University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Forum for Equality Louisiana v. Barfield PB-LA-0005
Docket / Court 2:14-cv-00327 ( E.D. La. )
State/Territory Louisiana
Case Type(s) Public Benefits / Government Services
Special Collection Same-Sex Marriage
Case Summary
On February 12, 2014, four married, same-sex couples and a nonprofit organization filed a lawsuit under 42 U.S.C. § 1983 in the U.S. District Court Eastern District of Louisiana against the State of Louisiana. The plaintiffs, represented by private counsel, asked the court to declare ... read more >
On February 12, 2014, four married, same-sex couples and a nonprofit organization filed a lawsuit under 42 U.S.C. § 1983 in the U.S. District Court Eastern District of Louisiana against the State of Louisiana. The plaintiffs, represented by private counsel, asked the court to declare unconstitutional any Louisiana Laws that do not recognize the legal marriages of same-sex couples performed in other jurisdictions, enjoin enforcement of such laws, declare that the enforcement of such laws violates citizens' right to free speech, require the defendants in their official capacities to recognize the plaintiffs' marriages as valid and enforceable under Louisiana law, and to award the plaintiffs reasonable attorney's fees and costs of suit.

The Louisiana Anti-Recognition Laws prohibited Louisiana officials from recognizing the marriages of same-sex couples entered into in another jurisdiction where same-sex marriages were legal. The plaintiff claimed that the Louisiana Anti-Recognition Laws violated their rights under the Equal Protection and Due Process clauses of the United States constitution. The plaintiffs also alleged that the laws infringed upon their freedom of speech.

This case was consolidated with a similar Louisiana case, Robicheaux v. Caldwell, on March 18, 2014.

On September 3, 2014, the court (Magistrate Judge Michael North) entered judgment in favor of the defendants. The court found that the State of Louisiana had a legitimate interest under a rational basis standard of review for addressing the meaning of marriage through the democratic process, and that the plaintiffs had failed to establish a genuine dispute regarding a First Amendment violation. The order denied the plaintiffs' motion for summary judgment and granted the defendants' motion for the same.

On September 4, 2014, the plaintiffs appealed to the U.S. Court of Appeals for the Fifth Circuit, which has scheduled oral argument for January 9, 2015.

Megan Dolan - 10/23/2014
Priyah Kaul - 12/04/2014


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Issues and Causes of Action
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Issues
Affected Gender
Female
Male
Constitutional Clause
Due Process
Equal Protection
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
Non-profit NON-religious organization
Private Plaintiff
Causes of Action State law
Declaratory Judgment Act, 28 U.S.C. § 2201
42 U.S.C. § 1983
Defendant(s) State of Louisiana
Plaintiff Description Plaintiffs are four married, same-sex couples and a nonprofit organization that advocates for the rights of gay, lesbian, bisexual, and transgender Louisiana residents.
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer Yes
Nature of Relief None
Source of Relief Litigation
Form of Settlement None on record
Order Duration not on record
Case Closing Year n/a
Case Ongoing Yes
Case Listing PB-LA-0002 : Robicheaux v. Caldwell (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)
2:14-cv-00327-MLCF-MBN (E.D. La.) 09/04/2014
PB-LA-0005-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Declaratory and Injunctive Relief 02/12/2014 (2014 WL 570570)
PB-LA-0005-0001.pdf | WESTLAW | Detail
Document Source: PACER [Public Access to Court Electronic Records]
[Order for case consolidation] 03/18/2014 (E.D. La.)
PB-LA-0005-0003.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order and Reasons 09/03/2014 (2 F.Supp.3d 910) (E.D. La.)
PB-LA-0005-0002.pdf | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judgment 09/03/2014 (E.D. La.)
PB-LA-0005-0004.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Feldman, Martin Leach-Cross (FISC, E.D. La.)
PB-LA-0005-0002 | PB-LA-0005-0003 | PB-LA-0005-0004 | PB-LA-0005-9000
Monitors/Masters None on record
Plaintiff's Lawyers Courson, J. Dalton (Louisiana)
PB-LA-0005-0001 | PB-LA-0005-9000
Harris, Lesli D. (Louisiana)
PB-LA-0005-9000
Landis, John M. (Louisiana)
PB-LA-0005-9000
Tigchelaar, Brooke C. (Louisiana)
PB-LA-0005-9000
Wall, Maurine (Louisiana)
PB-LA-0005-9000
Defendant's Lawyers Duncan, Stuart Kyle (Louisiana)
PB-LA-0005-9000
Johnson, J. Michael (Louisiana)
PB-LA-0005-9000
Other Lawyers None on record

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