3:13-cv-24068 #40

8/22/2019 3:13-cv-24068 #40

http://slidepdf.com/reader/full/313-cv-24068-40 1/40

UNITED STATES DISTRICT COURT FOR THE

SOUTHERN DISTRICT OF WEST VIRGINIA

HUNTINGTON DIVISION

CASIE JO MCGEE and SARAH ELIZABETHADKINS; JUSTIN MURDOCK and WILLIAMGLAVARIS; and NANCY ELIZABETH

MICHAEL and JANE LOUISE FENTON,

individually and as next friends of A.S.M., a minorchild;

Plaintiffs,

v.

KAREN S. COLE, in her official capacity asCABEL COUNTY CLERK; and VERA J.

MCCORMICK, in her official capacity as

KANAWHA COUNTY CLERK;

Defendants,

and

STATE of WEST VIRGINIA,

Intervenor.

No. 3:13-cv-24068

PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT

Pursuant to Rule 56 of the Federal Rules of Civil Procedure, Plaintiffs hereby move for

summary judgment against all Defendants.

WHEREFORE, for the reasons stated in the accompanying Brief in Support of Plaintiffs’

Motion for Summary Judgment and supporting declarations, Plaintiffs hereby move this Court to

grant summary judgment in their favor.

Dated: December 30, 2013

Respectfully submitted,

Case 3:13-cv-24068 Document 40 Filed 12/30/13 Page 1 of 4

8/22/2019 3:13-cv-24068 #40


CASIE JO MCGEE and SARAH

ELIZABETH ADKINS, et al.

By Counsel:

/s/ John H. Tinney Jr. .THE TINNEY LAW FIRM, PLLCJohn H. Tinney, Jr. (WVSB #6970)

Heather Foster Kittredge (WVSB #8543)

P.O. Box 3752Charleston, West Virginia 25337-3752

Phone: (304) 720-3310

Fax: (304) 720-3315

[email protected]@tinneylawfirm.com

LAMBDA LEGAL DEFENSE ANDEDUCATION FUND, INC.

Elizabeth L. Littrell ( pro hac vice pending)

730 Peachtree Street, N.E.

Suite 1070Atlanta, Georgia 30308-1210

Phone: (404) 897-1880

Fax: (404) 897-1884 [email protected]

Karen L. Loewy ( pro hac vice pending)

120 Wall Street, 19th

Floor New York, New York 10005-3904

Phone: (212) 809-8585

Fax: (212) [email protected]

Camilla B. Taylor ( pro hac vice pending)105 West Adams, 26

th Floor

Chicago, Illinois 60603-6208

Phone: (312) 663-4413

Fax: (312) [email protected]

JENNER & BLOCK LLP

Paul M. Smith ( pro hac vice pending)Lindsay C. Harrison ( pro hac vice pending)

Luke C. Platzer ( pro hac vice pending)

R. Trent McCotter ( pro hac vice pending)1099 New York Avenue, NW Suite 900


8/22/2019 3:13-cv-24068 #40


Washington, D.C. 20001-4412

Phone: (202) 639-6000

Fax: (202) 639-6006 [email protected]

[email protected]

[email protected]@jenner.com

CERTIFICATE OF SERVICE

I hereby certify that on the 30th day of December 2013, I effected service upon counsel

for Defendants by electronically filing the foregoing Motion for Summary Judgment, together

with six supporting declarations and a Statement of Undisputed Facts with the Clerk of the Courtusing the CM/ECF system.

Lee Murray HallSarah A. Walling

JENKINS FENSTERMAKER, PLLC

P. O. BOX 2688

Huntington, WV 25726-2688Phone: (304) 523-2100

Attorney For: Karen S. Cole

Elbert LinJulie Ann Warren

Office of the Attorney GeneralState Capitol Building 1, Room E-26

Charleston, WV 25305

Attorney For: State of West Virginia

Charles R. BaileyMichael W. Taylor

BAILEY & WYANT

P. O. Box 3710Charleston, WV 25337-3710Email: [email protected]

Email: [email protected]

Attorneys For: Vera J. McCormick

/s/ John H. Tinney Jr. .

