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Varnum v. Brien

Supreme Court of Iowa
763 N.W.2d 862 (2009)
ELI5:

Rule of Law:

A state statute limiting civil marriage to a union between a man and a woman violates the equal protection clause of the Iowa Constitution because the classification based on sexual orientation does not substantially further any important governmental objective.


Facts:

  • Twelve individuals, comprising six same-sex couples, lived in committed relationships across Iowa.
  • The plaintiffs included professionals such as a nurse, a teacher, a social worker, and a business manager; some were raising children or were foster parents.
  • In 1998, the Iowa legislature amended the state's marriage statute to define marriage exclusively as a union between a man and a woman.
  • The six same-sex couples applied for marriage licenses from the Polk County Recorder.
  • The recorder, citing the state statute, refused to issue the marriage licenses to the couples.
  • Aside from the gender-based restriction in the statute, the plaintiffs met all other legal requirements to marry in Iowa.
  • As unmarried couples, the plaintiffs were denied numerous legal and financial protections, including rights related to healthcare decisions, insurance, pension benefits, taxes, and adoption.

Procedural Posture:

  • Twelve plaintiffs, comprising six same-sex couples, filed a lawsuit against the Polk County Recorder in the Polk County District Court, a state trial court.
  • The plaintiffs claimed the statutory ban on same-sex marriage violated the liberty and equal protection clauses of the Iowa Constitution.
  • The case was decided on motions for summary judgment.
  • The district court granted summary judgment for the plaintiffs, finding the statute unconstitutional under both the due process and equal protection clauses.
  • The district court initially ordered the county recorder to begin issuing licenses but then stayed its order pending an appeal.
  • The Polk County Recorder (as defendant-appellant) appealed the district court's decision to the Iowa Supreme Court, the state's highest court.

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Issue:

Does Iowa Code section 595.2, which defines marriage as a union only between a man and a woman, violate the equal protection clause of the Iowa Constitution?


Opinions:

Majority - Cady, Justice

Yes, Iowa's statute limiting civil marriage to a man and a woman violates the equal protection clause of the Iowa Constitution. The court determined that classifications based on sexual orientation are subject to a heightened level of judicial scrutiny. To decide this, the court applied a four-factor framework, considering: (1) the history of invidious discrimination against gay and lesbian people; (2) that sexual orientation is not related to a person's ability to contribute to society; (3) that sexual orientation is an immutable or deeply central aspect of identity; and (4) the relative political powerlessness of the group. Concluding that heightened scrutiny was required, the court applied intermediate scrutiny, which requires a law to be substantially related to an important governmental objective. The court then analyzed and rejected the state's proffered justifications for the law, including maintaining tradition, promoting an optimal environment for child-rearing, encouraging procreation, and conserving state resources. The court found that excluding same-sex couples from civil marriage did not substantially further any of these objectives and was therefore unconstitutional.



Analysis:

This unanimous decision was a landmark case in the history of marriage equality, making Iowa the third state to legalize same-sex marriage through a judicial ruling. It established sexual orientation as a quasi-suspect classification under the Iowa Constitution, requiring any law discriminating on this basis to survive a demanding intermediate scrutiny test. The case solidified Iowa's historical reputation as a judicial leader in civil rights and set a powerful precedent for other state courts by providing a detailed framework for analyzing such claims under state equal protection clauses, years before the U.S. Supreme Court's ruling in Obergefell v. Hodges.

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