My last post concerned some questions asked by David Frum concerning same-sex marriage and conflict of laws, as well as some answers provided by Eugene Volokh. The questions generally concerned two people who married in Massachusetts and how that marriage would be treated by other states and by the federal government. Frum believes his questions demonstrate why we need a national solution to same-sex marriage. I think recognizing same-sex marriage throughout the United States would be a wonderful thing and that it would provide better simpler answers to Frum's question. Banning same-sex marriage throughout the United States, however, will not avoid Frum's questions. That is because same-sex marriage is already legal elsewhere, for example, Canada. So just replace Massachusetts with Ontario in Frum's questions and we will still be faced with the consequences that follow from not recognizing valid marriages. Let's see the new eight questions:
- An Ontario man buys a condo in Miami. He marries another Ontario man. The condo purchaser dies before he can write a new will. Who inherits the condo?
- Two Ontario women marry. One of them becomes pregnant. The couple split up, and the woman who bore the child moves to Connecticut. The other woman sues for visitation rights. What should the Connecticut courts do?
- An Ontario man living in the United States is accused of stock fraud. The federal Securities and Exchange Commission subpoenas his spouse. The spouse claims marital privilege and refuses to answer the SEC’s questions. May the SEC compel him to answer anyway?
- An Ontario woman marries another Ontario woman. The relationship sours. Without obtaining a divorce, she moves to Texas and marries a man. Has she committed bigamy?
- Two married Ontario men are vacationing in the United States. One of them has a stroke. The hospital concludes he will never recover. Local law requires the hospital to ask the next of kin whether to continue treatment. Whom should it ask?
- A Massachusetts man marries a Canadian man in Ontario. Should the foreigner be entitled to US residency?
- A Delaware family set up a trust for their son. The son moves to Ontario, marries a man, and then gets divorced. The trust is the son's only financial asset. Should Ontario take the trust into account while dividing up the couple’s possessions? If yes, what happens when the Delaware trustees refuse to comply?
- An Ontario woman married to another woman wins a lawsuit against a California corporation. She dies before she can collect her debt. Her closest blood relative demands that the corporation pay the relative, not the surviving spouse. Who should get the money?
I think in all of these cases the United States or the particular state should recognize the marriage. There are many good reasons for doing so, and I do not see what is to be gained by not recognizing the marriage. In any case, though, those conflicts will occur regardless of whether same-sex marriage is allowed in Massachusetts. So unless the US plans on invading Canada, this is something we are going to have to deal with. And actually, at least for the time being, we are more likely to have deal with these scenarios arising from Canada. That is because the general rule of law is that a marriage valid where celebrated is valid everywhere. There are exceptions to this rule, and many states as well as the federal government have carved out an exception for same-sex marriages. The rule does not depend, though, on whether that location was another state or another country. It does matter, though, whether the marriage was valid where celebrated. Ontario has no residency requirements, so a marriage there even between US citizens is going to be valid there. Massachusetts, however, does have a reverse evasion law which says that a marriage contracted between people residing and intending to continue to reside in another jurisdiction is invalid if it would be "void" in that other jurisdiction. So with such marriages we don't even have to look to the exceptions, it violates the general rule to begin with. That is why GLAD is telling people in such situations that they would be better off marrying in Canada as opposed to Massachusetts. There is still no guarantee that the marriage will be recognized, but it is hard to imagine a situation where the Massachusetts marriage would be recognized, but not the Canadian marriage.
NOTE: Fun coincidence. As noted in the last post, Frum originally asked his questions on my last birthday. The decision first legalizing same-sex marriage in Canada was delivered on my wife's last birthday. Weird.
So unless the US plans on invading Canada, this is something we are going to have to deal with.
Well... we invaded Canada during the war of 1812, I think to resolve the issue of who inherits a condo in Florida, we should invade again. But, I think we'll also need to invade all of Scandinavia.
And what if some other liberal European states enact SSM?
I'm seeing a slippery slope here.....
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On an irrelevant note: I'll admit, like many of my fellow Americans, I'm relatively clueless about Canadian history. When did Canada officially become Canada, as opposed to abunch of separate English Colonies? Did we invade Canada, "proto-Canada", or just a stand alone province during the war of 1812?
Posted by: lucia | May 12, 2004 at 12:16 PM
I guess most people would say Canada officially became Canada in 1867 with the passage of the British North America Act which combined the provinces into one Federation. Canada didn't become a fully sovereign state until the Canada Act of 1982, though.
