12-689 coalition's reply brief

7/29/2019 12-689 Coalition's Reply Brief

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No. 12-689

In the Supreme Court of the United States_________

COALITION FOR THE PROTECTION OF MARRIAGE,Petitioner,

v.

BEVERLYSEVCIK, et al.,Respondents.

________________________

On Petition for a Writ of CertiorariBefore Judgment to the

United States Court of Appealsfor the Ninth Circuit

________________________

REPLY BRIEF FOR THE PETITIONER_______________________

MONTE NEIL STEWARTCounsel of Record

CRAIG G.TAYLORDANIEL W.BOWERBELNAP STEWART TAYLOR &

MORRIS PLLC12550 W. Explorer Drive,

Suite 100Boise, Idaho 83713(208) [email protected]

WILLIAM C.DUNCANMARRIAGE LAW

FOUNDATION1868 North 800 EastLehi,Utah 84043(801) 367-4570

Counsel for Petitioner Coalition for the Protection ofMarriage


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TABLE OF CONTENTS

Page

1. A states federal constitutional authority to

preserve marriages man-woman meaning does notturn on whether it has adopted a domestic

partnership arrangement .......................................... 2

2. The Coalition has Article III standing in its own

right, and, in any event, the McConnellpiggy-back

doctrine applies with full force to the Petition ......... 9

3. The Oppositions discussion of grant, vacate, and

remand has no application to this case or to the

Petition ..................................................................... 13

APPENDIX IState Constitutional Provisions

On Domestic Partnerships ...................................... 1a


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TABLE OF AUTHORITIES

Cases

Diamond v. Charles,476 U.S. 54 (1986) .......................................... 11, 12

In re McElrath,

248 F.2d 612 (D.C. Cir. 1957) .............................. 11

King v. Bd. of Regents of Univ. of Nevada,

200 P.2d 221 (1948) ................................................ 7

McConnell v. Fed. Election Comm'n,

540 U.S. 93 (2003) .................................................. 9

Perry v. Brown,

671 F.3d 1052 (9th Cir. 2012) ................................ 1

Romer v. Evans,

517 U.S. 620 (1996) ................................................ 3

Constitutions and Statutes

28 U.S.C. 1254(1) ............................................... 9, 12

Nev. Rev. Stat. 122A.010 et seq. ........................... 2

Utah Const. art. I, 29 .............................................. 6

Rules

Federal Rule of Civil Procedure 24.......................... 10


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Other Authorities

Amici Curiae Brief of Judge Georg Ress and the

Marriage Law Foundation in Support of

Petitioners, Hollingsworth v. Perry, 133 S.Ct. 786(2012) (No. 12-144) ................................................. 5

Amicus Curiae Brief of Coalition for the Protection of

Marriage in Support of Hollingsworth and

Bipartisan Legal Advisory Group Addressing the

Merits and Supporting Reversal, Hollingsworth v.

Perry, Nos. 12-144 and 12-307

(U.S. Jan. 29, 2013) ................................................ 3

Eugene Gressman et al., Supreme Court Practices

2.52.4 (9th ed. 2007) ............................................ 9

John R. Searle, Making the Social World: The

Structure of Human Civilization (2010) ................ 4

Matthew O'Brien, Why Liberal Neutrality Prohibits

Same-Sex Marriage: Rawls, Political Liberalism,

and the Family, 1 Brit. J. Amer. L. Studies 411

(2012) ...................................................................... 4

Monte Neil Stewart, Eliding in Washington and

California,42 Gonzaga L. Rev. 501 (2007)............. 6

Monte Neil Stewart, Judicial Redefinition of

Marriage, 21 Can. J. Fam. L. 11 (2004) .................... 8


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________________________

REPLY BRIEF FOR THE PETITIONER_______________________

The Nevada government officials named as

defendants in this civil action and now appearing as

respondents (Government Respondents) have filed

no opposition to the Coalitions petition for writ of

certiorari before judgment (Petition). The

plaintiffs below (Plaintiff Respondents) have filed a

Brief in Opposition (Opposition).

