Geiger v. Kitzhaber

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Geiger v. Kitzhaber
Seal of the U.S. District Court for the District of Oregon.gif
Court United States District Court for the District of Oregon
Full case nameDeanna L. Geiger and Janine M. Nelson, William Griesar and Robert Duehmig, Plaintiffs
and
Paul Rummell and Benjamin West, Lisa Chickadonz and Christine Tanner, Basic Rights Education Fund, Plaintiffs
v.
John Kitzhaber, in his official capacity as Governor of the State of Oregon, Ellen Rosenblum, in her official capacity as Oregon Attorney General, Jennifer Woodward, in her official capacity as State Registrar, Center of Health Statistics, and Randy Walruff, in his official capacity as Multnomah County Assessor, Defendants
ArguedApril 23, 2014
DecidedMay 19, 2014
Docket nos. 6:13-cv-01834
Citation(s)994 F. Supp. 2d 1128
Case history
Subsequent action(s)U.S. Court of Appeals
(No. 14-35427, 9th Cir.)

May 4, 2014: Appeal by movants National Organization for Marriage denied intervenor status lodged.

Contents

May 19, 2014: Emergency motion for stay of injunction by proposed intervenors denied.

Aug. 27, 2014: Appeal ordered dismissed. (Order)

Nov. 24, 2014: Request for initial en banc hearing denied.

Dec. 3, 2014: Mandate to dismiss case issued.

U.S. Supreme Court
(No. 13A1173)

May 27, 2014: Application for stay lodged sub nom. National Organization for Marriage, Inc. v. Geiger.

Jun. 4, 2014: Stay denied, 2014 WL 2514491. (Order)
Holding
Plaintiffs' motion for summary judgment granted. Oregon's marriage laws that exclude "same-gender" gay and lesbian couples violate equal protection
Court membership
Judge sitting Michael J. McShane
Keywords
Same-sex marriage, equal protection, due process, marriage equality, discrimination

Geiger v. Kitzhaber is a decision by the U.S. District Court for the District of Oregon that requires Oregon to allow same-sex couples to marry and to recognize same-sex marriages established in other jurisdictions. The decision arose from two consolidated cases that alleged that Oregon's constitutional ban on same-sex marriage, Article 15, § 5, and all related marriage statutes, violate the Due Process Clause and the Equal Protection Clause of the 14th Amendment to the United States Constitution. Among the several defendants, Attorney General Ellen Rosenblum filed appearances in the case to defend Oregon's position, but declined to defend the constitutionality of the bans and ordered state agencies to recognize the validity of same-sex marriages established elsewhere.

U.S. District Judge Michael J. McShane ruled on May 19, 2014, that Oregon's constitution and statutes restricting marriage rights for same-sex couples violate the U.S. Constitution and ordered an immediate end to their enforcement.

The National Organization for Marriage, an organization opposed to same-sex marriage, tried without success to intervene in the suit, to stay enforcement of the district court decision, and to appeal that decision.

Filing

Deanna Geiger and Janine Nelson, lead plaintiffs in Geiger v. Kitzhaber Deanna Geiger and Janine Nelson Geiger v. Kitzhaber.jpg
Deanna Geiger and Janine Nelson, lead plaintiffs in Geiger v. Kitzhaber

Geiger v. Kitzhaber was filed on October 15, 2013, by Deanna Geiger and Janine Nelson, a lesbian couple wanting to marry in Oregon, and by William Griesar and Robert Duehmig, a gay male couple together for 25 years who had married in Canada. The case was filed in the United States District Court of Oregon. The case claims that Oregon's constitutional ban on same gender marriage, Article 15, § 5, and all Oregon marriage statutes referring to husband and wife that government officials interpreted in a way that excluded full and equal marriage rights for gay and lesbian couples, violate the Due Process Clause and the Equal Protection Clause of the 14th Amendment to the United States Constitution. [1] The couples named as defendants Governor John Kitzhaber, Attorney General Ellen Rosenblum, Jennifer Woodward, State Registrar, and Randy Walruff, Multnomah County Assessor.

