## Facts

- Seven same-sex couples in Massachusetts, many in long-term relationships and some raising children, sought marriage licenses in 2001.
- Local officials denied the applications solely because each couple consisted of two people of the same sex.
- The couples sued the Department of Public Health and its Commissioner, challenging Massachusetts marriage statutes as applied to exclude same-sex couples.
- The Superior Court granted summary judgment for the Department, reasoning that redefining marriage was for the Legislature and that limiting marriage to opposite-sex couples was rationally related to legitimate purposes.
- The Supreme Judicial Court heard the appeal and considered whether the exclusion was consistent with state constitutional protections.

## Issues

1. Whether excluding same-sex couples from civil marriage violates Massachusetts constitutional guarantees of individual liberty and substantive due process.
2. Whether the exclusion denies equality before the law under Massachusetts constitutional equal protection principles.
3. Whether the exclusion is rationally related to legitimate governmental interests asserted to justify limiting marriage to opposite-sex couples.

## Decision

- The Supreme Judicial Court reversed and ordered judgment for the plaintiffs, holding the exclusion violates Massachusetts constitutional guarantees of liberty and equality.
- The court applied rational basis review and concluded the exclusion was not rationally related to legitimate interests in public health, safety, or welfare.
- The court rejected asserted justifications, including: encouraging procreation within marriage, favoring an “optimal” setting for child-rearing, conserving public resources, and preserving tradition or proceeding cautiously.
- The court reasoned that procreation has never been a prerequisite to marriage, that excluding same-sex couples harms children being raised by such couples by denying family protections, and that tradition alone cannot justify unequal legal status.
- The court defined civil marriage as “the voluntary union of two persons as spouses, to the exclusion of all others.”
- The court stayed entry of judgment for 180 days to allow legislative action consistent with the constitutional ruling.

## Legal Principles

- Civil marriage is a secular, state-created legal status carrying extensive benefits and obligations; denial of access to that status triggers review under state constitutional liberty and equality guarantees.
- Under Massachusetts constitutional review, a statutory classification must bear a rational relationship to a legitimate governmental objective; unsupported appeals to tradition or generalized caution do not satisfy this requirement.
- The state may not justify exclusion from a core civil institution by reasons that do not logically advance asserted objectives or that inflict substantial harm without adequate governmental justification.
- Equal liberty principles prohibit assigning a disfavored group an inferior civil status where the exclusion lacks a rational connection to legitimate state interests.

## Conclusion

The Supreme Judicial Court held that Massachusetts may not deny civil marriage to same-sex couples because the exclusion lacks a rational relation to legitimate state objectives and violates state constitutional protections of liberty and equality; the court required access to marriage after a 180-day stay and adopted a gender-neutral definition of civil marriage.


Goodridge v. Dep't of Pub. Health, 440 Mass. 309, 798 N.E.2d 941 (2003)