Joseph R. Diaz v. Janice K. Brewer, Governor of the State of Arizona

In April 2008, the state of Arizona began offering healthcare benefits to the dependents of state employees. This allowed domestic partners to receive healthcare benefits, regardless of gender. In November 2008, the state passed the Marriage Protection Amendment, which limited marriage to opposite-sex couples. In September 2009, the healthcare benefits scheme was amended to extend healthcare benefits to only the spouses of state employees rather than to domestic partners. This resulted in same-sex domestic partners of state employees losing access to healthcare benefits. In response, Joseph R. Diaz (plaintiff) filed an action in federal district court against Governor Janice K. Brewer (the state) (defendant). Diaz argued that the scheme violated the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution because the scheme was not rationally related to a legitimate government interest and, therefore, restricted healthcare benefits in an arbitrary and discriminatory manner. The state argued that the Constitution did not obligate the state to provide the healthcare benefits. The state also argued that the scheme was rationally related to the legitimate interests of encouraging marriage and reducing costs and administrative burdens. The federal district court found that the scheme was not rationally related to the government’s professed interests, because similarly situated homosexual and heterosexual couples could not be treated differently under the guise of saving costs. Additionally, the federal court explained that the scheme was not rationally related to the government’s interest in encouraging marriage, because homosexual couples could not marry. The district court concluded that the restriction was not rationally related to any legitimate interest. The matter was appealed.