THE TINNEY LAW FIRM, PLLC

John H. Tinney, Jr. (WVSB #6970)Heather Foster Kittredge (WVSB #8543)

P.O. Box 3752

Charleston, West Virginia 25337-3752


mailto:[email protected]




8/22/2019 3:13-cv-24068 #40


Phone: (304) 720-3310

Fax: (304) 720-3315

[email protected]@tinneylawfirm.com

Counsel for Plaintiffs





8/22/2019 3:13-cv-24068 #40




HUNTINGTON DIVISION

CASIE JO MCGEE and SARAH ELIZABETHADKINS; JUSTIN MURDOCK and WILLIAMGLAVARIS; and NANCY ELIZABETH MICHAELand JANE LOUISE FENTON, individually and as nextfriends of A.S.M., a minor child;

Plaintiffs,

v.

KAREN S. COLE, in her official capacity as CABELCOUNTY CLERK; and VERA J. MCCORMICK, inher official capacity as KANAWHA COUNTYCLERK;

Defendants,

and

STATE of WEST VIRGINIA,

Intervenor .

No. 3:13-cv-24068

STATEMENT OF UNDISPUTED FACTS (“SUF”)

1. Casie Jo McGee and Sarah Elizabeth Adkins, both born and raised in West

Virginia, have been in a loving, committed relationship for more than three years and wish to

marry. Declaration of Casie Jo McGee (“McGee Dec.”) ¶¶ 2-4; Declaration of Sarah Elizabeth

Adkins (“Adkins Dec.”) ¶ 2-4.

2. Casie’s state employer makes available affordable spousal health insurance for its

employees, but Casie cannot add Sarah to her employer-provided health plan because she and

Sarah are not married. Because the couple could not afford to buy separate health insurance for

Sarah, Sarah went uninsured for a period of time. McGee Dec. ¶ 7.

Case 3:13-cv-24068 Document 40-1 Filed 12/30/13 Page 1 of 8

8/22/2019 3:13-cv-24068 #40


2

3. For Casie and Sarah, the ability to make medical decisions for each other is not

academic; Sarah has diabetes and has required emergency room treatment that the couple had to

pay for out-of-pocket. McGee Dec. ¶¶ 8-10.

4. Once, Casie became seriously ill after a vacation, and Sarah stayed home to care

for her. Adkins Dec. ¶ 6. Even though she arranged for someone to cover her shift at work,

Sarah was reprimanded for inappropriately taking the day off, and her supervisor told her, “It’s

not like Casie is your wife or something.” Adkins Dec. ¶ 6.

5. Casie and Sarah would like to start a family through assisted reproductive

technology, but Casie’s inability to put Sarah on her health insurance plan made it impossible for

Sarah to carry their child. McGee Dec. ¶¶ 13-14; Adkins Dec. ¶ 9.

6. Justin Murdock and William Glavaris, who both grew up in West Virginia, have

been in a loving, committed relationship for almost three years and wish to marry. Declaration

of Justin Murdock (“Murdock Dec.”) ¶ 2; Declaration of William Glavaris (“Glavaris Dec.”) ¶¶

2, 4.

7. Justin has two children from a prior marriage, and he now shares custody of his

children with his former spouse. Murdock Dec. ¶¶ 5,7.

8. Justin and Will wish to get married because it is the only way to indicate the

seriousness and importance of their relationship with one another. Murdock Dec. ¶ 14; Glavaris

Dec. ¶¶ 13-14.

9. Will is estranged from his only family members in West Virginia, and his closest

remaining family member is located in South Carolina (a great aunt). Glavaris Dec. ¶ 11. Justin

and Will both worry who would be permitted to make important medical decisions on Will’s

behalf. Glavaris Dec. ¶ 11; Murdock Dec. ¶ 19.


8/22/2019 3:13-cv-24068 #40


3

10. On a daily basis, Justin and Will are reminded that their inability to marry renders

them “strangers” to each other in the eyes of the law. Murdock Dec. ¶ 20.

