## Facts

- The New York City Clerk issued written guidelines for couples seeking to have a City Hall wedding officiated by the Clerk or a deputy.
- The guidelines required “proper” attire, including that the bride wear a dress or skirt and blouse (no slacks) and the groom wear a coat and tie.
- The guidelines also stated that one or two rings must be exchanged, but the Clerk’s office treated the requirement as satisfied by exchanging any tangible item; plaintiffs did not ultimately press the ring issue as an independent claim.
- Doreen Rappaport wanted to be married at City Hall wearing a green velvet pantsuit; she was told she must wear a skirt to be married by the Clerk, complied, and was married, but claimed injury from being required to change attire.
- A second engaged couple (including a bride-to-be who wished to wear pants) objected to the attire rule and stated they did not want a ring exchange as part of their ceremony.
- Plaintiffs filed a federal civil-rights action under 42 U.S.C. § 1983 seeking damages and injunctive relief against the City Clerk, individually and in his official capacity.
- At oral argument, plaintiffs expressly disclaimed any ongoing First Amendment claim, leaving due process/privacy theories as the main constitutional bases.
- Both sides moved for summary judgment.

## Issues

1. Whether the City Clerk’s City Hall wedding dress guideline constituted a substantial deprivation of a federal constitutional right actionable under 42 U.S.C. § 1983.
2. Whether a federal court should supervise local ceremonial “decorum” rules for marriages performed by a municipal official through injunctive and damages remedies.

## Decision

- The court granted the City Clerk’s motion for summary judgment and dismissed the complaint.
- The court concluded the challenge did not present a substantial federal question warranting § 1983 relief.
- The court treated the guidelines as minimal conditions for a particular government-officiated ceremony, not as a meaningful barrier to marriage itself.
- The court emphasized the local interest in maintaining solemnity and decorum in City Hall wedding ceremonies and declined to impose federal judicial control over such matters.

## Legal Principles

- A § 1983 claim requires a meaningful deprivation of a cognizable federal right; minor objections to local ceremonial regulations may be dismissed as insubstantial in federal constitutional terms.
- Conditions governing the outward form of a municipal ceremony, when not materially foreclosing the ability to marry, are generally matters of state and local administration rather than federal constitutional adjudication.
- Abandonment of First Amendment theories narrows review to due process/privacy claims, which may fail where the challenged rule is characterized as a neutral decorum guideline rather than compelled expression or belief.

## Conclusion

The court held that City Hall wedding attire requirements were local decorum rules that did not substantially burden a federal constitutional right, and it dismissed the § 1983 action on summary judgment rather than placing federal courts in the role of supervising municipal marriage-ceremony guidelines.


Rappaport v. Katz, 380 F. Supp. 808 (S.D.N.Y. 1974)