Recognition of out-of-state marriages

The next day, October 16, the state's Chief Operating Officer Michael Jordan directed state agencies to "recognize all out-of-state marriages for the purposes of administering state programs. That includes legal, same-sex marriages performed in other states and countries." [2] He cited an opinion by the Oregon Department of Justice dated the same day. According to that opinion, Jordan had inquired whether, in the light of the U.S. Supreme Court decision in United States v. Windsor and the fact that California and Washington were recognizing same-sex marriages, Oregon could recognize same-sex marriages established in other jurisdictions. Deputy Attorney General Mary H. Williams, writing on behalf of the Department of Justice, replied to his inquiry saying: "We cannot identify any legitimate (much less compelling) state interest in requiring that each marriage recognized in Oregon contain one partner of each sex. We conclude that state agencies can recognize these marriages as valid. To do otherwise would likely violate the federal constitution." [3] [4]

Consolidation

The case was assigned to U.S. District Judge Michael J. McShane. Two months after Geiger was filed, two additional couples and the Basic Rights Education Fund filed another lawsuit, Rummell v. Kitzhaber, again alleging that Oregon's ban on same-sex marriages was unconstitutional. [5] The Rummell plaintiffs asked the court to consolidate their case with the Geiger case. The Geiger plaintiffs objected to the consolidation because it would cause a delay in the ruling. [6] On January 22, 2014, Judge McShane consolidated the two cases. The plaintiffs in both Geiger and Rummell filed motions asking for summary judgment, since no facts were in dispute. [7]

Attorney General's response

On February 20, 2014, Attorney General Ellen Rosenblum filed an answer to the Rummell plaintiffs' complaint in which she conceded that Oregon's laws excluding same-sex couples from marriage were unconstitutional. She told the court that she believed "that performing same-sex marriages in Oregon would have no adverse effect on existing marriages, and that sexual orientation does not determine an individual's capacity to establish a loving and enduring relationship." She found it impossible to defend the state's "under any standard of review" and her office would no longer defend the ban in court. Speaking publicly, she announced that the "Oregon Department of Justice will not defend the prohibition in our state's constitution against marriages between people of the same sex." [8] [9] [10]

Oral arguments

On April 23, 2014, Judge Michael McShane heard oral arguments [11] on the motions for summary judgment in the consolidated lawsuit. While all parties present supported same-sex marriage, Judge McShane questioned whether there was a role for Oregon voters who had approved the amendment defining marriage in 2004 and considered whether to implement his ruling immediately or stay his ruling and await guidance from related cases pending in the U.S. courts of appeal. The court scheduled another session of oral arguments for May 14, where the National Organization for Marriage ("NOM"), an organization that opposes same-sex marriage, tried without success to qualify for intervention in the case. McShane ruled that the group was unreasonably late in filing its request to intervene and that it failed to convincingly demonstrate that it should be allowed to intervene on behalf of three anonymous Oregon-based members of NOM. [12] [13]

Ruling

The court granted the plaintiffs' motion for summary judgment on May 19, resulting in the immediate legalization of same-sex marriage in Oregon. [14]

Judge McShane departed from the common descriptor of "same-sex" throughout his opinion, [15] using instead the terms same-gender marriage and same-gender couples. [16] His opinion included several paragraphs designed for the public:

I am aware that a large number of Oregonians, perhaps even a majority, have religious or moral objections to expanding the definition of civil marriage (and thereby expanding the benefits and rights that accompany marriage) to gay and lesbian families. It was these same objections that led to the passage of Measure 36 in 2004. Generations of Americans, my own included, were raised in a world in which homosexuality was believed to be a moral perversion, a mental disorder, or a mortal sin...On a darker level, that same worldview led to an environment of cruelty, violence, and self-loathing. It was but 1986 when the United States Supreme Court justified, on the basis of a "millennia of moral teaching," the imprisonment of gay men and lesbian women who engaged in consensual sexual acts. ...

It is not surprising then that many of us raised with such a world view would wish to protect our beliefs and our families by turning to the ballot box to enshrine in law those traditions we have come to value. But just as the Constitution protects the expression of these moral viewpoints, it equally protects the minority from being diminished by them. ...

I believe that if we can look for a moment past gender and sexuality, we can see in these plaintiffs nothing more or less than our own families. Families who we would expect our Constitution to protect, if not exalt, in equal measure. With discernment we see not shadows lurking in closets or the stereotypes of what was once believed; rather, we see families committed to the common purpose of love, devotion, and service to the greater community.

Where will this all lead? I know that many suggest we are going down a slippery slope that will have no moral boundaries. To those who truly harbor such fears, I can only say this: Let us look less to the sky to see what might fall; rather, let us look to each other ... and rise.