11. Nancy Elizabeth Michael and Jane Louise Fenton have been in a loving,

committed relationship for sixteen years and wish to marry. Declaration of Nancy Elizabeth

Michael (“Michael Dec.”) ¶ 2; Declaration of Jane Louise Fenton (“Fenton Dec.”) ¶¶ 2-3.

12. Nancy and Jane have a six-year old son, A.S.M., who was conceived using

assisted reproductive technology. Fenton Dec. ¶ 4; Michael Dec. ¶ 11. Only Nancy is listed on

A.S.M.’s birth certificate, even though Jane has functioned as the boy’s parent since his birth.

Fenton Dec. ¶ 5.

13. Nancy and Jane worry that in an emergency, Jane would not be authorized to

make decisions for A.S.M. Fenton Dec. ¶ 6.

14. Because Nancy and Jane have been unable to get married, they have paid for

alternate — but inferior — protections such as powers of attorney. Fenton Dec. ¶¶ 5-6. Jane must

carry these important documents with her at all times. Fenton Dec. ¶ 5.

15. Nancy and Jane worry about the stigma and discrimination that A.S.M. may be

subjected to because his parents are barred from marrying. Michael Dec. ¶¶ 15, 18-20. He has

already recognized that the law brands Nancy and Jane as “just partners.” Michael Dec. ¶ 18.

16. The harm comes in smaller ways too. Because of the marriage ban, Jane must list

on employment forms that she has no children, which causes her to feel as if she is denying her

own child. Fenton Dec. ¶ 7.

17. Nancy and Jane also lack the financial safety net available to married couples and

their children. Fenton Dec. ¶ 8. Nancy and A.S.M. are unable to receive Jane’s social security

survivor or retirement benefits. Fenton Dec. ¶ 8.


8/22/2019 3:13-cv-24068 #40


4

18. A.S.M., who sues through his parents and next friends Nancy and Jane, does not

have the rights or benefits that accrue to children of married parents. Fenton Dec. ¶ 8.

19. A.S.M.’s financial security is threatened because Nancy and Jane have had to

divert money to pursue alternatives to the protections of marriage, such as guardianship

documents. Fenton Dec. ¶ 5.

20. A.S.M. receives lower-quality health insurance because Nancy and Jane are

unable to qualify for a family plan marriage because they are not married. Fenton Dec. ¶ 8.

21. A.S.M. already recognizes that the State brands his family’s relationship as less

consequential, enduring, and meaningful than those of different-sex parents and their children.

Michael Dec. ¶¶ 18-19.

22. All Adult Plaintiffs and other same-sex couples face numerous harms at the state

level based on their exclusion from the right to marry. There are almost 700 references to

marriage in West Virginia law.1 Adult Plaintiffs and other same-sex couples cannot solemnize

their relationships through state-sanctioned ceremonies, W. Va. Code § 48-2-401; they cannot

have their relationships recorded and recognized as marriages even if they solemnize them in

other jurisdictions, W. Va. Code § 48-2-603; and they lack the ability to safeguard family

resources under an array of laws that protect spousal finances. West Virginia same-sex couples

are denied spousal coverage on health insurance, id. § 5-16-8; benefits for surviving spouses of

public employees, sheriffs, police officers, and firefighters, id. §§ 5-10-24, 7-14D-18, 8-22A-20;

a $2000 tax credit for a surviving spouse, id. § 11-21-16(c); the ability to maintain auto insurance

under the same terms as a divorced or deceased spouse, id. § 33-6-36(a); tax exemptions for

1 See Westlaw search of unannotated West Virginia statutes and the West Virginia Constitutionfor terms “wife,” “husband,” “spouse,” “married,” “marriage,” “marital,” “matrimony,”“widow,” or “widower.” (Dec. 28, 2013) (returning 696 hits).


8/22/2019 3:13-cv-24068 #40


5

transferring a motor vehicle between spouses, id. § 17A-3-4(b)(2); free college education for the

spouse of a military member killed in action, id. § 18-19-3; the automatic ability and priority to

make caretaking decisions in times of medical emergency, id. § 16-30-8; the right for school

teachers to receive full pay while out of work due to a s pouse’s death or serious injury, id. §

18A-4-10(a)(2); the presumption of gift for real property transfers between spouses, id. § 48-29-

202; the right to receive an elective share of a deceased spouse’s estate, id. § 42-3-1; access to an

equitable division of finances in the event a couple separate, id. § 48-7-103; and the ability to

hold a partner accountable for spousal and child support, id. §§ 48-8-101, 48-11-101.