The Petition demonstrated that this case is

optimal for resolving the fundamental marriage

issue. That issue is whether a state has sufficiently

strong interests in preserving the man-woman

meaning at the core of our societys marriage

institutionwhen at no time in its history has the

state allowed marriage by a same-sex couple. That

issue applies to all forty-one states that continue to

preserve marriages core man-woman meaning

except California. See Pet. App. 62a70a. Theunique California experience is now before this

Court in Hollingsworth v. Perry, No. 12-144.

Although it is possible that this Court will resolve

Perry in a way that answers the fundamental

marriage issue, that is far from certain; the Ninth

Circuit did not do so, relying instead on the unique

take away feature it perceived in Californias

Proposition 8. SeePerry v. Brown, 671 F.3d 1052,

1064, 1076, 1082 n.14, 1087 n.20, 1096 (9th Cir.

2012), cert. granted sub nom.Hollingsworth v. Perry,133 S.Ct. 786 (Dec. 7, 2012).

The Opposition seeks to denigrate this cases

optimal relationship to the fundamental marriage


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issue by making two arguments, both of which are

plainly wrong.

1. A states federal constitutional authority topreserve marriages man-woman meaning

does not turn on whether it has adopted a

domestic partnership arrangement.

The Opposition argues that Nevadas 2009

enactment of a domestic partnership arrangement

available to same-sex couples1 somehow rendered

unconstitutional the 2002 amendment to Nevadasconstitution that preserves marriages man-woman

meaning (Marriage Amendment). The Opposition

then argues that only a very small and possibly

shrinking number of states share Nevadas legal

landscape, that is, a legal landscape preserving

marriages man-woman meaning while providing

comprehensive domestic partnership or civil union

schemes available to same-sex couples. Thus, the

argument goes, this case will not resolve the

fundamental marriage issue. Oppn at 1112.

This narrow grounds argument makes sense

only if a states adoption or not of a domestic

partnership arrangement has any genuine

constitutional significance relative to the marriage

issue. It does not.

Forty-one states have elected to preserve by law

marriages man-woman meaning. See Pet. App. at

67a70a. Of those, eight have chosen to make

available to same-sex couples a domestic partnership

or similar arrangement. Oppn at 11. Of the thirty-three that have not yet made that choice, nineteen

1Domestic Partnership Act, Nev. Rev. Stat. 122A.010 et seq.


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have a constitutional provision precluding such an

arrangement. See Reply Pet. App. at 1a4a; see also

Pet. App. at 62a66a.2

The Oppositions narrow grounds argument

seems to have two facets: one, the domestic

partnership legislation somehow effectively

repudiates all the strong public interests advanced

by the man-woman marriage laws, leaving

thereafter those laws with an insufficiently strong

basis in policy; and, two, because all the legislature

or voters are doing with the man-woman marriage

laws is withholding from same-sex couples the mere

word marriage, the state cannot possibly have a good

reason for such a course, and therefore all that is at

work must be the kind of animus prohibited by

Romer v. Evans, 517 U.S. 620 (1996).

Social institutional realities defeat both facets of

the argument.3 Because social institutions are

constituted by, and only by, complex webs of widely

shared public meanings and are created by language

acts, language creates the social reality that

marriage unquestionably is. Marriage is an

institution as fundamental, influential, and

consequential as any. Accordingly, the political/legal

power over the mere word marriage is a massive

2The chart in the Petition Appendix incorrectly identifies

Tennessee as such a state.3The Petition at 1521 and 2932 summarizes those realities,

and the Coalitions amicus curiae brief in Perry and Windsor

fleshes them out. Amicus Curiae Brief of Coalition for the

Protection of Marriage in Support of Hollingsworth andBipartisan Legal Advisory Group Addressing the Merits and

Supporting Reversal, Hollingsworth v. Perry, Nos. 12-144 and

12-307 (U.S. Jan. 29, 2013).


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power. That power flows from the laws expressive

effect and is reinforced by the laws coercive and

pedagogical powers:

The legal institution of marriage has the

expressive effect of socially recognizing,

promoting and dignifying the nature of the

relationships that the law deems eligible for

marriage. [T]he debate is about which rival

conception of sexual value and identity should

harness laws expressive effect and be

reinforced by the laws coercive and

pedagogical powers.4

Informed genderless marriage advocates know

this. One sees the role of the vocabulary in the

activities of revolutionary and reformist movements.

