University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Morgan v. Snyder PB-MI-0008
Docket / Court 1:14-cv-00632 ( W.D. Mich. )
State/Territory Michigan
Case Type(s) Public Benefits / Government Services
Special Collection Same-Sex Marriage
Case Summary
On June 11, 2014, plaintiffs, a gay couple, filed this lawsuit in the U.S. District Court for the Western District of Michigan, under 42 U.S.C. 1983, against the State of Michigan and Kent County, Michigan. The plaintiffs, represented by private counsel, asked the court for declaratory and ... read more >
On June 11, 2014, plaintiffs, a gay couple, filed this lawsuit in the U.S. District Court for the Western District of Michigan, under 42 U.S.C. 1983, against the State of Michigan and Kent County, Michigan. The plaintiffs, represented by private counsel, asked the court for declaratory and injunctive relief, claiming that State's refusal to recognize their out-of-state marriage violated the Due Process and Equal Protection Clauses of the Fourteenth Amendment to the U.S. Constitution.

Earlier, in DeBoer v. Snyder, PB-MI-0004 in this Clearinghouse, the case challenging Michigan's ban on same-sex marriage, on March 21, 2014, the U.S. District Court for the Eastern District of Michigan (Judge Bernard Friedman) had struck down the ban. DeBoer v. Snyder, 973 F. Supp. 2d 757 (E.D. Mich. 2014). The next day about three hundred same-sex couples wed across the state. Later that afternoon, the U.S. Court of Appeals for the Sixth Circuit granted a temporary stay in DeBoer; it was subsequently extended pending that case's final disposition in the Sixth Circuit. See Order, DeBoer v. Snyder, Case No. 14-1341 (6th Cir. March 25, 2014). The stay prevented any more same-sex couples in Michigan from marrying. On November 6, 2014, the Sixth Circuit reversed Judge Friedman's ruling and held the same-sex marriage ban constitutional. 772 F.3d 388 (6th Cir. 2014).

Earlier yet, in December 2013, plaintiffs in this case, Michigan residents, had traveled to New York State in order to marry. New York recognized same-sex marriage--Michigan did not. Back home in Michigan, in April 2014, plaintiffs submitted a quit claim deed, for recording with the Kent County Register of Deeds, conveying their residence from themselves as tenants to themselves as tenants by the entirety; tenancy by the entirety requires a valid marriage. Plaintiffs attached a copy of their New York marriage license. The Register of Deeds refused to record their deed claiming that Michigan does not recognize same-sex marriage. Plaintiffs brought this suit.

In plaintiffs' view, same-sex marriage was legal in Michigan for a brief time window after Judge Friedman's DeBoer ruling and before the Sixth Circuit's stay. Under the U.S. Constitution's Full Faith and Credit Clause, plaintiffs say that Michigan is required to recognize the out-of-state same-sex marriages of its residents living in the state during that brief window. Their case was assigned to Judge Gordon Quist. On July 14, 2014, the state filed a motion to dismiss, as well as a motion to stay the case pending the decision in DeBoer, which was then pending before the Sixth Circuit. On August 11, 2014, Judge Quist granted the state's motion for a stay pending the decision in DeBoer. On December 23, 2014, Judge Quist denied the state's motion to dismiss and extended this stay following the Sixth Circuit's decision and any subsequent review by the U.S. Supreme Court. The Supreme Court granted certiorari review in DeBoer, and on January 16, 2015, consolidated the case with three others as Obergefell v. Hodges.

In this case, the plaintiffs moved to lift the stay and enter judgment in their favor on April 2, 2015, citing the January 15, 2015 decision in Caspar v. Snyder in the Eastern District of Michigan, which held that the state could not refuse to recognize same-sex marriages that were performed in Michigan during the time between the district court’s ruling in DeBoer and the Sixth Circuit’s issuance of a temporary stay, 77 F. Supp. 3d 666 (E.D. Mich. 2015), and the declining health of one of the plaintiffs. Judge Quist denied the plaintiffs' motion to lift the stay on April 21, 2015, noting that the court was still bound by the Sixth Circuit decision in DeBoers and that the Caspar decision was both non-binding and distinguishable.

On June 26, 2015, the Supreme Court held in a 5-4 decision in Obergefell that the Fourteenth Amendment requires all states to grant same-sex marriages and recognize same-sex marriages granted in other states. 135 S.Ct. 2584 (2015). In an October 8, 2015 order, the court determined that the Supreme Court's decision in Obergefell rendered the issues in this case moot.

The plaintiffs moved for attorney's fees under 42 U.S.C. 1988. In a December 3, 2015 order, Judge Quist found that the plaintiffs were not a prevailing party for purposes of the fee-shifting statute because the Obergefell decision rendered the issues in the case moot. The plaintiffs appealed the order denying the motion for attorney's fees and costs to the Sixth Circuit on December 30, 2015. On April 13, 2016, the Sixth Circuit dismissed the appeal pursuant to the voluntary dismissal of the parties.

David Hamstra - 02/03/2015
Sarah McDonald - 08/06/2018


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Equal Protection
Full faith and credit
Defendant-type
Jurisdiction-wide
Discrimination-basis
Sexual orientatation
General
Gay/lesbian/transgender
Marriage
Public benefits (includes, e.g., in-state tuition, govt. jobs)
Plaintiff Type
Private Plaintiff
Race
Race, unspecified
Causes of Action 42 U.S.C. § 1983
Defendant(s) Kent County, Michigan
State of Michigan
Plaintiff Description Plaintiffs are two men married in New York State. They are seeking recognition of their marriage in their home state of Michigan.
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief None
Source of Relief None
Filing Year 2014
Case Closing Year 2016
Case Ongoing No
Case Listing PB-MI-0004 : DeBoer v. Snyder (E.D. Mich.)
Docket(s)
1:14-cv-00632 (W.D. Mich.)
PB-MI-0008-9000.pdf | Detail
Date: 04/13/2016
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint [ECF# 1]
PB-MI-0008-0001.pdf | Detail
Date: 06/11/2014
Source: PACER [Public Access to Court Electronic Records]
Order Granting Motion to Stay [ECF# 25] (W.D. Mich.)
PB-MI-0008-0002.pdf | Detail
Date: 08/11/2014
Source: PACER [Public Access to Court Electronic Records]
Order Staying Case [ECF# 31] (W.D. Mich.)
PB-MI-0008-0003.pdf | Detail
Date: 12/23/2014
Source: PACER [Public Access to Court Electronic Records]
Judges Quist, Gordon Jay (W.D. Mich.)
PB-MI-0008-0002 | PB-MI-0008-0003 | PB-MI-0008-9000
Plaintiff's Lawyers Myott, Stephanie D. (Michigan)
PB-MI-0008-0001 | PB-MI-0008-9000
Defendant's Lawyers Booth, Joshua O. (Michigan)
PB-MI-0008-9000
Grossi, Christina M. (Michigan)
PB-MI-0008-9000
Howell, Linda S. (Michigan)
PB-MI-0008-9000
Murphy, Michael F (Michigan)
PB-MI-0008-9000

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