23. West Virginia’s marriage laws afford numerous protections to children of married

parents, including the ability to secure legal recognition of parent-child bonds: an efficient

procedure to adopt a spouse’s child, W. Va. Code §§ 48-22-116, 48-22-301(b)(3); legitimization

of children through marriage, id. § 42-1-6; and the presumption of parentage for children born

into a marriage, id. §§ 16-5-10(f), 48-22-110. West Virginia also makes spouses and parents

accountable for economic support through, for example, obligations of spousal and child support.

Id. §§ 48-8-101, 48-11-101. These rules ensure that children can maintain a relationship with

both spouses, that the best interests of children remain uppermost if parents separate, and that

children receive financial support from their parents, rather than by the State.

24. West Virginia’s marriage ban also renders Adult Plaintiffs and other same-sex

couples unable to benefit from a host of federal rights that turn on marital status. The federal

General Accounting Office reported in 1997 that there are more than 1,000 references in federal

law to marriage, see United States v. Windsor , 133 S. Ct. 2675, 2683 (2013), including laws

pertaining to Social Security, housing, taxes, criminal sanctions, copyright, and veterans’

benefits.


8/22/2019 3:13-cv-24068 #40


6

25. In addition to these tangible harms, Plaintiffs suffer from the harm of being

excluded from the unique social recognition that marriage conveys. The marriage ban makes it

more difficult for A.S.M. and other children of same-sex couples to understand the integrity and

closeness of their own families. Without access to the familiar language and legal label of

marriage, Adult Plaintiffs are unable instantly or adequately to communicate to others the depth

of their commitment, or obtain respect for that commitment, as other do by simply invoking their

married status. Adult Plaintiffs wish to express the nature, depth, and quality of their lifelong

commitment to each other in the way that they, their family, their friends, and society best

understand. See, e.g., McGee Dec. ¶¶ 12-13, 15; Adkins Dec. ¶¶ 7-9; Glavaris Dec. ¶¶ 13, 15;

Murdock Dec. ¶¶ 10, 14; Fenton Dec. ¶ 9; Michael Dec. ¶ 21.

Dated: December 30, 2013

Respectfully submitted,

CASIE JO MCGEE and SARAHELIZABETH ADKINS, et al.

By Counsel:

/s/ John H. Tinney Jr. .THE TINNEY LAW FIRM, PLLCJohn H. Tinney, Jr. (WVSB #6970)Heather Foster Kittredge (WVSB #8543)P.O. Box 3752Charleston, West Virginia 25337-3752Phone: (304) 720-3310Fax: (304) [email protected]@tinneylawfirm.com

LAMBDA LEGAL DEFENSE ANDEDUCATION FUND, INC.Elizabeth L. Littrell ( pro hac vice pending)730 Peachtree Street, N.E.Suite 1070Atlanta, Georgia 30308-1210


8/22/2019 3:13-cv-24068 #40


7

Phone: (404) 897-1880Fax: (404) 897-1884 [email protected]

Karen L. Loewy ( pro hac vice pending)

120 Wall Street, 19

th

Floor New York, New York 10005-3904Phone: (212) 809-8585Fax: (212) [email protected]

Camilla B. Taylor ( pro hac vice pending)105 West Adams, 26th FloorChicago, Illinois 60603-6208Phone: (312) 663-4413Fax: (312) 663-4307

[email protected]

JENNER & BLOCK LLPPaul M. Smith ( pro hac vice pending)Lindsay C. Harrison ( pro hac vice pending)Luke C. Platzer ( pro hac vice pending)R. Trent McCotter ( pro hac vice pending)1099 New York Avenue, NW Suite 900Washington, D.C. 20001-4412Phone: (202) 639-6000Fax: (202) 639-6006 [email protected]@[email protected]@jenner.com

CERTIFICATE OF SERVICE

I hereby certify that on the 30th day of December 2013, I effected service upon counselfor Defendants by electronically filing the foregoing with the Clerk of the Court using theCM/ECF system.