Minutes after the decision was announced at noon, officials in at least four counties were fulfilling requests for marriage licenses from same-sex couples. Multnomah County issued 96 licenses the first day, and judges officiated at wedding ceremonies at six altars set up in a Portland ballroom. [17] [18] [19] Deanna Geiger and Janine Nelson were the first to marry after Judge McShane's ruling. [20]

Appeals

On May 4, 2014, while the Geiger case was still pending in district court, the National Organization for Marriage (NOM) filed an appeal of the district court's denial of intervenor status in the U.S. Court of Appeals for the Ninth Circuit. Once Judge McShane released his May 19, 2014, order, NOM immediately sought a stay of that order from the Ninth Circuit, which denied that emergency motion that same day. [21] The state defendants, including Governor Kitzhaber, joined by the plaintiffs, moved the next day to dismiss NOM's appeal as moot. They argued that Judge McShane was correct in denying NOM intervenor status, and that therefore NOM lacked standing and its appeal was moot. On August 27, a three-judge panel of the Court of Appeals, consisting of U.S. Circuit Judges Schroeder, Thomas, and N.R. Smith, agreed and granted the motion dismissing the appeal. [22] [23]

On May 27, 2014, NOM filed an application for an emergency stay with Justice Anthony Kennedy, the Circuit Justice for the Ninth Circuit. [24] On June 4, Justice Kennedy referred the application to the full U.S. Supreme Court, which rejected the request for a stay without comment or recorded dissent on June 4. [25]

On November 24, 2014, the Ninth Circuit denied NOM's request for an initial hearing en banc. On December 3, 2014, the Ninth Circuit issued the mandate finalizing its August 27 decision to dismiss NOM's appeal. [26] [27]

On April 20, 2015, the U.S. Supreme Court denied another NOM petition for review. [28]

Attorneys

Lake Perriguey of Law Works LLC began working on the case in July 2013. [29] He and Lea Ann Easton of Dorsay & Easton LLP [30] filed Geiger in October 2013. [31]

Tom Johnson [32] and Misha Isaak of Perkins Coie LLP, [33] and Jennifer Middleton of Johnson Johnson & Schaller PC, [34] together with ACLU staff attorneys Kevin Diaz, Amanda Goad, and Rose Saxe, filed Rummell in December 2013 on behalf of Basic Rights Education Fund and two other plaintiff couples. [35] In addition to litigating a challenge to Oregon's marriage laws on behalf of their clients, the Rummell attorneys represented the plaintiffs in both consolidated cases in opposing the National Organization for Marriage's motion to intervene [36] and motions to stay at the Ninth Circuit Court of Appeals and U.S. Supreme Court. [37]

The Oregon Attorney General's office represented Governor Kitzhaber and the state registrar. The lawyers were Sheila Potter, Anna Joyce, and Mary Williams. The Office of Multnomah County Attorney represented the Multnomah County defendant. The lawyers were Jenny Morf Madkour and Kate von Ter Stegge.

See also

Related Research Articles

Same-sex marriage in Oregon has been legally recognized since May 19, 2014, when Judge Michael J. McShane of the U.S. District Court for the District Court of Oregon ruled in Geiger v. Kitzhaber that Oregon's 2004 state constitutional amendment banning same-sex marriages discriminated on the basis of sexual orientation in violation of the Equal Protection Clause of the U.S. Constitution. A campaign that was then under way to win voter approval of a constitutional amendment legalizing same-sex marriage was suspended following the decision. In July 2015, Governor Kate Brown signed legislation codifying same-sex marriage in various Oregon statutes. The law change went into effect on January 1, 2016.

Same-sex marriage in Florida has been legal since January 6, 2015, as a result of a ruling in Brenner v. Scott from the U.S. District Court for the Northern District of Florida. The court ruled the state's same-sex marriage ban unconstitutional on August 21, 2014. The order was stayed temporarily. State attempts at extending the stay failed, with the U.S. Supreme Court denying further extension on December 19, 2014. In addition, a state court ruling in Pareto v. Ruvin allowed same-sex couples to obtain marriage licenses in Miami-Dade County on the afternoon of January 5, 2015. In another state case challenging the state's denial of marriage rights to same-sex couples, a Monroe County court in Huntsman v. Heavilin stayed enforcement of its decision pending appeal and the stay expired on January 6, 2015.