I guess we wouldn't really be invading Canada, though. It would be more an act of liberation. After all, it was judges that legalized same-sex marriage there and we all know that is an act of tyranny. I'm sure Canadians would welcome us liberating them from those judicial tyrants.
Posted by: Galois | May 12, 2004 at 12:28 PM
By this canadian logic, the U.S. will have to recognize the polygamous partnerships of Saudis as well, right?
Posted by: Marty | May 12, 2004 at 04:46 PM
Ontario has no residency requirements, so a marriage there even between US citizens is going to be valid there.
This is not a move for the impulsive though, since Ontario does have a residency requirement for divorce (one or both spouses must have lived in Ontario for at least a year).
On an irrelevant note: I'll admit, like many of my fellow Americans, I'm relatively clueless about Canadian history. When did Canada officially become Canada, as opposed to abunch of separate English Colonies? Did we invade Canada, "proto-Canada", or just a stand alone province during the war of 1812?
As an American who now lives in Canada, I found the book "Canadian History for Dummies" (yes, really) to be quite informative and entertaining.
The short answer is that in 1812 the U.S. invaded the colony of "Upper Canada" (basically, what is now Ontario), which was populated mostly by English Loyalists who had fled the American Revolution and were none to keen on being annexed by the U.S. The other colonies of British North America (especially Lower Canada - what is now Quebec) did get involved in the war later on to lesser or greater degrees.
And yes, the British North American colonies formed The Dominion of Canada in 1867 (though some provinces joined later - with Newfoundland being the last in 1949), partially in response to the U.S. Civil War. Officially Britain (and Canada) were neutral during the Civil War - but unofficially they were rooting for the Confederacy (two United Stateses distracted by squabbling amongst themselves would have made it easier for Canada to gobble up larger parts of western North America). As the war wound down to its bloody end, many in the North were casting angry eyes to the farther north and vowing, "Canada next!" and Congress even passed the Annexation Bill, which laid the groundwork for admitting the various Canadian colonies as U.S. states even before they asked. No annexation ended up occurring, but the free-trade agreement that had existed with most of British N.A. was not renewed by the U.S. The Canadian colonies bonded together out of mutual economic need and mutual protection against possible American annexation.
Posted by: Alex | May 12, 2004 at 05:28 PM
By this canadian logic, the U.S. will have to recognize the polygamous partnerships of Saudis as well, right?
Good question. The answer is, no. That is one of the exceptions to the general rule. Since polygamy is "odious" to the forum, it does not need to be recognized. That is not to say that polygamous marriages have not been recognized for some purposes.
For example, see in re Dalip Singh Bir's Estate. The deceased had two wives from India. The court decided that it was okay to recognize both marriages for purposes of succession of the estate, since the State only had an interest in preventing polygamous cohabitation in the forum. In reversing the trial court (which had not recognized the marriages) the court of appeal said:
As I said these are issues that already come up. To say we need a national policy with regards to same-sex marriage because otherwise these issues will arise is ridiculous. They already arise.
Posted by: Galois | May 12, 2004 at 05:34 PM
Gabriel, the concern is about the Full Faith and Credit clause. Canada is not just another state.
The distinction you're missing is between whether a state may choose not to recognize a foreign marriage, and whether the FF&C clause forces it to recognie the marriage. In the legal lexicon, Mississippi is a foreign jurisdiction to Louisiana just as Canada is. The difference is the FF&C clause.
You've got to be careful in grabbing quotes from cases. The key fact in the Dalip Singh case was that there was no dispute between the parties. In our adversarial system, courts are encouraged to act as referees deciding between opposing parties. It's very rare to arrive at a decision that neither of the parties has asked for. What's strange about that case is that the trial court denied both litigants what they wanted.
Another point on the SSM and the FF&C clause from your posts on Dust in the Light: In analyzing a legal issue, the question is not "Is there a coherent argument for your side?" Each side always has coherent arguments. The question is what the judge will do.
Predicting judges is really what the practice of law is all about. It's partly a question of logic and precedent, and partly a question of politics and personal emotion. Judges are responsible for creating rules that are workable across a wide variety of situations. Judges aren't supposed to create messes for others to clean up; they're supposed to get rid of the messes. The only examples I can think of are too technical to get into, but suffice to say, good judges are always worried about the practical effects of their decisions.
That's a big reason why I'm so confident that a court would conclude that the FF&C clause would hold based on Williams v. North Carolina 317 U.S. 287 (1942). It's not that the problems of patchwork marriage would be definitely be impossible to solve. It's not a judge's place to create problems like that. A judge who wasn't an ideologue would have no interest in risking a nationwide plague of difficult legal questions about marriage.