They try to get hold of the vocabulary in order to

alter the system . . . .5 Here the role of the

vocabulary, that is, the laws and hence societys use

of the mere word marriage, will determine the fate

of the childs bonding interest, of bionormativity in

the construction of parenthood, of natural rights in

family relations, of the statuses and identities of

husband and wife, and on and on. Accordingly, a

society cannot give up the mere word marriage

without giving up the man-woman marriage

institution and the valuable social goods that it

uniquely provides.

4

Matthew B. OBrien, Why Liberal Neutrality Prohibits Same-Sex Marriage: Rawls, Political Liberalism, and the Family , 1

Brit. J. Amer. L. Studies 411, 414 (2012).5John R. Searle, Making the Social World: The Structure of

Human Civilization 104 (2010).


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Certainly the preservation of those goods is the

wholly legitimate and compelling objective of the

man-woman marriage laws in Nevada and the forty

other states with such laws. That reality refutes the

animus facet of the Plaintiff Respondents

argument, built as it is on the false premise that a

state and its people have no substantial legitimate

reason to preserve the man-woman marriage

institution. That facet is further refuted by the

truth that

[t]he overwhelming international consensus

including among liberal western democracies

with established traditions of concern for the

rights of gays and lesbiansis that reserving

the formal institution of marriage to opposite-

sex couples while supporting same-sex couples

through other rights and legal mechanisms is

sound public policy. That consensus is based

not on irrationality, ignorance, or animus

toward gays and lesbians but on considered

judgments about the unique nature and needsof same-sex couples and children.6

The other facet of the argument for a society to

recognize domestic partnerships somehow destroys

its compelling interests in preserving man-woman

marriageis equally baseless. To create a domestic

partnership arrangement while still preserving

marriages man-woman meaning simultaneously

supports same-sex couples and insures the laws

continuing support for the man-woman marriage

6Amici Curiae Brief of Judge Georg Ress and the Marriage

Law Foundation in Support of Petitioners at 2, Hollingsworth

v. Perry, 133 S.Ct. 786(2012) (No. 12-144).


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institutionexactly for the purpose of preserving the

valuable social goods it uniquely provides. After all,

in both law and the public understanding a key

meaning of domestic partnership is not marriage.7

That not-marriage meaning is essential for the

perpetuation of the valuable social goods our existing

marriage institution uniquely providesgoods that a

genderless marriage regime cannot provide and

towards which it will be inimical.

In light of these realities, a states adoption (or

not) of a domestic partnership arrangement has no

genuine constitutional significance. Federal

constitutional jurisprudence does not and should not

take the silly position of countenancing, for example,

Utahs laws, which protect man-woman marriage

and prohibit domestic partnerships and similar

arrangements,8 while not countenancing Nevadas

laws protecting man-woman marriage and providing

domestic partnerships for same-sex couples. For

federal constitutional jurisprudence, the authentic

question for both Nevada and Utah and all statessituated like them must come down to the

fundamental marriage issue: Does a state have

sufficiently strong reasons and interests for

preserving the man-woman meaning constitutive

and at the core of our social institution of marriage?

Moreover, the Plaintiff Respondents own

arguments to the District Court refute their

assertion now that this cases sole issue is and

always has been the constitutionality of a man-

7See Monte Neil Stewart, Eliding in Washington and

California, 42 Gonz. L. Rev. 501, 510 n.40 (2007).8Utah Const. art. I, 29.


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woman marriage law in a legal context also

providing for a domestic partnership arrangement.

Their arguments have relied most heavily on the

assertion that the social sciences somehow prove

the societal interests advanced by the man-woman

marriage institution either to be weak or to not be

affected by implementation of a genderless marriage

regime, see Dkt. Nos. 86, 86-2, 86-3, 98, 98-1, 98-2,

rather than on the assertion that Nevadas Domestic

Partnership Act repudiates those interests. Their

primary assertion goes directly to the fundamentalmarriage issue and is not at all tied to the presence

or not of a domestic partnership arrangement.

Further, Plaintiff Respondents argument is

premised on the notion that a state statute

(Nevadas Domestic Partnership Act) can override

the policies and purposes of a state constitutional

provision (Nevadas Marriage Amendment) and

thereby render the latter unconstitutional. That

notion is clearly wrong. If the policy judgments of

one must give way, it must be those of the statute.The Domestic Partnership Act has no power to

repudiate the important social, governmental, and

personal interests protected and advanced by the

Marriage Amendment. SeeKing v. Bd. of Regents of

Univ. of Nevada, 200 P.2d 221, 225 (1948) (state

constitutions are limitations of the lawmaking

power and legislation cannot contravene some

expressed or necessarily implied limitation

appearing in the constitution itself).

