Case: Goodridge v. Department of Human Health

01-01647 | Massachusetts state trial court

Filed Date: 2001

Closed Date: 2003

Clearinghouse coding complete

Case Summary

On September 24, 2002, fourteen private citizens of five different Massachusetts counties filed this lawsuit in the Suffolk Superior Court in Massachusetts. The plaintiffs, all of which were in long-term same-sex relationships, sued the Massachusetts Department of Human Health because they believed that the Department’s refusal to issue them marriage licenses violated their rights under the Massachusetts Constitution. Represented by lawyers associated with GLAD, the plaintiffs asked the court f…

On September 24, 2002, fourteen private citizens of five different Massachusetts counties filed this lawsuit in the Suffolk Superior Court in Massachusetts. The plaintiffs, all of which were in long-term same-sex relationships, sued the Massachusetts Department of Human Health because they believed that the Department’s refusal to issue them marriage licenses violated their rights under the Massachusetts Constitution. Represented by lawyers associated with GLAD, the plaintiffs asked the court for declaratory relief acknowledging that their exclusion from receiving marriage licenses violates Massachusetts law on both due process and equal protection grounds. Judge Thomas E. Connolly of the Suffolk Superior Court granted summary judgment for the defendants, and the case was appealed directly to the Massachusetts Supreme Court.

The main issue before the Massachusetts Supreme Court was whether or not government actions to prevent same-sex couples from obtaining marriage licenses—and thus marriages—was a proper use of the State’s authority to regulate the conduct of its citizens, or if this conduct violated the Massachusetts Constitution. On November 18, 2003, the Massachusetts Supreme court ruled for the latter.

Writing the court’s opinion, Chief Justice Margaret Marshall discussed (and dismissed) all three of the defendant’s main rationales for excluding same-sex couples from obtaining civil marriages. The defendant’s first argument, that marriage should be solely between a man and a woman because this arrangement was optimal for procreation, was dismissed because intent to have children has never been a requirement of heterosexual couples to obtain marriage licenses.

The defendants next argued that marriage in Massachusetts needed to be kept between a man and a woman to ensure the optimal setting for child rearing. The court dismissed this claim because heterosexual marital status was not a prerequisite for adopting a child in Massachusetts at the time. In fact, many of the plaintiffs had children of their own. The court reasoned that, if anything, extending civil marriages to same-sex couples would promote child welfare because it would enable more children to be raised in households with the financial and legal benefits afforded by marriage.

Thirdly, the defendants argued that same-sex marriages would put a strain on state resources because they reasoned that same-sex couples were more financially independent. The court noted that this is not necessarily true—many of the plaintiffs in the case had dependents, including children and older relatives. Also, the court noted that heterosexual couples were not required to be financially dependent on one-another to obtain a marriage license.

The court held that the defendant had not articulated any adequate constitutional justification for maintaining the marriage ban, and so found for the plaintiffs, declaring that—and thereby changing the common law of Massachusetts to say—that marriage is “the voluntary union of two persons as spouses, to the exclusion of all others.” It instituted a 180-day stay to allow the legislature to take action based on its decision, and it reversed and remanded the case to the Suffolk Superior Court for judgment. 798 N.E.2d 941 (2003).

This was the first time that the highest court in any state had ruled in favor of same-sex marriage. Almost a dozen years later, the Supreme Court effectively lifted the marriage ban for the United States in Obergefell v. Hodges (PB-OH-003 in this clearinghouse).

Summary Authors

Megan Brown (10/9/2016)

People


Judge(s)

Cordy, Robert J. (Massachusetts)

Greaney, John M. (Massachusetts)

Marshall, Margaret H. (Massachusetts)

Sosman, Martha B. (Massachusetts)

Spina, Francis X (Massachusetts)

Attorneys(s) for Plaintiff

Bonauto, Mary L. (Massachusetts)

Buseck, Gary D. (Massachusetts)

Klein, Bennett H. (Massachusetts)

Levi, Jennifer (Massachusetts)

Loewy, Karen L. (Massachusetts)

Judge(s)

Cordy, Robert J. (Massachusetts)

Greaney, John M. (Massachusetts)

Marshall, Margaret H. (Massachusetts)

Sosman, Martha B. (Massachusetts)

Spina, Francis X (Massachusetts)

Attorneys(s) for Plaintiff

Bonauto, Mary L. (Massachusetts)

Buseck, Gary D. (Massachusetts)

Klein, Bennett H. (Massachusetts)

Levi, Jennifer (Massachusetts)

Loewy, Karen L. (Massachusetts)

Attorneys(s) for Defendant

Edwards, Kenneth E. (Washington)

Rice, Juliana DeHann (Massachusetts)

Sacks, Peter (Massachusetts)

Documents in the Clearinghouse

Document

01-01647

Docket

Nov. 1, 2005

Nov. 1, 2005

Docket

01-01647

Opinion of Supreme Judicial Court of Massachusetts

Goodridge v. Department of Public Health

Massachusetts state supreme court

798 N.E.2d 941

Nov. 18, 2003

Nov. 18, 2003

Order/Opinion

Resources

Docket

Last updated July 27, 2022, 3 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Massachusetts

Case Type(s):

Public Benefits/Government Services

Special Collection(s):

Same-Sex Marriage

Key Dates

Filing Date: 2001

Closing Date: 2003

Case Ongoing: No

Plaintiffs

Plaintiff Description:

fourteen private citizens from five different Massachusetts counties. All fourteen of these citizens were engaged in long-term same-sex relationships.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

GLAD (GLBTQ Legal Advocates & Defenders)

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

The State of Massachusetts (Suffolk), State

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

State law

Constitutional Clause(s):

Due Process

Equal Protection

Availably Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Declaratory Judgment

Source of Relief:

Litigation

Issues

General:

Gay/lesbian/transgender

Marriage

Discrimination-basis:

Sexual orientatation