Posted by: Ben Bateman | May 13, 2004 at 11:01 AM
Yes there is no telling what a judge would rule, but I see no reason to believe that a judge would say that FF&C requires any and all sister-state marriages to be recognized. It has never been interpreted so, and on the contrary it has been stated a number of times that FF&C merely constitutionalized what were general principles of international law. In that sense it was like a strong treaty. I'll look into the matter, but I'm guessing we have similar treaties with Canada. On top of that, based on the wording of the FF&C clause, the Supreme Court has indicated it would give great deference to Congress on what and how things required Full Faith and Credit. Legal experts in conflict-of-laws have reiterated this point. So while there is of course no predicting what judges will do with 100% certainty, I cannot imagine a judge recognizing a Massachusetts same-sex marriage and not recognizing an Ontario same-sex marriage with the same fact pattern.
Keep in mind, I'm not saying that a judge wouldn't recognize a Massachusetts marriage under a certain fact pattern. What I am saying is the same judge would then almost certainly recognize the Ontario marriage under the same circumstances. Ultimately even if a judge did declare out of the blue that FF&C required recognition of a Massachusetts marriage, but not an Ontario marriage, I can't imagine five justices on the Supreme Court that would agree. More than ever this court has been a strong defender of the sovereigty of states. I could possibly see them requiring SSM on equal protection and due process grounds, but not FF&C.
Yes in Dalip Singh there was no dispute between the parties. It reminds me of the case in Iowa where a judge granted a dissolution to a civil union. He just signed off on an agreement the parties had reached, but there has been a big uproar.
Posted by: Galois | May 13, 2004 at 11:36 AM
Hmm...it seems that there are no treaties with Canada in regards to choice-of-law provisions. The standard principles of comity have applied, though, so I think there might be due process concerns if a state violated them in a particular case.
In any case the courts will still have to deal with these situations. So a national policy against same-sex marriage does not eliminate having to deal with these cass. If Frum think it is unworkable to have the marriage recognized in Massachusetts but not Texas, I don't see why it suddenly becomes workable if that same thing happens with Ontario and Texas.
Posted by: Galois | May 13, 2004 at 12:07 PM
That is because the general rule of law is that a marriage valid where celebrated is valid everywhere. There are exceptions to this rule, and many states as well as the federal government have carved out an exception for same-sex marriages. The rule does not depend, though, on whether that location was another state or another country.
What is the source of this 'general rule of law'? If you're admitting that polygamy is an exception, then it's the exception that eats the rule--eats it alive, and with salt!
Marriages between individuals that are contracted in other countries are recognized only at the option of the host country, barring some treaty commitment. In general, they are recognized, but that's simply a matter of policy choice, not a 'general rule of law.'
Even if we were being complete legal realists, and stating that since they were generally recognized, that 'is' the law, precision would be in order here: throughout the world, in general, heterosexual monogamous unions between non-incestuous partners of the same race are 'almost universally' recognized. Beyond that, we're in the realm of 'exceptions.'
Posted by: A. Rickey | May 15, 2004 at 12:58 PM
What is the source of this 'general rule of law'?
The source is common law (I believe the principle is referred to as lex loci celebrationis), although the policy has subsequently been put in place by statute in many jurisdictions. Many states have specifically incorporated the rule as expressed in the Restatement (Second) Conflict of Laws. (I think section 283) If you would like to investigate whether and how the rule has been put in place in a certain state you can research that. You're now a 2L (congrats!), I assume you have some sort of student access to Lexis-Nexis. I would also recommend the following journal articles:
One thing you will notice in the choice of law rules that states have adopted is that--at least the ones I have seen so far--they do not draw a distinction between sister states and other foreign jurisdictions. They are both foreign marriages.
If you're admitting that polygamy is an exception, then it's the exception that eats the rule--eats it alive, and with salt!
I don't know what you mean by that. Polygamy is an exception, oft times specifically mentioned. Other times it is taken to fall under the "strong public policy" exception. The general rule is still there, and states have recognized marriages that would not have been valid under the forum's own law. This is especially true if the marriages were not evasive, although there have even been recognition of evasive marriages in some cases. But again, I'm not aware of any state drawing a distinction is drawn between sister state marriages and other foreign marriages, although it possible some state does and I just haven't come across yet in my readings.
In general, they are recognized, but that's simply a matter of policy choice, not a 'general rule of law.'
Maybe we're using the word "law" in different senses. I agree it is a policy choice, but laws are generally policy choices. When I said general rule of law I meant (1) it was a rule recognized at common law (with the public policy exception) and (2) it is a rule that has been put in place by many states by statute.
