marriage ceremony

Karen Capato married Robert Capato in May 1999. Shortly thereafter, Robert was diagnosed with esophageal cancer and was told that the chemotherapy he required might render him sterile. Because the couple wanted children, Robert deposited his semen in a sperm bank before undergoing chemotherapy. Despite Robert's treatment, Karen conceived naturally and gave birth to a son in August 2001. Robert's health deteriorated in late 2001, and he died in Florida in March 2002. His will, executed in Florida, named as beneficiaries the son born of his marriage to Karen and two children from a previous marriage, but made no provision for children conceived after his death. Shortly after Robert's death, Karen began in vitro fertilization using her husband's frozen sperm. She conceived in January 2003 and gave birth to twins in September 2003, eighteen months after Robert's death. Karen Capato claimed survivors insurance benefits on behalf of the twins. The Social Security Administration denied her application. The U.S. District Court for the District of New Jersey affirmed the agency's decision. The court determined that the twins would qualify for benefits only if they could inherit from the deceased wage earner under Florida intestacy law. Under Florida law, a child born posthumously may inherit only if conceived during the decedent's lifetime. The Court of Appeals for the Third Circuit reversed. It concluded that the undisputed biological children of a deceased wage earner and his widow qualify for survivors benefits without regard to state intestacy law. Courts of Appeals had divided on the question, with some circuits reaching conflicting results. The Supreme Court granted certiorari to resolve the conflict.

Joan Stanley and Peter Stanley lived together intermittently for 18 years, during which time they had three children. When Joan Stanley died, Peter Stanley lost not only her but also his children. Under Illinois law, the children of unwed fathers become wards of the State upon the death of the mother. Accordingly, upon Joan Stanley’s death, in a dependency proceeding instituted by the State of Illinois, Stanley’s children were declared wards of the State and placed with court-appointed guardians. Stanley appealed. He claimed that he had never been shown to be an unfit parent. Since married fathers and unwed mothers could not be deprived of their children without such a showing, he had been deprived of the equal protection of the laws guaranteed him by the Fourteenth Amendment. The Illinois Supreme Court accepted the fact that Stanley’s own unfitness had not been established, but rejected the equal protection claim, holding that Stanley could properly be separated from his children upon proof of the single fact that he and the dead mother had not been married. Stanley’s actual fitness as a father was irrelevant. The decision is reported at In re Stanley, 45 Ill. 2d 132, 256 N. E. 2d 814 (1970). Stanley presses his equal protection claim in the United States Supreme Court. The State responds that unwed fathers are presumed unfit to raise their children. The Supreme Court granted certiorari, 400 U. S. 1020 (1971), to determine whether this method of procedure by presumption could be allowed to stand in light of the fact that Illinois allows married fathers — whether divorced, widowed, or separated — and mothers — even if unwed — the benefit of the presumption that they are fit to raise their children.

The petitioners were fourteen same-sex couples and two men whose same-sex partners were deceased. They lived in Michigan, Kentucky, Ohio, and Tennessee. Those states defined marriage as a union between one man and one woman under their constitutions and statutes. The petitioners filed suits in federal district courts in their home states. They sought marriage licenses or recognition of marriages lawfully performed elsewhere. James Obergefell and John Arthur traveled from Ohio to Maryland to marry aboard a medical transport plane because Arthur suffered from ALS; Obergefell later sought to be listed as surviving spouse on Arthur's death certificate. April DeBoer and Jayne Rowse, Michigan nurses, adopted three children but could not both serve as legal parents under state adoption rules. Army Reserve Sergeant Ijpe DeKoe and Thomas Kostura married in New York before DeKoe's deployment to Afghanistan and later settled in Tennessee. Each district court ruled in the petitioners' favor. The respondents appealed. The Sixth Circuit consolidated the cases and reversed the district court judgments. The petitioners sought certiorari, which the Supreme Court granted. Same-sex couples had begun establishing families after substantial cultural and political developments in the late twentieth century. Earlier litigation had addressed the legal status of gays and lesbians, including challenges that reached the Supreme Court in Bowers v. Hardwick and Lawrence v. Texas.

Respondents, a class of inmates confined or to be confined at the Renz Correctional Institution, brought this action in the United States District Court for the Western District of Missouri against petitioners, officials of the Missouri Division of Corrections. The Renz facility, located in Cedar City, Missouri, housed both male and female prisoners of varying security classifications in a minimum security setting without guard towers or walls. Most female prisoners at Renz were medium or maximum security inmates, while most male prisoners were minimum security offenders. The facility was occasionally used to provide protective custody for inmates from other Missouri prisons. Two regulations were at issue in the litigation. The correspondence regulation permitted inmate-to-inmate letters only with immediate family members at other institutions or concerning legal matters, and otherwise only when the classification team of each inmate deemed it in the best interest of the parties. As applied at Renz, the rule operated as a complete prohibition on correspondence between non-family inmates. The marriage regulation, promulgated while the suit was pending, required the prison superintendent's approval for any inmate marriage and directed that approval be granted only upon a finding of compelling reasons, which officials generally limited to situations involving pregnancy or the birth of an illegitimate child. The District Court certified a class encompassing persons confined or to be confined at Renz who wished to correspond with inmates at other Missouri facilities or to marry inmates of Missouri correctional institutions. Following a bench trial, the District Court concluded that both regulations violated the inmates' constitutional rights. The court applied a strict scrutiny standard derived from prior precedent and determined that the regulations were not the least restrictive means of achieving the state's asserted interests. The District Court also found that the correspondence regulation had been enforced in an arbitrary and capricious manner. The Court of Appeals for the Eighth Circuit affirmed the District Court's judgment in its entirety. The appellate court agreed that strict scrutiny was the proper standard and that neither regulation satisfied that standard. The Supreme Court granted certiorari to consider the validity of the regulations.