Now, that rationale is overbroad insofar as the constitutional amendments also constrain the legislature. But overbreadth doesn't matter under rational-basis review. Moreover, a similar rationale justifies application to the legislature: preventing elected officials from subordinating the State's rational basis to the policy preferences of an ideological minority.

In sum, if a State's citizens have a rational basis in extending marriage only to straight couples, then they necessarily have a rational basis in preventing a State's public officials from going further than that, since those officials are their agents and should be exercising their will.

Joe said...

"preventing state court judges from ignoring that rational basis and extending marriage to gays based on nothing more than their own ideological preferences disguised as constitutional holdings"

Or, states disagreeing with the fiction or noting animus or determining that heightened scrutiny is necessary.

Why must it merely be "ideological preferences"? Part of having an independent judiciary is that sometimes they based on rational based law override legislatures.

The state legislatures can wrongly think something here esp when constrained by higher law.

Finally, at the end of the day, I don't see Prof. Dorf accepting rational basis is met today.
The amendments can interfere with that and it is part of their problem. NY, e.g., didn't require the added effort of passing an amendment to put SSM in place. Normal legislative process was allowed to addressing changing times.

Finally, it has to be shown that same sex marriage is an "invented" right any more than more gender equal marriages in the 1970s were. If so, where was the wave of amendments blocking that?

---

As to JHW, one issue there is that the argument is so weak no matter how you play it. Why exactly is it latched on to? It is a legal fiction that animus is not significantly involved.

Michael C. Dorf said...

Hash: I don't think that works on a combination of Supremacy and Erie grounds. Subject to whatever is left of the political process doctrine following Schuette v. BAMN, in a state in which the voters amend the state constitution by referendum, they can constrain state judges or state legislators via referendum, but that will only mean that they thereby provide a constraint under state law. That should not affect the analysis under the federal Constitution.

Let's suppose that in 1925 the state legislature would have a rational basis for authorizing the issuance of driver's licenses only to drivers w/o also providing non-driver IDs, but that by 2000 the state legislature lacks such a rational basis. If so, then the voters of the state in 2000 also lack a rational basis for enacting a state constitutional ban on non-voter IDs--even if their goal is to constrain judges or state legislators. There is no valid rational basis for constraining the Supremacy of federal law. Erie is also relevant in that federal law treats all sources of state law (whether state legislation or state constitutional amendments) as the same--absent some extroardinary provision or doctrine that limits the means by which a state may change its law (e.g., the Takings Clause, Art II w/r/t Presidential elections, certain aspects of procedural due process).

Hashim said...

Mike, I don't understand your reference to Supremacy Clause or Erie. I never once argued that the State's citizens had a rational basis in constraining the supremacy of federal law.

Federal law -- namely, EPC/DPC -- of course fully applies, and the substantive question under those clauses is whether the State's citizens had a rational basis in not only refusing themselves to extend marriage to gays under state law, but in preventing their legislators or judges from extending marriage to gays under state law either.

The answer to that question is obvious: whatever rational basis justifies the State's citizens' failure to extend marriage to gays equally justifies their refusal to allow their legislators or judges to extend marriage to gays, because the legislators and judges are their agents and thus the citizens can rationally want them to follow suit.

More concretely, here, the rational basis asserted is that the marital relationship is recognized by the State in order to limit the number of unwanted children from accidental procreation, by channeling people who procreate into stable family units. That particular interest isn't implicated by gays, and so there's a rational reason not to extend marriage to them. And since there's a rational reason not to extend marriage to them, and the State's citizens agree with that reason, a State's citizens are acting completely rationally in stopping their legislative and judicial agents from defying their wishes and gratutiously expanding marriage to gays based on their own ideological beliefs.

Given your driver's license hypo, it warrants emphasis that this rational basis is equally valid today as in 1925 as in 25 BC: gay people simply do not present any meaningful risk of creating unwanted children through accidental procreation, and so the State dpes not have that reason to channel them into marriage. Thus, this isn't some case where the State's citizens no longer have a rational basis for their law and are nevertheless trying to prevent their legislators and judges from updating the law to eliminate irrationality. Rather, this is a case where the State's citizens continue to have the same rational basis that has existed from the dawn of human history, and they do not want to let their legislators and judges subordinate that rational basis based on their modern ideological beliefs.

Finally, yes, this rational-basis defense would be subject to attack under whatever's left of the political process doctrine after Schuette. I suspect you know what what I think remains of that preposterous doctrine.

Michael C. Dorf said...

Ah, now I see what you're saying. I think the title of my post misled you into thinking that I was conceding that the state (and thus the voters) would have a rational basis for consciously choosing not to extend marriage to same-sex couples. I meant to concede arguendo only that it might be rational for a state (through whatever means) to fail to extend marriage to same-sex couples if the state simply wasn't thinking about the non-procreation-related reasons for people getting married, i.e., that such an oversight might be rational. However, once the issue is on the agenda there is not a rational basis to deny same-sex couples the right to marry, given all of the other tangible and intangible benefits that go with marriage and that have nothing to do with accidental procreation. And it is wildly implausible to imagine that the voters for a state referendum are preserving their decision to fail to notice the possibility of SSM, as opposed to voting to prevent same-sex couples from marrying.

Hashim said...

Fair enough. I'll be curious at some point to hear why it's "irrational" to refuse to extend a legal status to people who don't implicate the reason why the status was created in the first place, simply because they want to be ancillary beneficiaries of the status.