Lee Murray HallSarah A. WallingJENKINS FENSTERMAKER, PLLCP. O. BOX 2688Huntington, WV 25726-2688Phone: (304) 523-2100Attorney For: Karen S. Cole


8/22/2019 3:13-cv-24068 #40


8

Elbert LinJulie Ann WarrenOffice of the Attorney GeneralState Capitol Building 1, Room E-26Charleston, WV 25305Attorney For: State of West Virginia

Charles R. BaileyMichael W. TaylorBAILEY & WYANTP. O. Box 3710Charleston, WV 25337-3710Email: [email protected]: [email protected]

Attorneys For: Vera J. McCormick

/s/ John H. Tinney Jr. .THE TINNEY LAW FIRM, PLLCJohn H. Tinney, Jr. (WVSB #6970)Heather Foster Kittredge (WVSB #8543)P.O. Box 3752Charleston, West Virginia 25337-3752Phone: (304) 720-3310Fax: (304) [email protected]@tinneylawfirm.com

Counsel for Plaintiffs









8/22/2019 3:13-cv-24068 #40


1



HUNTINGTON DIVISION




Plaintiffs,

v.




Defendants,

and

STATE of WEST VIRGINIA, ex rel.

PATRICK MORRISSEY, ATTORNEY

GENERAL,

Intervenor.

No. 3:13-cv-24068

DECLARATION OF CASIE JO MCGEE

I, Casie Jo McGee, hereby declare as follows:

1. The testimony set forth in this Declaration is based on first-hand knowledge,

about which I could and would testify competently in open Court if called upon to do so.

2. I live in Huntington, West Virginia, with Sarah Elizabeth Adkins ("Sarah"), with

whom I have been in a committed relationship for more than three years. We wish to marry each

other.


8/22/2019 3:13-cv-24068 #40


2

3. I am 30 years old, and am an Assistant Professor of Mathematics at Mountwest

Community and Technical College in Huntington. I obtained my bachelor’s degree in English

and Mathematics and a master’s degree in Mathematics from Marshall University, where I was a

Yeager Scholar. I also have a law degree and am admitted to the West Virginia Bar, but have

never worked full time as an attorney. I have been a West Virginian most of my life and was

raised in Ritchie County.

4. Sarah and I met online in March of 2010. We spent hours chatting online with

each other and talking over the phone. We are both avid readers and love to play video games.

We are also both born and raised West Virginians.

5. I knew immediately that Sarah was the person I wanted to spend the rest of my

life with. A week after meeting online, we finally met in person and shortly after, she moved into

my home.

6. I can’t imagine my life without Sarah. She is such a fun and sunny person and has

brought real joy to my life. We met during a low point in my life. I had lost both my father and

stepfather within eighteen months of each other and I was just trying to piece my life back

together. I met Sarah two months after my father died; I was trying to recover from sadness and

death. Meeting and getting to know her really brightened my life. She helped me heal.

7. Sarah is my family. As my family, I want to take care of her. I have health

insurance through my employment with Mountwest Community College, a state employer.

Mountwest Community College provides affordable spousal health insurance to its employees.

However, this is not an option for Sarah and me because we are not permitted to marry. Because

we could not afford to buy insurance separately for Sarah, she was uninsured for a period of time

and therefore did not seek as much preventive healthcare as she might have done otherwise.


8/22/2019 3:13-cv-24068 #40


3

8. Last winter Sarah wasn’t feeling well. She thought she had a sinus infection, so

we went to the nearby clinic. There, they checked her blood sugar which turned out to be at a

dangerously high level of 432. At that emergency visit, we found out Sarah was diabetic. The

doctors urged me to take Sarah to the emergency room immediately. I had to drive because Sarah

could have slipped into a coma at any moment.

9. At the hospital, once Sarah was stabilized, I sat with her by her bedside. I was

really worried about her. I later learned that blood sugar levels in this range could result in

stroke, coma and even death. I almost lost Sarah that day.