Same-sex marriage in Colorado has been legally recognized since October 7, 2014. Colorado's state constitutional ban on same-sex marriage was struck down in state district court on July 9, 2014, and by the U.S. District Court for the District of Colorado on July 23, 2014. The Tenth Circuit Court of Appeals had already made similar rulings with respect to such bans in Utah on June 25 and Oklahoma on July 18, which are binding precedents on courts in Colorado. On October 6, 2014, the U.S. Supreme Court declined to hear the Tenth Circuit cases, and the Tenth Circuit lifted its stay. On October 7, 2014, the Colorado Supreme Court and the Tenth Circuit cleared the way for same-sex marriages to begin in Colorado.

Same-sex marriage in Arizona has been legal since October 17, 2014. The U.S. state had denied marriage rights to same-sex couples by statute since 1996 and by an amendment to its State Constitution approved by voters in 2008. On October 17, Judge John W. Sedwick ruled in two lawsuits that Arizona's ban on same-sex marriage was unconstitutional, and enjoined the state from enforcing its ban, effective immediately. Attorney General Tom Horne said the state would not appeal that ruling, and instructed county clerks to comply and issue marriage licenses to same-sex couples.

<span class="mw-page-title-main">American Foundation for Equal Rights</span> American nonprofit organization

The American Foundation for Equal Rights (AFER) was a nonprofit organization active in the United States from 2009 through 2015. The organization was established to support the plaintiffs in Hollingsworth v. Perry, a federal lawsuit challenging California's Proposition 8 under the Due Process and Equal Protection Clauses of the Fourteenth Amendment to the United States Constitution. AFER retained former United States Solicitor General Theodore B. Olson and David Boies to lead the legal team representing the plaintiffs challenging Proposition 8.

Hollingsworth v. Perry was a series of United States federal court cases that re-legalized same-sex marriage in the state of California. The case began in 2009 in the U.S. District Court for the Northern District of California, which found that banning same-sex marriage violates equal protection under the law. This decision overturned California ballot initiative Proposition 8, which had banned same-sex marriage. After the State of California refused to defend Proposition 8, the official sponsors of Proposition 8 intervened and appealed to the Supreme Court. The case was litigated during the governorships of both Arnold Schwarzenegger and Jerry Brown, and was thus known as Perry v. Schwarzenegger and Perry v. Brown, respectively. As Hollingsworth v. Perry, it eventually reached the United States Supreme Court, which held that, in line with prior precedent, the official sponsors of a ballot initiative measure did not have Article III standing to appeal an adverse federal court ruling when the state refused to do so.

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Sevcik v. Sandoval is the lead case that successfully challenged Nevada's denial of same-sex marriage as mandated by that state's constitution and statutory law. The plaintiffs' complaint was initially filed in the U.S. District Court for the District of Nevada on April 10, 2012, on behalf of several couples denied marriage licenses. These couples challenged the denial on the basis of the U.S. Constitution's Fourteenth Amendment guarantee of equal protection.

<span class="mw-page-title-main">Michael J. McShane</span> American judge

Michael J. McShane is an American lawyer and jurist serving as a United States district judge of the United States District Court for the District of Oregon. He previously served as a state court judge on the Oregon Multnomah County Circuit Court from 2001 to 2013.

<i>Kitchen v. Herbert</i> American legal case

Kitchen v. Herbert, 961 F.Supp.2d 1181, affirmed, 755 F.3d 1193 ; stay granted, 134 S.Ct. 893 (2014); petition for certiorari denied, No. 14-124, 2014 WL 3841263, is the federal case that successfully challenged Utah's constitutional ban on marriage for same-sex couples and similar statutes. Three same-sex couples filed suit in March 2013, naming as defendants Utah Governor Gary R. Herbert, Attorney General John Swallow, and Salt Lake County Clerk Sherrie Swensen in their official capacities.

This is a list of notable events in the history of LGBT rights that took place in the year 2014.

The lead cases on same-sex marriage in Kentucky are Bourke v. Beshear, and its companion case Love v. Beshear. In Bourke, a U.S. district court found that the Equal Protection Clause requires Kentucky to recognize valid same-sex marriages from other jurisdictions. In Love, the same court found that this same clause renders Kentucky's ban on same-sex marriage unconstitutional. Both decisions were stayed and consolidated upon appeal to the Sixth Circuit Court of Appeals, which heard oral arguments in both cases on August 6, 2014. On November 6, the Sixth Circuit upheld Kentucky's ban on same-sex marriage.

Same-sex marriage in Kentucky has been legal since the U.S. Supreme Court's ruling in Obergefell v. Hodges on June 26, 2015. The decision, which struck down Kentucky's statutory and constitutional bans on same-sex marriages, was handed down on June 26, 2015, and Governor Steve Beshear and Attorney General Jack Conway announced almost immediately that the court's order would be implemented.