Because it is built entirely on the never-provenand clearly wrong premise that implementation or

not of a domestic partnership arrangement has

constitutional significance, the Oppositions narrow


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grounds argument collapses entirely. This case

from Nevada really is optimal for resolving the

fundamental question. In important part, that is so

because this case cannot be resolved without

answering that question, and the answer will

certainly determine marriages fate in at least forty

states.

This correct understanding of this cases

connection to the fundamental marriage issue also

illuminates the weakness of the Oppositions

prudential argument against the Petition: this

Court should allow more time for lower courts to

consider, develop, and refine the issue. Oppn at

1213. However, already at least twenty-one state

appellate court decisions9 and thirteen federal court

decisions have addressed some aspect of the issue,

and the serious judicial and extrajudicial dialogue on

the issue has been going on for twenty years now.

Pet. at 14; Pet. App. at 59a61a. These realities

quite thoroughly undercut the Oppositions call for

more delay to get more lower court input.

9Although the state courts were interpreting equality and

liberty norms arising from state constitutions, in all materialrespects the issue and hence the judicial analysis were the

same as the issue and analysis in the federal context. See, e.g.,

Monte Neil Stewart, Judicial Redefinition of Marriage, 21 Can.

J. Fam. L. 11, 2829 (2004).


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2. The Coalition has Article III standing in itsown right, and, in any event, theMcConnell

piggy-back doctrine applies with full

force to the Petition.

The Oppositions second attack on this cases

optimal status is to assert that the Coalition does

not have Article III standing and that this asserted

lack of standing precludes the Coalition from alone

filing the Petition. The Opposition also argues that

the McConnell piggy-back doctrine10 somehow

does not operate in the context of 28 U.S.C.

1254(1), which provides that any party may file a

petition for writ of certiorari before judgment.11

This case has always qualified as a case or

controversy under Article III. Without question,

the Plaintiff Respondents, on one hand, and the

Government Respondents, on the other hand, each

have Article III standing because the members of

the former group are seeking to vindicate what they

see as their personal federal constitutional rights

and thus are seeking to impose a coercive judgment

on the members of the latter group, with at least

two of the Government Respondents (Governor

Sandoval and Clerk-Recorder Glover) actively and

consistently opposing such a judgment. See Dkt.

Nos. 74, 85, 96, 97.

Further, this case is one case and always has

been. It has not divided amoeba-like to create one

10

See McConnell v. Fed. Election Commn, 540 U.S. 93, 233(2003), overruled in part on other grounds by Citizens United v.

Fed. Election Commn, 558 U.S. 310 (2010).11See Eugene Gressman et al., Supreme Court Practice 2.52.4

(9th ed. 2007).


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case in the District Court, another case in the Court

of Appeals, and yet another case in this Court. It is

one case with its genuine parties and its genuine

controversy. (We note this because the Opposition

seems to characterize the case here as somehow

different and separate from the case in the Court of

Appeals, with resulting confusion of analysis on the

standing issue. SeeOppn at 710.)

As to genuine parties, the Coalition is every bit as

much a party to this case as any of its other parties.

That is the logic and operation of Federal Rule of

Civil Procedure 24, especially where, as here, the

District Courts order made the Coalition a party

without any conditions or restrictions on its

involvement in the case. Dkt. No. 67.

No standing or other justiciability issue hampers

this case, either in general or in connection with the

Petition. It is uncontested that this case contains

parties on both sides with standing, and the parties

are genuinely adverse and are litigating accordingly.

The Oppositions effort to cloud that reality should

get no traction.

