Gartner v. Iowa Department of Public Health
Iowa Supreme Court
830 N.W.2d 335 (2013)
- Written by Galina Abdel Aziz , JD
Facts
Melissa and Heather Gartner (plaintiffs) had been in a long-term committed relationship since 2003. Heather conceived a child by artificial insemination via an anonymous sperm donor. The Gartners went through formal adoption procedures to ensure that both Heather and Melissa were listed on the child’s birth certificate. Iowa subsequently legalized same-sex marriage, and Melissa and Heather married. At the time, Heather was six months pregnant with the couple’s second daughter, Mackenzie. After Mackenzie’s birth, the Iowa Department of Public Health (the department) (defendant) issued Mackenzie’s birth certificate, which only listed Heather as a parent and left a blank space for the father’s name. The Gartners requested that the department recognize both Heather and Melissa on the birth certificate. The department denied the request, alleging that Iowa recognized the gendered roles of a mother and father and that the nonbiological mother in a lesbian marriage must adopt a child to be listed on the birth certificate. Under Iowa Code § 144.13(2), if a mother was married at the conception, birth, or any time between conception and birth, then the name of the husband was entered on the birth certificate unless a court determined paternity otherwise. The Gartners sued the department, alleging that the department had violated the equal-protection clauses of the Iowa constitution because the refusal constituted a classification based on sex and sexual orientation. The district court found for the Gartners and ordered the department to issue a new birth certificate that included Melissa. The department appealed, arguing that the refusal only classified individuals based on sex and that an intermediate level of scrutiny applied. The department also argued that § 144.13(2) furthered important government interests including accuracy, efficiency and effectiveness, and the determination of paternity.
Rule of Law
Issue
Holding and Reasoning (Wiggins, J.)
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