Same-sex marriage in Missouri has been legal since the U.S. Supreme Court's landmark ruling in Obergefell v. Hodges, which struck down state bans on marriages between two people of the same sex on June 26, 2015. Prior to the court ruling, the state recognized same-sex marriages from other jurisdictions pursuant to a state court ruling in October 2014, and certain jurisdictions of the state performed same-sex marriage despite a statewide ban.

<i>Whitewood v. Wolf</i>

Whitewood v. Wolf is the federal lawsuit that successfully challenged the Pennsylvania Marriage Laws, as amended in 1996 to ban same-sex marriage. The district court's decision in May 2014 held that the Marriage Laws violated the Due Process and Equal Protection clauses of the United States Constitution. Same-sex couples immediately sought and received marriage licenses and the decision was not appealed. One county clerk sought repeatedly without success to intervene to defend the law.

<i>De Leon v. Perry</i>

De Leon v. Perry was a federal lawsuit challenging Texas marriage law, specifically the state's constitutional ban on same-sex marriage and corresponding statutes. A U.S. district court ruled in favor of the plaintiff same-sex couples on February 26, 2014, granting their motion for a preliminary injunction. The state defendants filed an interlocutory appeal before the United States Court of Appeals for the Fifth Circuit, as the disposition on the motion was not a final ruling in the case. On April 14, 2014, the plaintiffs filed a motion for an expedited hearing, which was denied on May 21, 2014. The plaintiffs filed another motion for an expedited hearing on October 6, 2014, after the Supreme Court of the United States denied appeals in other marriage equality cases, and the motion was granted on October 7, 2014, setting a hearing for November 2014. However, on October 27, 2014, the Fifth Circuit set oral arguments for January 9, 2015.

<i>Latta v. Otter</i>

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<i>Baskin v. Bogan</i>

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<i>Bostic v. Schaefer</i> United States federal lawsuit challenging range same-sex marriage bans

Bostic v. Schaefer is a lawsuit filed in federal court in July 2013 that challenged Virginia's refusal to sanction same-sex marriages. The plaintiffs won in U.S. district court in February 2014, and the Fourth Circuit Court of Appeals upheld that ruling in July 2014. On August 20, 2014, the U.S. Supreme Court stayed enforcement of the Fourth Circuit's ruling pending the outcome of further litigation. State officials refused to defend the state's constitutional and statutory bans on same-sex marriage.

In Brenner v. Scott and its companion case, Grimsley v. Scott, a U.S. district court found Florida's constitutional and statutory same-sex marriage bans unconstitutional. On August 21, 2014, the court issued a preliminary injunction that prevents that state from enforcing its bans and then stayed its injunction until stays are lifted in the three same-sex marriage cases then petitioning for a writ of certiorari in the U.S. Supreme Court–Bostic, Bishop, and Kitchen–and for 91 days thereafter. When the district court's preliminary injunction took effect on January 6, 2015, enforcement of Florida's bans on same-sex marriage ended.