The Coalition has its own Article III standing on

four independent and individually adequate

grounds. One, the Coalition has a real, concrete, and

highly particularized reputational interest at stake

here. The Plaintiff Respondents have made in this

case the standard animus/bigotry arguments and

focused them with particularly on the Coalition,

even before the Coalition was a party. It is not the

Government Respondents who have been the targetsof the animus/bigotry arguments; rather, the target

has been the Coalition because of its unique role as


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the leader of the campaign in favor of the Marriage

Amendment and as the primary source of the

campaign ads. See Dkt. Nos. 1 at 9; 30 at 13. Such a

particularized reputational interest at stake in this

context sustains Article III standing. E.g., In re

McElrath, 248 F.2d 612, 616 (D.C. Cir. 1957). Two

and three, as established in the District Court, see

Dkt. No. 30 at 1315, the Coalition has associational

standing relative to its members particularized

interests both in the perpetuation of the man-woman

marriage institution and its unique social goods andin specific religious liberties put in genuine jeopardy

by a move to a genderless marriage regime. Id.

Four, as proponent of the Marriage Amendment, the

Coalition under Nevada law stands in the same

relationship to this case as the Petitioners in Perry

under California law have in that case, with only the

difference that some Nevada officials are actively

opposing the plaintiffs claims.

The McConnellpiggy-back doctrine applies with

full force to the Petition, and the Oppositionssuggestions to the contrary are clearly wrong. First,

in this case, unlike Windsor, the government officials

whose standing matters for purposes of the doctrine

have since the beginning of the case actively and

continuously opposed the plaintiffs claims; those

officials are Governor Sandoval and Clerk-Recorder

Glover. They have not opposed the Petition and

continue to actively oppose the Plaintiff

Respondents claims.

Second, Diamond v. Charles, 476 U.S. 54 (1986),clearly does not apply here. There,


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[b]y not appealing the judgment below, the

State indicated its acceptance of that decision,

and its lack of interest in defending its own

statute. The States general interest may be

adverse to the interests of appellees, but its

failure to invoke our jurisdiction leaves the

Court without a case or controversy

between appellees and the State of Illinois.

Id. at 6364. In contrast, here Nevada has not

accepted, and thereby declined to contest further, an

adverse judgment; rather, it (through the Governor

and the Clerk-Recorder) continues to defend the

Marriage Amendment against the Plaintiff

Respondents claims.

The only question is where the next round of the

litigation will occur, here or in the Court of Appeals.

Either place, this case will fully qualify as an Article

III case or controversy because, in either place, the

concrete interests and actual adversity of the parties

will be exactly the same. That reality is not altered

by the fact that it was the Coalition rather than

some other party that invoked the right of any

party to seek to have the next round of the contest

here instead of in the Court of Appeals. See 28

U.S.C. 1254(1).

As to the wisdom of the next round being here

instead of in the Court of Appeals, the fundamental

marriage issue has been fully ventilated, developed,

and refined, both judicially and extrajudicially, over

the past twenty years; the issue is one of surpassing

importance and consequence; and the Nation itseems to us is understandably anxious to have this


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Court resolve that issue now. This case is optimal

for resolving that issue.

3. The Oppositions discussion of grant,vacate, and remand has no application to

this case or to the Petition.

With all due respect, the Oppositions discussion

of GVR has no application to this case or to the

Petition.

The Courts options are:

Hold the Petition pending resolution ofPerry and/or Windsor;

Grant the Petition and expedite briefingand argument (if there is to be any) so as to

resolve this case this Term;

Grant the Petition and set the case forargument next Term; or

Deny the Petition, in which event this casewill proceed in the Court of Appeals.

The Coalition urges the second option.

Respectfully submitted,

MONTE NEIL STEWARTCounsel of Record

CRAIG G.TAYLORDANIEL W.BOWERBELNAP STEWART TAYLOR &MORRIS PLLC12550 W. Explorer Drive, Suite 100Boise, Idaho 83713(208) 345-3333

[email protected]

February 14, 2013


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APPENDIX I

LANGUAGE OF STATE CONSTITUTIONAL

BANS ON DOMESTIC PARTNERSHIPS AND

OTHER NON-MARITAL UNIONS

Alabama: 2006; A union replicating marriage of or

between persons of the same sex in the state of

Alabama or in any other jurisdiction shall beconsidered and treated in all respects as having no

legal force of effect in this state and shall not be

recognized by this state as a marriage or other union

replicating marriage Ala. Const. amdt. 774.

Arkansas: 2004; Legal status for unmarried

persons which is identical or substantially similar to

marital status shall not be valid or recognized in

Arkansas Ark Const. amend. LXXXII, 1.

