University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Robicheaux v. Caldwell PB-LA-0002
Docket / Court 2:13-cv-05090-MLCF-ALC ( E.D. La. )
State/Territory Louisiana
Case Type(s) Public Benefits / Government Services
Special Collection Same-Sex Marriage
Case Summary
On July 16, 2013, a resident of Louisiana, who had legally married a spouse of the same sex under the laws of Iowa, filed a lawsuit in the U.S. District Court for the Eastern District of Louisiana under 42 U.S.C. § 1983 against the State of Louisiana. The plaintiff, represented by private counsel, ... read more >
On July 16, 2013, a resident of Louisiana, who had legally married a spouse of the same sex under the laws of Iowa, filed a lawsuit in the U.S. District Court for the Eastern District of Louisiana under 42 U.S.C. § 1983 against the State of Louisiana. The plaintiff, represented by private counsel, asked the court for declaratory and injunctive relief, claiming that Louisiana laws denying recognition of valid, out-of-state marriages were unconstitutional. Specifically, the plaintiff alleged that Section 15 of the Louisiana Constitution and Louisiana Civil Code article 3520 violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment of the United States Constitution and that non-recognition of legal marriages violated the Full Faith and Credit Clause of the United States Constitution.

The plaintiff filed an amended complaint on August 9, 2013, which fleshed out the details of his argument. On September 26, 2013, the defendant filed a motion to dismiss the case for improper venue and to transfer the case to the Middle District of Louisiana. On October 16, 2013, the Court (Judge Martin L. C. Feldman) ordered counsel for both sides to submit supplementary papers to the court by October 30, 2013, addressing whether the venue is appropriate.

Judge Martin L. C. Feldman rendered judgment on September 3, 2014, granting the defendants' motion for summary judgment. The opinion explained that the Court found Louisiana's decision to neither permit nor recognize same-sex marriage to be supported by a rational basis, because the state has an interest in defining the meaning of marriage though the democratic process. This was the first federal court opinion to uphold a same-sex marriage ban following the Supreme Court's decision in Windsor; several dozen other opinions had come out the other way. On September 5, 2014, the plaintiffs filed a notice of appeal.

Carlyn Williams - 11/04/2013
Megan Dolan - 09/10/2014


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Issues and Causes of Action
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Issues
Affected Gender
Female
Male
Constitutional Clause
Due Process
Equal Protection
Full faith and credit
Defendant-type
Jurisdiction-wide
Discrimination-basis
Sex discrimination
Sexual orientatation
General
Gay/lesbian/transgender
Marriage
Public benefits (includes, e.g., in-state tuition, govt. jobs)
Plaintiff Type
Private Plaintiff
Causes of Action Declaratory Judgment Act, 28 U.S.C. § 2201
42 U.S.C. § 1983
Defendant(s) State of Louisiana
Plaintiff Description Individual plaintiffs desire to have their same-sex marriage, celebrated in Iowa, recognized in Louisiana.
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year n/a
Case Ongoing Yes
Case Listing PB-LA-0005 : Forum for Equality Louisiana v. Barfield (E.D. La.)
Additional Resources
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Case Studies Limited Partnership
http://www.limitedpartnershipmovie.com/
By: Thomas G. Miller
[ Detail ] [ External Link ]

  United States Government says L.A. Gay Couple’s 1975 Marriage is Valid
The Pride L.A.
Written: Jun. 07, 2016
By: Troy Masters
[ Detail ] [ External Link ]

Docket(s)
13-cv-05090 (E.D. La.) 09/09/2014
PB-LA-0002-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint 07/16/2013
PB-LA-0002-0001 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Amended Complaint for Declaratory and Injunctive Relief 08/09/2013
PB-LA-0002-0002 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order and Reasons [Denying Leave to File Third Amended Complaint] 01/13/2014 (986 F.Supp.2d 749) (E.D. La.)
PB-LA-0002-0004 PDF | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Order and Reasons 09/03/2014 (2 F.Supp.3d 910) (E.D. La.)
PB-LA-0002-0003 PDF | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Feldman, Martin Leach-Cross (FISC, E.D. La.)
PB-LA-0002-0003 | PB-LA-0002-0004 | PB-LA-0002-9000
Monitors/Masters None on record
Plaintiff's Lawyers Spivey, Scott J. (Louisiana)
PB-LA-0002-0001 | PB-LA-0002-0002 | PB-LA-0002-9000
Defendant's Lawyers Freel, Angelique Duhon (Louisiana)
PB-LA-0002-9000
Thornhill, Jessica M.P. (Louisiana)
PB-LA-0002-9000
Other Lawyers None on record

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