10.

Because Sarah was uninsured, we had to pay for the emergency treatment she

experienced that day out of pocket. This is just one of the tangible ways that our inability to

marry has harmed us.

11. In order to help her manage her diabetes, Sarah has started a diet and she also now

exercises. To help her and be supportive, I’ve done the same. As a family, we are in this life

together and so are working together to manage Sarah’s medical condition.

12. Sarah and I have many hopes and dreams for our life together. We would like to

buy a home and start a family. Before meeting Sarah, I never thought I would have children, and

I didn’t even think that I wanted to. Sarah changed all of that for me; I just needed to meet the

right person. Now, I long to start a family together and we look forward to the day when we will

have children. Sarah and I want to marry both to safeguard our relationship to each other and to

protect any children we may have.

13. As exciting as it is to think about starting a family, this goal is significantly

burdened because we are not able to marry or be recognized as married in West Virginia. Sarah

and I would like to conceive a child through the use of reproductive technology and an


8/22/2019 3:13-cv-24068 #40


4

anonymous donor. When married different-sex couples give birth through the use of

reproductive technology, both spouses are legal parents to the child from birth, regardless of

whether they share a genetic relationship to the child. However, since Sarah and I can’t marry,

one of us would inevitably be a legal stranger to our child at birth – even though we are planning

and saving for our child together, and intend to share equally in all parenting responsibilities. It

makes us anxious to think of co-parenting a child who is a legal stranger to one of his or her

parents, unable to be recognized by the government, school and healthcare workers as having

two legal parents.

14.

Both Sarah and I have significant health problems that could make carrying a

child challenging and even dangerous. We are weighing seriously our decision about which one

of us should try to conceive the child. For us, the decision about who will carry the child is a

complicated consideration of health issues, employment issues and finances. However, because

we cannot put Sarah on my employer’s health insurance plan as my spouse, we also have to take

into account Sarah’s lack of access to a plan comparable to the one I have, which has taken the

possibility of Sarah carrying our child completely off the table. If we were married, we would

not have to weigh this additional consideration.

15. West Virginia is home. This is where our family is. We dream of being able to

marry each other before our friends and families in West Virginia, but we would marry in

another state if we thought we could have our marriage respected and recognized here at home.

16. On or about September 18, 2013, Sarah and I appeared in person at the office of

Defendant Cole in Huntington, West Virginia, to seek a marriage license because we wish to

marry each other. We both presented valid forms of identification, provided the required

personal information, and were prepared to pay the required fee and complete a marriage


8/22/2019 3:13-cv-24068 #40


5

application. When we requested a marriage license, an employee of Defendant Cole answered,

“We can't do it because you're both female.”

I declare under penalty of perjury under the laws of the United States of America that the

foregoing is true and correct to the best of my knowledge and ability.


8/22/2019 3:13-cv-24068 #40


1



HUNTINGTON DIVISION




Plaintiffs,

v.




Defendants,

and



GENERAL,

Intervenor.

No. 3:13-cv-24068

DECLARATION OF SARAH ELIZABETH ADKINS

I, Sarah Elizabeth Adkins, hereby declare as follows:



2. I live in Huntington, West Virginia, with Casie Jo McGee (“Casie”), with whom I

have been in a committed relationship for more than three years. We wish to marry each other.


8/22/2019 3:13-cv-24068 #40


2

3. I am 33 years old, and am a student of anthropology at Marshall University in

Huntington, WV. I have lived in the Huntington area nearly all of my life. I was born here. In

fact, my family has looked into genealogical records from my paternal grandmother’s family. To

the best of my understanding, in 1723, an ancestor of my grandmother settled in West Virginia

from Scotland. That man, with the last name Adkins married a woman whose family had been in

West Virginia and she was an Adkins as well.

4. Casie is also a born and raised West Virginian. This was one of the many things

that we learned we had in common when we would spend hours and hours talking to each other

over the phone after we first met. In fact, we were so excited about each other that we somehow

found the time to read each other’s favorite books as a way of getting to know each other better.

