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Alaska Civil Liberties Union v. State

Supreme Court of Alaska
122 P.3d 781 (Alaska 2005)


Facts

The State of Alaska and the Municipality of Anchorage (defendants) offered health insurance to the spouses of their employees. Under the defendants’ benefits program, health insurance was limited to the spouses of employees and did not extend to the partners of unmarried employees. Because the Alaska Constitution prohibited same-sex marriage, health-insurance benefits were unavailable to any same-sex partners of the defendants’ employees. The Alaska Civil Liberties Union, together with several employees of the defendants and the employees’ same-sex partners (plaintiffs), sued the defendants, arguing that the spousal limitation violated the plaintiffs’ right to equal protection. Both the plaintiffs and the defendants moved for summary judgment. The plaintiffs argued that the court should apply heightened scrutiny in considering the plaintiffs’ equal-protection claim. The superior court instead applied the lowest level of scrutiny and found that the spousal limitation was substantially related to the defendants’ legitimate interest in promoting marriage. The superior court accordingly granted summary judgment to the defendants. The plaintiffs appealed.

Rule of Law

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Issue

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Holding and Reasoning (Eastaugh, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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