For example, imagine if, in response to a drunk-driving epidemic, the State creates a "sober driver" program, where drivers who choose to participate permanently give up alcohol, are rewarded with an array of tangible and intangible benefits, and are penalized for non-compliance. Now imagine that people who are physically incapable of driving drunk -- e.g., because they're physically unable to drive, or to drink alcohol, or both -- ask to participate in the program because they too want the benefits of the "sober driver" program and are willing to incur the costs. It seems blazingly obvious to me that the State could rationally refrain to expand the "sober driver" program to non-drivers, no matter how much they'd benefit from participation.

So too with marriage: the Govt has traditionally recognized marriage, not because it sentimentally cares about "love" or "relationships", but because creating monogamous family units is the best way to reduce the number of accidentally conceived children who will end up as wards of the state. Or, at the very least, that's certainly a rational reason to create this institution.

By the way, I imagine there's a decent test of whether marriage is fundamentally about procreation: surely there have been some governments at some point in time that have not condemned homosexuality as immoral; did they allow gays to "marry"? I strongly suspect not, which is pretty hard to explain on your view of the world. Though perhaps I'm wrong about the existence of any such govt(though that would be pretty damning evidence against this purported constitutional right as well).

Scott said...

@Hashim: "If (as you're willing to assume arguendo for purposes of this post) a State acts rationally in not extending marrriage to gays, then I think you're overlooking a pretty obvious rational basis for passing state constitutional amendments banning same-sex marriage: namely, preventing state court judges from ignoring that rational basis and extending marriage to gays based on nothing more than their own ideological preferences disguised as constitutional holdings. It's no surprise that the wave of constitutional amendments came in the wake of state-court decisions inventing a state constitutional right to ssm."

So your argument is that if it's rational to fail-to-extend, it should be rational to ban in order to prevent judicial extension. The obvious problem with that logic is that now you've converted failure-to-extend into a ban, which therefore becomes susceptible to the justification arguments already leveled at bans.

"Simply put, it's obviously rational for a State's citizens to stop a State's judges from inventing rights that the public doesn't believe exist."

I think you meant to say "that a majority of the public doesn't believe exists." If at least some members of the public didn't believe that the right existed, no one would be suing for it. So essentially you're arguing for a tyranny of the majority in a civil rights case. Hopefully you can see why that's problematic for a number of us.

JHW said...

Hashim: I think your latest comment misses the point. Say we adopt the "sober driver" program you describe, and we enforce its boundaries with the following rule: "This program is only open to people with driver's licenses." And say the program is challenged on equal protection grounds by people without driver's licenses who want the benefit of the program.

Surely the state will not say: well, it wouldn't actually do any harm to extend this program to everyone, but it just wasn't what we were thinking about it when we designed it, so go home. The state can say, perfectly reasonably, "We made a deliberate choice to exclude people without driver's licenses, and we did so for a specific reason: the costs we undertake to provide the benefits and to administer and enforce this program outweigh the (lesser) benefits of reducing alcohol use among non-drivers." That's an actual claim of harm to a legitimate state interest (cost reduction).

The problem with the legal arguments against same-sex marriage is that they have largely abandoned even this sort of claim. They don't say, "If we legalize same-sex marriage, we'll take on new cost burdens that exceed the benefits of marriage where accidental procreation is not at issue." There are at least two reasons, I think, that this argument gets very little play. First, it is a very poor match to the actual legal structure of marriage, and thus can instead backfire by highlighting the irrational and discriminatory ways state law in no-recognition states treat same-sex couples. (That's why, in general, people and states are *more* willing to extend the tangible legal elements to same-sex couples than they are to extend the status itself.) Second, relatedly, marriage as a government subsidy scheme whose boundaries must be policed to save the state costs is an extremely deflationary view of marriage that states are unlikely to want to wholeheartedly endorse and judges are unlikely to find plausible.

Joe said...
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Joe said...
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Joe said...

Okay. So we are moving past labeling judges covering up law with personal ideology because apparently (see nothing else really) we disagree with them? That's good.

More concretely, here, the rational basis asserted is that the marital relationship is recognized by the State in order to limit the number of unwanted children from accidental procreation, by channeling people who procreate into stable family units. That particular interest isn't implicated by gays, and so there's a rational reason not to extend marriage to them.

Marriage furthers monogamy, including in same sex couples where one of the members might have an affair with another sex. Bisexuals exist. This can result in accidental pregnancy. So it is "implicated."

Likewise, gays and lesbians "procreate" overall, including those who feel a desire to have children. Marriage channels them into more stable relationships with added support of a partner. It also helps the children involved in the process. This is not directly the same thing but the point here is not merely to creatively find some "rational" reason to stop same sex marriages but overall protect the interests of children.

Animus and other factors lead to such unreasonable analysis and the judiciary is in part there to guard against the tyranny of the majority, including when it wrongly handcuffs the legislature by amendments that make changing policy for certain groups of people harder to pass.

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Emma O'Connell said...

But let us suppose for the sake of argument that the SSM bans were subject only to rational basis scrutiny. Even so, the one-step-at-a-time defense would fail as a response to Judge Posner's argument about adoption. To see why, one needs to examine exactly what the state is saying in its accidental procreation argument. The state is not saying that preventing same-sex couples from marrying in some way prevents accidental procreation by unmarried heterosexuals.Buy FIFA 15 Coins
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