I do not mean this is any binding law of nature or inalienable right that a state could not get rid of if it so chose. I do think there is a right to due process so I believe the State would need to justify the decision to treat these marriages differently, but if they could justify treating same-sex couples differently with regards to marrying them within the state in the first place, they very well might be able to satisfy the concerns with respect to foreign marriages. It's hard for me to say because I see no rational basis to not marry the couples in the first place, but I understand some disagree with me on that matter.
throughout the world, in general, heterosexual monogamous unions between non-incestuous partners of the same race are 'almost universally' recognized.
But the rules in those states without a DOMA don't say heterosexual. Even some incestuous marriages have been recognized under this rule. Now you are saying there should be an exception for homosexual marriages. Fine, but why? And why should a state draw a distinction between Canadian marriages and Massachusetts marriages?
This post was in a response to Frum saying that there would be too many policy problems from having a marriage recognized in Massachusetts but not recognized elsewhere. Regardless of how one views Full Faith and Credit many of the same policy problems he points out occurs if a marriage is recognized in Canada but not in the United States (those policy problems relating to Federal/State disagreement over marriage will not necessarily translate completely but become more like the Interstate disagreement). There are strong policy reasons for recognizing foreign marriages including same-sex marriages. What policy reasons are there for not giving any recognition to them?
Posted by: Galois | May 15, 2004 at 02:42 PM
I did a little more research for you as to which states have adopted this common law rule by statute. In today's FindLaw Writ, Joanna Grossman writes:
A quick google search leads me to the Legal Information Institute which has a listing of which states have adopted the UMDA. Namely Arizona, Colorado, Illinois, Kentucky, Minnesota, Missouri, Montana, and Washington. All of these states I believe have specific exceptions listed including same-sex marriages, (see for example Arizona). Of course this listing is not exhaustive of states which have adopted by statute place-of-celebration rules. Notice also that the place-of-celebration rule says nothing about whether that place is another state of the union.
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in the vip -
i spy cameltoe -
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milf next door -
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please bang my wife -
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mikes apartment -
milf hunter -
milf next door -
mr chews asian beaver -
please bang my wife -
round and brown -
see her squirt -
street blowjobs -
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we live together -
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kalifornication -
8th street latinas -
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in the vip -
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mikes apartment -
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milf next door -
mr chews asian beaver -
please bang my wife -
round and brown -
see her squirt -
street blowjobs -
teeny bopper club -
tinys black adventures -
tranny surprise -
we live together -
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milf next door -
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please bang my wife -
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see her squirt -
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tinys black adventures -
tranny surprise -
we live together -
xxx proposal -
lesbian sweat -
8th street latinas -
all reality pass -
all sites access -
barefoot maniacs -
big naturals -
big tit patrol -
boys first time -
cam crush -
captain stabbin -
coeds need cash -
cum fiesta -
dangerous dongs -
euro sex parties -
first time auditions -
horny spanish flies -
in the vip -
i spy cameltoe -
mike in brazil -
mikes apartment -
milf hunter -
milf next door -
mr chews asian beaver -
please bang my wife -
round and brown -
see her squirt -
street blowjobs -
teeny bopper club -
tinys black adventures -
tranny surprise -
we live together -
xxx proposal -
lesbian sweat -
8th street latinas -
all reality pass -
all sites access -
barefoot maniacs -
big naturals -
big tit patrol -
boys first time -
cam crush -
captain stabbin -
coeds need cash -
cum fiesta -
dangerous dongs -
euro sex parties -
first time auditions -
horny spanish flies -
in the vip -
i spy cameltoe -
mike in brazil -
mikes apartment -
milf hunter -
milf next door -
mr chews asian beaver -
please bang my wife -
round and brown -
see her squirt -
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mikes apartment -
milf next door -
round and brown -
street blowjobs -
tranny surprise -
we live together -
anal sorority -
8th street latinas -
all sites access -
big naturals -
boys first time -
cam crush -
captain stabbin -
cum fiesta -
dangerous dongs -
in the vip -
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mikes apartment -
round and brown -
street blowjobs -
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we live together -
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all sites access -
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captain stabbin -
cum fiesta -
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in the vip -
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round and brown -
street blowjobs -
tranny surprise -
we live together -
asian sizzle -
8th street latinas -
all sites access -
big naturals -
boys first time -
cam crush -
captain stabbin -
cum fiesta -
dangerous dongs -
in the vip -
mike in brazil -
mikes apartment -
round and brown -
street blowjobs -
tranny surprise -
we live together -
Posted by: jc | November 02, 2007 at 10:26 PM