Hollingsworth v. Perry
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| Hollingsworth v. Perry | |
|---|---|
| Name | Hollingsworth v. Perry |
| Court | Supreme Court of the United States |
| Citation | 570 U.S. 693 (2013) |
| Decided | June 26, 2013 |
| Docket | No. 12-144 |
| Prior | Perry v. Schwarzenegger, 704 F. Supp. 2d 921 (N.D. Cal. 2010); Perry v. Brown, 671 F.3d 1052 (9th Cir. 2012) |
| Holding | Petitioners lacked standing; lower court rulings vacated as moot |
| Majority | Scalia (per curiam) |
| Joinmajority | Roberts, Kennedy, Thomas, Alito |
| Concurrence | Kennedy (opinion respecting the judgment) |
| Dissent | Ginsburg |
Hollingsworth v. Perry
Hollingsworth v. Perry was a 2013 Supreme Court case that decided procedural standing issues in litigation challenging California's Proposition 8, a 2008 ballot measure that amended the California Constitution to limit marriage to opposite-sex couples. The decision left intact a district court ruling that found Proposition 8 unconstitutional but held that the named petitioners lacked Article III standing to appeal, thereby allowing same-sex marriages to resume in California while avoiding a national constitutional ruling on same-sex marriage. The case intersected with litigation involving prominent actors including Proposition 8, Perry v. Schwarzenegger, Pope v. United States, and organizations like ProtectMarriage.com and Campaign for California Families.
Background
Proposition 8 emerged from California's 2008 electoral campaign, where supporters such as Proposition 8 backers and groups like ProtectMarriage.com mounted a ballot initiative effort that amended the California Constitution. Opposition included plaintiffs represented by attorneys from organizations such as the American Civil Liberties Union and the ACLU of Northern California, along with advocacy groups like Equality California and litigants associated with Perry v. Schwarzenegger. Key public figures and institutions—Governor Arnold Schwarzenegger, Attorney General Jerry Brown, and the California Supreme Court in earlier contexts—figured in the political and legal landscape surrounding marriage equality, alongside national actors such as Human Rights Campaign, Lambda Legal, National Center for Lesbian Rights, and civil rights litigators tied to Wiley Rein and other law firms.
District Court proceedings (Perry v. Schwarzenegger)
The district court case was brought in the United States District Court for the Northern District of California by same-sex couples challenging Proposition 8, with the action styled as Perry v. Schwarzenegger. Plaintiffs were represented by attorneys from the ACLU, Lambda Legal, and private counsel including David Boies and Ted Olson, while defendants nominally included state officials like Governor Arnold Schwarzenegger and Attorney General Jerry Brown. After the Great Recession-era political fallout and judicial appointments shifting the federal bench composition, Judge Vaughn R. Walker presided and oversaw extensive trial proceedings, including testimony from witnesses linked to organizations such as ProtectMarriage.com and experts affiliated with universities such as Stanford University and University of California, Berkeley. In 2010 Walker issued a detailed decision finding that Proposition 8 violated the Due Process Clause and the Equal Protection Clause of the Fourteenth Amendment, concluding that sexual orientation classifications required careful scrutiny under precedents like Loving v. Virginia and Romer v. Evans and referencing analytical frameworks from cases such as United States v. Windsor and Lawrence v. Texas.
Ninth Circuit decision
After Judge Walker's ruling, the case proceeded on appeal to the United States Court of Appeals for the Ninth Circuit. The Ninth Circuit panel, considering briefs from parties including ProtectMarriage.com proponents and intervenors such as Campaign for California Families, affirmed the district court's judgment on constitutional grounds in an opinion authored by judges with connections to decisions involving Proposition 8-era litigation. The appellate decision engaged with precedents including Baker v. Nelson and appellate jurisprudence from circuits like the United States Court of Appeals for the Second Circuit and United States Court of Appeals for the Fourth Circuit. The Ninth Circuit's opinion set the stage for a Supreme Court review by contrasting conflicts among circuit decisions on same-sex marriage and equality claims advanced by litigants like Perry v. Schwarzenegger plaintiffs and organizational amici such as Human Rights Campaign and National Center for Lesbian Rights.
Supreme Court review and ruling
Petitions for certiorari were filed by proponents of Proposition 8, represented by counsel associated with organizations like Campaign for California Families and attorneys who had advised ballot measure committees. The Supreme Court granted review limited to the question of standing, consolidating the case under the caption in which proponents such as Dennis Hollingsworth and affiliated petitioners appeared. The Court's per curiam opinion, joined by Justices Antonin Scalia, John Roberts, Anthony Kennedy, Clarence Thomas, and Samuel Alito, held that the petitioners lacked Article III standing to appeal because state officials had declined to defend Proposition 8 and proponents did not have a recognized personal stake. Justice Kennedy filed an opinion respecting the judgment, while Justice Ruth Bader Ginsburg dissented, joined by Justices Sonia Sotomayor and Elena Kagan.
Legal issues and rationale
The Court's analysis focused on Article III standing doctrine, exploring precedents such as Lujan v. Defenders of Wildlife, Clapper v. Amnesty International U.S.A., and structural principles reflected in cases like Massachusetts v. Mellon and United States v. Windsor. The majority evaluated whether private proponents of a state-enacted ballot measure could invoke state-law authority to defend the statute after state officials declined to do so, and whether that conferred a concrete and particularized injury sufficient for federal jurisdiction. The opinion examined state-law roles in cases involving officials like Attorney Generals and governors, referencing state practices in jurisdictions including California and considering implications from decisions such as Arizonans for Official English v. Arizona and Raines v. Byrd. The Court concluded that the proponents lacked a judicially cognizable interest in the enforcement of Proposition 8 and therefore could not satisfy Article III, vacating and remanding the Ninth Circuit judgment as moot.
Impact and aftermath
The immediate practical effect of the decision was to allow same-sex marriages to resume in California by virtue of the district court judgment remaining in effect. The case catalyzed further litigation and political developments that culminated in the nationwide recognition of same-sex marriage in Obergefell v. Hodges, where the Supreme Court addressed marriage equality on the merits. Legal scholars and organizations such as Human Rights Campaign, Lambda Legal, National Center for Lesbian Rights, American Civil Liberties Union, and law faculties at institutions like Harvard Law School and Yale Law School debated the standing doctrine and democratic implications, citing works from legal theorists connected to Columbia Law School and decisions from the United States Court of Appeals for the Ninth Circuit. The ruling influenced subsequent strategic use of ballot initiatives in states including Oregon, Washington, New York, Massachusetts, and legislative and judicial initiatives involving LGBTQ rights, informing advocacy by groups such as Freedom to Marry and prompting scholarly commentary in journals associated with Stanford Law School and University of Chicago Law School.