References

  1. ↑ "Gay Couples File Federal Suit To Overturn Oregon Ban on Same-Sex Marriage". Wweek.com. October 15, 2013. Retrieved March 27, 2014.
  2. ↑ Damewood, Andrea (October 16, 2013). "Oregon To Recognize Marriages of Gay Couples Wed Out of State". Willamette Week. Archived from the original on February 24, 2014. Retrieved February 13, 2014.
  3. ↑ "Oregon Department of Justice: Letter" (PDF). Oregon Live. Retrieved August 30, 2014. If an Oregon court construed our constitution so as to prohibit recognition of out-of-state marriages, we believe the court [i.e., U.S. Supreme Court] would find that provision violates the federal constitution's equal protection principles.
  4. ↑ Esteve, Harry (October 17, 2013). "Oregon government agencies must recognize same-sex marriages from other states, DOJ says". OregonLive.com. Retrieved August 20, 2014.
  5. ↑ "Two more couples file suit against Oregon's ban on gay marriage". OregonLive.com. December 20, 2013. Retrieved March 27, 2014.
  6. ↑ Dubois, Steven (January 22, 2014). "Judge consolidates Oregon gay-marriage lawsuits". News.yahoo.com. Retrieved March 27, 2014.
  7. ↑ "Ruling on gay marriage in Oregon could come by summer after federal judge consolidates two cases". OregonLive.com. January 23, 2014. Retrieved March 27, 2014.
  8. ↑ Johnson, Chris (February 20, 2014). "Oregon AG won't defend marriage ban in court". Washington Blade. Retrieved February 20, 2014.
  9. ↑ "Statement of Oregon Attorney General Ellen Rosenblum on the subject of pending litigation challenging same-sex marriage ban" (Press release). Oregon Attorney General. February 20, 2014. Retrieved May 2, 2014.
  10. ↑ Harry Esteve/The Oregonian (February 20, 2014). "Gay marriage advocates have big day as Oregon AG Ellen Rosenblum says 'no rational basis' for ban". OregonLive.com. Retrieved March 27, 2014.
  11. ↑ Oral arguments
  12. ↑ Mapes, Jeff (April 23, 2014). "Gay marriage: Judge Michael McShane provides little clue in how he will rule on Oregon case". The Oregonian. Retrieved April 23, 2014.
  13. ↑ Mapes, Jeff (April 22, 2014). "Judge won't rule in Oregon gay marriage case until at least May 14 while he decides on intervenor". The Oregonian. Retrieved April 23, 2014.
  14. ↑ Marshall, Cathy (May 20, 2014). "Gay couples immediately occurring after ruling". Kgw.com. Archived from the original on May 30, 2014. Retrieved June 29, 2014.
  15. ↑ opinion
  16. ↑ "Geiger v. Kitzhaber Final Opinion Decision Oregon Gay Marriage". Scribd.com. Retrieved June 29, 2014.
  17. ↑ Mears, Bill (May 19, 2014). "Federal judge strikes down Oregon's same-sex marriage ban". CNN News. Retrieved August 28, 2014.
  18. ↑ Carson, Teresa (May 19, 2014). "Same-sex couples wed in Oregon after gay marriage ban lifted". Reuters. Retrieved August 28, 2014.
  19. ↑ Chokshi, Niraj (May 20, 2014). "Gallery: Gay couples wed after Oregon marriage ban struck down". Washington Post. Retrieved August 28, 2014.
  20. ↑ House, Kelly (May 19, 2014). "Gay marriage in Oregon: First couple exchanges vows in Multnomah County building". The Oregonian. Retrieved January 17, 2015.
  21. ↑ Mapes, Jeff (May 19, 2014). "Ninth Circuit strikes down National Organization's request to halt judge's decision".
  22. ↑ NOM v. Geiger v. Kitzhaber - 9th Cir. Order Granting State's Motion to Dismiss NOM's Appeal
  23. ↑ "Federal appeals court dismisses anti-gay marriage group's bid to halt Oregon same-sex marriages". The Oregonian. Retrieved August 27, 2014.
  24. ↑ Mapes, Jeff (May 19, 2014). "Gay marriage now appears set in Oregon, but future legal clouds could appear".
  25. ↑ "Supreme Court declines request to halt gay marriages in Oregon". Washington Post. Retrieved June 4, 2014.
  26. ↑ Geidner, Chris (November 24, 2014). "NOM Loses, Again, In Appeal Trying To Intervene In Oregon's Marriage Case". BuzzFeed News. Retrieved November 24, 2014.
  27. ↑ "Mandate, Geiger v. Kitzhaber, No. 14-35427". Scribd.com. U.S. Court of Appeals for the Ninth Circuit. December 3, 2014.
  28. ↑ Ring, Trudy (April 21, 2015). "High Court Ends NOM's Efforts to Undo Oregon Marriage". Advocate.com. Retrieved April 23, 2015.
  29. ↑ Acena, TJ (June 11, 2014). "He treated marriage like pancakes–the government is doling out Pancakes and not doing it in an equal way". PQ Monthly. Archived from the original on July 17, 2014. Retrieved September 7, 2014.
  30. ↑ Dorsay & Easton LLP
  31. ↑ "Marriage Duel: The Competing Approaches To Legalizing Gay Marriage in Oregon". Willamette Week. Wweek.com. October 23, 2013. Retrieved March 27, 2014.
  32. ↑ Thomas Johnson
  33. ↑ "Misha Isaak". Archived from the original on August 13, 2014. Retrieved August 11, 2014.
  34. ↑ Jennifer Middleton
  35. ↑ University of Michigan Law SchOOL: Case Profile: Geiger v. Kitzhaber
  36. ↑ Transcript - Geiger v. Kitzhaber, May 14, 2014
  37. ↑ "No. 13A1173: NOM v. Geiger". Supreme Court of the United States. Retrieved August 28, 2014.
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