University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Inniss v. Aderhold PB-GA-0006
Docket / Court 1:14-cv-01180 ( N.D. Ga. )
State/Territory Georgia
Case Type(s) Public Benefits / Government Services
Special Collection Same-Sex Marriage
Attorney Organization Lambda Legal
Case Summary
On April 22, 2014, three same-sex couples and one individual filed this class-action lawsuit in the U.S. District Court for the Northern District of Georgia. Two couples wished to marry in Georgia, one couple sought recognition of their marriage celebrated in Connecticut, and the widow of a couple ... read more >
On April 22, 2014, three same-sex couples and one individual filed this class-action lawsuit in the U.S. District Court for the Northern District of Georgia. Two couples wished to marry in Georgia, one couple sought recognition of their marriage celebrated in Connecticut, and the widow of a couple married in New York sought recognition of that marriage. Represented by Lambda Legal, the plaintiffs filed their lawsuit against the State of Georgia. They sought class certification, injunctive relief, and attorneys fees.

Specifically, the plaintiffs alleged that the Georgia ban on celebration or recognition of same-sex marriage violated their rights under the Fourteenth Amendment of the United States Constitution, depriving them of due process and equal protection. They argued that the ban passed no level of judicial scrutiny and that it discriminated on the basis of sexual orientation and sex. On August 4, 2014, the plaintiffs filed an Amended Complaint.

The State moved to dismiss the complaint, and the court denied their motion on Jan. 8, 2015. Using rational basis review, the court held that the State did "not address how Georgia’s asserted interests in child welfare and procreation are advanced by the State’s prohibition on same-sex marriages, and the State’s refusal to recognize lawful marriages performed in other States." The court also found that the plaintiffs had presented evidence to the contrary, alleging that same-sex marriage prohibition in fact harms child welfare. 80 F.Supp.3d 1335.

The State moved to stay proceedings pending the resolution of Obergefell v. Hodges in the Supreme Court. The court ordered, on January 29, 2015, that the motion was granted in part and denied in part. It was granted with respect to discovery in this action, but denied with respect to non-discovery pleadings.

On June 26, 2015, the Supreme Court in Obergefell held that the right to marry is fundamental, and that it demeans gay and lesbian couples to deprive them of access to marriage. The 14th Amendment therefore does not allow states to ban same-sex marriage.

On October 7, 2015, the court enjoined the defendants from excluding same-sex couples from civil marriage on the same terms and conditions of different-sex couples. The court found that Obergefell was binding precedent and that it required entry of judgment in favor of the plaintiffs. The court enjoined the State from excluding same-sex couples from marriage on the same terms as opposite-sex couples, and from refusing to recognize a lawful same-sex marriage performed in another state on the grounds of that marriage's same-sex character.

The case is now closed.

Megan Dolan - 11/15/2015
Virginia Weeks - 03/09/2018


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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
Disparate Treatment
Gay/lesbian/transgender
Marriage
Plaintiff Type
Private Plaintiff
Causes of Action Declaratory Judgment Act, 28 U.S.C. § 2201
42 U.S.C. § 1983
Defendant(s) State of Georgia
Plaintiff Description Several same-sex couples in Georgia: some were married out-of-state and seek recognition of those marriages; some wish to marry in Georgia.
Indexed Lawyer Organizations Lambda Legal
Class action status sought Yes
Class action status granted No
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Filing Year 2014
Case Closing Year 2015
Case Ongoing No
Docket(s)
1:14-cv-01180-WSD (N.D. Ga.)
PB-GA-0006-9000.pdf | Detail
Date: 10/08/2015
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint For Injunctive And Declaratory Relief [Class Action]
PB-GA-0006-0001.pdf | Detail
Date: 04/22/2014
Source: Plaintiffs' counsel
First Amended Complaint for Injunctive and Declaratory Relief [Class Action] [ECF# 37]
PB-GA-0006-0002.pdf | Detail
Date: 08/04/2014
Source: PACER [Public Access to Court Electronic Records]
Order [ECF# 61] (N.D. Ga.)
PB-GA-0006-0003.pdf | Detail
Date: 01/29/2015
Source: PACER [Public Access to Court Electronic Records]
Order [ECF# 67] (N.D. Ga.)
PB-GA-0006-0004.pdf | Detail
Date: 10/07/2015
Source: PACER [Public Access to Court Electronic Records]
Judges Duffey, William S. Jr. (N.D. Ga.)
PB-GA-0006-0003 | PB-GA-0006-0004 | PB-GA-0006-9000
Plaintiff's Lawyers Borelli, Tara Lynn (California)
PB-GA-0006-0001 | PB-GA-0006-0002 | PB-GA-0006-9000
Custer, William V (Georgia)
PB-GA-0006-0001 | PB-GA-0006-0002 | PB-GA-0006-9000
Dempsey, Jennifer Burch (Georgia)
PB-GA-0006-0001 | PB-GA-0006-0002 | PB-GA-0006-9000
Draigh, David P (Florida)
PB-GA-0006-0001 | PB-GA-0006-0002 | PB-GA-0006-9000
Lantta, Luke A (Georgia)
PB-GA-0006-0001 | PB-GA-0006-0002 | PB-GA-0006-9000
Littrell, Elizabeth Lynn (Georgia)
PB-GA-0006-0001 | PB-GA-0006-0002 | PB-GA-0006-9000
Nevins, Gregory R. (Georgia)
PB-GA-0006-0001 | PB-GA-0006-0002 | PB-GA-0006-9000
Odom, Jennifer D. (Georgia)
PB-GA-0006-0001 | PB-GA-0006-0002 | PB-GA-0006-9000
Sommer, Susan (New York)
PB-GA-0006-0001 | PB-GA-0006-0002 | PB-GA-0006-9000
Winter, Douglas E. (District of Columbia)
PB-GA-0006-0001 | PB-GA-0006-0002 | PB-GA-0006-9000
Defendant's Lawyers Burwell, Kaye Woodard (Georgia)
PB-GA-0006-9000
Freeman, Diana L (Georgia)
PB-GA-0006-9000
Grant, Britt Cagle (Georgia)
PB-GA-0006-9000
Hill, Lanna Renee (Georgia)
PB-GA-0006-9000
Jenkins, Frank E III (Georgia)
PB-GA-0006-9000
Orland, Devon (Georgia)
PB-GA-0006-9000
Peterson, Nels Stefan David (Georgia)
PB-GA-0006-9000
Van Stephens, Michael II (Georgia)
PB-GA-0006-9000
Walker, Robert Lige (Georgia)
PB-GA-0006-9000
Ware, Robert D. (Georgia)
PB-GA-0006-9000

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