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, sought a declaration that any Louisiana ... 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, sought a declaration that any Louisiana laws that do not recognize the legal marriages of same-sex couples performed in other jurisdictions are unconstitutional and that the enforcement of such laws violates citizens' right to free speech. They also sought to enjoin enforcement of such laws, require the defendants in their official capacities to recognize the plaintiffs' marriages as valid and enforceable under Louisiana law, and 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, Magistrate Judge Michael North entered judgment in favor of the defendants. Robicheaux v. Caldwell, 2 F. Supp. 3d 910 (E.D. La. 2014). 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. While this appeal was under submission, the Supreme Court decided Obergefell v. Hodges, 135 S.Ct. 2584 (2015), (PB-OH-0003 in this Clearinghouse), which held that the right to marry is a fundamental right under the Due Process and Equal Protection Clauses of the Fourteenth Amendment and that same-sex couples may not be deprived of that right. Thus, on July 1, 2015, the Fifth Circuit reversed the District Court's decision and remanded for entry of judgment in favor of the plaintiffs. Robicheaux v. Caldwell, 791 F.3d 616 (5th Cir. 2015). The case is now closed.

Megan Dolan - 10/23/2014
Priyah Kaul - 12/04/2014
Eva Richardson - 01/07/2019


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Issues and Causes of Action
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Issues
Affected Gender
Female
Male
Constitutional Clause
Due Process
Equal Protection
Content of Injunction
Discrimination Prohibition
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 42 U.S.C. § 1983
Declaratory Judgment Act, 28 U.S.C. § 2201
State law
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.
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Declaratory Judgment
Attorneys fees
Injunction / Injunctive-like Settlement
Source of Relief Litigation
Filing Year 2014
Case Closing Year 2015
Case Ongoing No
Case Listing PB-LA-0002 : Robicheaux v. Caldwell (E.D. La.)
Docket(s)
2:14-cv-00327-MLCF-MBN (E.D. La.)
PB-LA-0005-9000.pdf | Detail
Date: 07/02/2015
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Declaratory and Injunctive Relief [ECF# 1] (2014 WL 570570)
PB-LA-0005-0001.pdf | WESTLAW | Detail
Date: 02/12/2014
Source: PACER [Public Access to Court Electronic Records]
[Order for case consolidation] [ECF# 16] (E.D. La.)
PB-LA-0005-0003.pdf | Detail
Date: 03/18/2014
Source: PACER [Public Access to Court Electronic Records]
Judgment [ECF# 17] (E.D. La.)
PB-LA-0005-0004.pdf | Detail
Date: 09/03/2014
Source: PACER [Public Access to Court Electronic Records]
Order and Reasons [ECF# 131] (2 F.Supp.3d 910) (E.D. La.)
PB-LA-0005-0002.pdf | WESTLAW| LEXIS | Detail
Date: 09/03/2014
Source: PACER [Public Access to Court Electronic Records]
Opinion [Ct. of App. ECF# 138] (791 F.3d 616)
PB-LA-0005-0005.pdf | WESTLAW| LEXIS | Detail
Date: 07/01/2015
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
Plaintiff's Lawyers Courson, J. Dalton (Louisiana)
PB-LA-0005-0001 | PB-LA-0005-9000
Harris, Lesli D. (Louisiana)
PB-LA-0005-9000
Laborde, Maurine Wall (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
Glazer, Phyllis Esther (Louisiana)
PB-LA-0005-9000
Johnson, J. Michael (Louisiana)
PB-LA-0005-9000
Sanders, David Glen (Louisiana)
PB-LA-0005-9000

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