Florida: 2008; Inasmuch as marriage is the legalunion of only one man and one woman as husband

and wife, no other legal union that is treated as

marriage or the substantial equivalent thereof shall

be valid or recognized. Fla. Const. art. I, 27.

Georgia: 2004; This state shall not give effect to

any public act, record, or judicial proceeding of any

other state or jurisdiction respecting a relationship

between persons of the same sex that is treated as a

marriage under the laws of such other state orjurisdiction. Ga. Const. art. I, 4 1.


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Idaho: 2006; A marriage between a man and a

woman is the only domestic legal union that shall be

valid or recognized in this state. Idaho Const., Art.

III, sec. 28.

Kansas: 2005; No relationship, other than a

marriage, shall be recognized by the state as

entitling the parties to the rights or incidents of

marriage. Kan. Const. art. XV, 16.

Kentucky: 2004; A legal status identical or

substantially similar to that of marriage for

unmarried individuals shall not be valid or

recognized. Kentucky Const., 233A.

Louisiana: 2004; A legal status identical or



recognized. La. Const. art. XII, 15.

Michigan: 2004; To secure and preserve the

benefits of marriage for our society and for future

generations of children, the union of one man and

one woman in marriage shall be the only agreement

recognized as a marriage or similar union for any

purpose. Mich. Const. art. I, 25.

Nebraska: 2000; The uniting of two persons of the

same sex in a civil union, domestic partnership, or

other similar same-sex relationship shall not bevalid or recognized in Nebraska. Neb. Const. art. I,

29.


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North Dakota: 2004; No other domestic union,

however denominated, may be recognized as a

marriage or given the same or substantially

equivalent legal effect. N.D. Const. art. XI, 28.

Ohio: 2004; This state and its political subdivisionsshall not create or recognize a legal status for

relationships of unmarried individuals that intends

to approximate the design, qualities, significance oreffect of marriage. Ohio Const. art. XV, 11

Oklahoma: 2004; Neither this Constitution nor

any other provision of law shall be construed to

require that marital status or the legal incidents

thereof be conferred upon unmarried couples or

groups. Okla. Const. art. II, 35.

South Carolina: 2006; A marriage between one

man and one woman is the only lawful domestic

union that shall be valid or recognized in this State.This State and its political subdivisions shall not

create a legal status, right or claim respecting any

other domestic union, however denominated. This

State and its political subdivisions shall not

recognize or give effect to a legal status, right or

claim created by another jurisdiction respecting any

other domestic union, however denominated.

Nothing in this section shall impair any right or

benefit extended by the State or its political

subdivisions other than a right or benefit arisingfrom a domestic union that is not valid or recognized

in this State. This section shall not prohibit or limit

parties, other than the State or its political


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subdivisions, from entering into contracts or other

legal instruments. S.C. Const. art. XVII, 15.

South Dakota: 2006; The uniting of two or more

persons in a civil union, domestic partnership, or

other quasi-marital relationship shall not be valid or

recognized. S.D. Const. art. XXI, 9.

Texas: 2005; This state or a political subdivision ofthis state may not create or recognize any legal

status identical or similar to marriage. Texas Const.

Art. I, 32.

Utah: 2004; No other domestic union, however

denominated, may be recognized as a marriage or

given the same or substantially equivalent legal

effect. Utah Const., Art. I, 29.

Virginia: 2006; This Commonwealth and its

political subdivisions shall not create or recognize alegal status for relationships of unmarried

individuals that intends to approximate the design,

qualities, significance, or effects of marriage. Nor

shall this Commonwealth or its political subdivisions

create or recognize another union, partnership, or

other legal status to which is assigned the rights,

benefits, obligations, qualities, or effects of

marriage. Virginia Const., Art. I, 15-A.

Wisconsin: 2006;

Only a marriage between oneman and one woman shall be valid or recognized as a

marriage in this state. A legal status identical or



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recognized in this state. Wisconsin Const., Art. XIII,

13. Cf. Appling v. Doyle, 2012 WL 6633863 (Wisc.

Ct. App., Dec. 20, 2012) (publication decision

pending) (noting that Wisconsins limited domestic

partnership law does not violate Wisconsins

Constitution.).

12-689 coalition's reply brief

Documents