## Facts

- The New Orleans City Council adopted an ordinance creating a Domestic Partner Registry allowing couples to register a public commitment to support one another.
- The City later extended employer-provided health insurance benefits to same-sex domestic partners of City employees, using registry participation as an eligibility mechanism.
- Citizen and taxpayer plaintiffs sued the City and City Council seeking a declaration that the ordinances were ultra vires and an injunction barring enforcement of the registry and benefits.
- The trial court, after remand from earlier appellate proceedings, granted summary judgment for the City and City Council and dismissed the suit with prejudice.
- Plaintiffs appealed, challenging the denial of their motions and the grant of summary judgment to defendants.

## Issues

1. Whether the City of New Orleans exceeded its constitutional and statutory authority by establishing a domestic partner registry.
2. Whether the City exceeded its authority by extending employee health insurance benefits to employees’ domestic partners.
3. Whether the ordinances conflicted with Louisiana law governing marriage such that they were invalid.

## Decision

- The court affirmed summary judgment for the City and City Council and affirmed dismissal of plaintiffs’ petition with prejudice.
- The court reviewed the summary judgment ruling de novo and concluded there was no genuine issue of material fact and defendants were entitled to judgment as a matter of law.
- The court held the registry and benefits program fell within municipal home-rule authority and were not prohibited by state law.
- The court found the registry did not alter or interfere with Louisiana marriage law because it created no marital status, obligations, enforcement mechanism, or state-court cause of action.

## Legal Principles

- A home-rule municipality may exercise broad local governmental powers, including structuring municipal administrative programs and employee compensation/benefits, unless state law or the constitution forbids the action.
- A local ordinance is not invalid merely because it addresses relationship recognition in an administrative way; conflict arises when an ordinance purports to alter statewide domestic relations law or create enforceable civil-status rights inconsistent with state law.
- A domestic partner registry that functions as an administrative designation, without creating legal obligations or enforceable rights equivalent to marriage, does not conflict with state marriage provisions.
- Summary judgment is proper when there is no genuine issue of material fact and the mover is entitled to judgment as a matter of law.

## Conclusion

The court upheld New Orleans’ domestic partner registry and extension of health insurance benefits to domestic partners of City employees, concluding these measures were authorized under home-rule powers and did not conflict with Louisiana’s statewide regulation of marriage.


Ralph v. City of New Orleans, 4 So. 3d 146 (La. Ct. App. 4th Cir. 2009)