Case: Charelle Loder v. Reese McKinney, Jr.

2:11-cv-00979 | U.S. District Court for the Middle District of Alabama

Filed Date: Nov. 17, 2011

Closed Date: 2013

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Case Summary

On November 17, 2011, several couples who reside in Alabama filed a class action lawsuit in the U.S. District Court of the Middle District of Alabama against the State of Alabama, alleging violations of the Due Process Clause and Equal Protection Clause of the 14th Amendment. The plaintiffs, represented by the Southern Poverty Law Center and private counsel, sought a declaratory judgment, injunctive relief, and attorneys' fees, alleging that the defendants' policies discriminated against non-U…

On November 17, 2011, several couples who reside in Alabama filed a class action lawsuit in the U.S. District Court of the Middle District of Alabama against the State of Alabama, alleging violations of the Due Process Clause and Equal Protection Clause of the 14th Amendment. The plaintiffs, represented by the Southern Poverty Law Center and private counsel, sought a declaratory judgment, injunctive relief, and attorneys' fees, alleging that the defendants' policies discriminated against non-U.S. citizens trying to obtain a marriage license in Alabama.

In Alabama, no person may marry without a marriage license. One of a probate judge's ministerial jobs is to issue marriage licenses to those couples that meet the requirements. Alabama law states that the parties issuing the marriage license must obtain the Social Security Number of the individuals getting married and have it appear in the marriage license and certificate. In 2008, the Alabama Attorney General, issued a statement saying that a Social Security Number or other proofs of citizenship were not required to obtain a marriage license. The Attorney General ordered the probate offices to instead allow people trying to get married the opportunity to submit an affidavit saying they do not have a Social Security Number.

On September 13, 2012, the District Court (Judge William Keith Watkins) denied Defendant Probate Judge McKinney, Jr.'s (Probate Judge Reed's predecessor) motion to dismiss. The defendant argued that the plaintiffs did not have standing since they did not apply for a marriage license and thus did not suffer any type of injury. However, the District Court (Judge Watkins) did not buy this argument since Judge McKinney, Jr. had a clear policy of requiring non-citizens who wanted to get a marriage license to provide proof of legal status. The District Court (Judge Watkins) thus found that the plaintiffs were effectively barred from applying for a marriage license and that applying for it would have been futile. On September 25, 2012, the District Court (Judge Watkins) denied the plaintiffs' motion for class certification so on December 7, 2012, the plaintiffs filed their first amended complaint.

On June 3, 2013, the District Court (Judge William Keith Watkins) entered a protective order assuring the confidentiality of certain information disclosed by both parties. On June 11, 2013, the District Court (Judge Watkins) granted Defendant Probate Judge Reed's motion to dismiss any claims against him. Judge Reed argued that his probate office did not require proof of citizenship prior to issuing marriage licenses, and that he was actually willing to give the plaintiffs their marriage licenses if they had applied for it. Judge McKinney, Jr.'s prior policy was repealed and so the District Court (Judge Watkins) found that the plaintiffs no longer had standing.

On August 19, 2013, the District Court (Judge William Keith Watkins) approved the parties' joint stipulation of dismissal. As part of the agreement, the official Probate County's marriage policy was amended and published so that it was clear that there were no citizenship requirements, including a Social Security Number, to obtaining a marriage license.

Summary Authors

Perry Miska (3/30/2014)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/5534842/parties/loder-v-mckinney/


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Documents in the Clearinghouse

Document

2:11-cv-00979

Docket

Aug. 19, 2013

Aug. 19, 2013

Docket
1

2:11-cv-00979

Class Action Complaint

Nov. 17, 2011

Nov. 17, 2011

Complaint
32

2:11-cv-00979

Order and Memorandum Denying Defendants' Motion to Dismiss

Charelle Loder, et al. v. Reese McKinney, Jr.

Sept. 13, 2012

Sept. 13, 2012

Order/Opinion

896 F.Supp.2d 1116

36

2:11-cv-00979

Order (Denying Plaintiffs' Motion for Class Certification)

Sept. 25, 2012

Sept. 25, 2012

Order/Opinion
51

2:11-cv-00979

First Amended Complaint

Dec. 7, 2012

Dec. 7, 2012

Complaint
74

2:11-cv-00979

Stipulated Protective Order

June 3, 2013

June 3, 2013

Order/Opinion
77

2:11-cv-00979

Memorandum Opinion and Order

June 11, 2013

June 11, 2013

Order/Opinion

2013 WL 2566907

82

2:11-cv-00979

Order and Stipulation of Dismissal

Aug. 19, 2013

Aug. 19, 2013

Order/Opinion

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/5534842/loder-v-mckinney/

Last updated Dec. 18, 2024, 3:43 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Alabama

Case Type(s):

Immigration and/or the Border

Special Collection(s):

Multi-LexSum (in sample)

Key Dates

Filing Date: Nov. 17, 2011

Closing Date: 2013

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Couples, where at least one individual is not a U.S. citizen, who are barred by an Alabama law from obtaining a marriage license.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Southern Poverty Law Center

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Denied

Defendants

State of Alabama, State

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

Declaratory Judgment Act, 28 U.S.C. § 2201

Constitutional Clause(s):

Due Process

Equal Protection

Available Documents:

Trial Court Docket

Complaint (any)

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Form of Settlement:

Voluntary Dismissal

Issues

General/Misc.:

Marriage

Discrimination Basis:

Immigration status

Immigration/Border:

Constitutional rights

Family Separation

Undocumented immigrants - rights and duties

Undocumented immigrants - state and local regulation