5. I love Casie. She is the person I want to spend the rest of my life with. I had been

in a few relationships before, but they didn’t last long or were never really good. With Casie, I

feel like I have found someone who shares my interests, and who values and respects me. It was

Casie who encouraged me to go back to college. Casie helped me to understand my value. With

her by my side, I finally felt like I had a support network and I quit the dead end job I had at that

time, and enrolled in the anthropology program at Marshall with a focus on archaeology.

Without her love and support I couldn’t have ever done it. She knew I could do it and was

rooting me on when no one else was. I am now in my senior year of the program and will be

graduating next year. I plan to go on to graduate school for a master ’s in geography and

archaeological map-making.

6. A couple of years ago, Casie and I went on vacation with a group of friends. Upon

returning home, one of these friends got really sick and had to be rushed to the hospital. Casie

also got sick with the same symptoms as the friend who was hospitalized. I was really scared and


8/22/2019 3:13-cv-24068 #40


3

needed to stay with her in case her condition worsened and I needed to rush her to the hospital. I

called and informed my employer that I would not be coming in, and got a friend to cover my

shift. Later that day, my supervisor called me and asked where I was. I explained that Casie was

really sick and that I needed to be with her. He felt it was an inappropriate reason to call off of

work. When I expressed to him that Casie was really important to me and was my family, he

responded, “It’s not like Casie is your wife or something.” He wrote me up for an inappropriate

call off. Aside from how unfair it was to write me up at a time when my partner was really sick,

this experience was also hurtful. It reminded me that my relationship with Casie is considered

inferior and not as good as others, because we are both women and unable to marry.

7. I am constantly reminded that my relationship is not seen as equal to others. My

best friend has recently met someone and got engaged really quickly. They haven’t known each

other for very long and they will be able to marry. I really wish that Casie and I could do that,

but we can’t, even though we have been together for a longer period of time and have

intertwined our lives together.

8. Our respective families are very supportive of us. My family is very large and

lives nearby. We spend a lot of time with them and they have all embraced Casie. Indeed,

whenever they see me, they expect to see her as well. If for some reason she isn’t with me, they

ask, “Where’s Casie?”

9. Casie and I really want to start a family. My cousin recently had a baby and we

went to visit her at the hospital. It was really sweet to see Casie hold the baby. The baby had

been really fussy, but the moment Casie held him, he stopped crying. Babies just seem to love

her; she’s really good with them. We often talk about all of the things we would want to teach a

child together.


8/22/2019 3:13-cv-24068 #40


4

10. Casie and I would like to buy a home together. We would like a home where our

dog could run around and where we could raise children. I guess you can say that we want the

typical American dream. For us, marriage is part of that dream.

11. But for the fact that Casie and I are of the same sex, we are legally qualified to

marry under the laws of West Virginia. We are not related to each other, and neither of us has a

spouse. On or about September 18, 2013, Casie and I appeared in person at the office of

Defendant Cole in Huntington, West Virginia, to seek a marriage license because we wish to

marry each other. We both presented valid forms of identification, provided the required

personal information, and were prepared to pay the required fee and complete a marriage

application. When we requested a marriage license, an employee of Defendant Cole answered,

"We can't do it because you're both female."




8/22/2019 3:13-cv-24068 #40


1



HUNTINGTON DIVISION




Plaintiffs,

v.




Defendants,

and



GENERAL,

Intervenor.

No. 3:13-cv-24068

DECLARATION OF JUSTIN MURDOCK

I, Justin Murdock, hereby declare as follows:



2. I am 32 years old and a life-long West Virginian. I am currently living in

Huntington, West Virginia, and have been in a committed and loving relationship with William

Glavaris (“Will”) for nearly three years. We wish to marry each other.


8/22/2019 3:13-cv-24068 #40


2

3. I grew up in Wayne County, West Virginia. I work for a business that supplies

mobility products and home and vehicle modification for physically disabled persons that my

family started in 1998. The business is located in Huntington. I am the General Manager.

4. I am a gay man, and have known that I was attracted to men most of my life.

When I was younger, I attempted to ignore and combat these innate feelings, hoping they would

go away. They did not.

5. When I was 20, and before I had acknowledged to myself or others that I am gay,

I married a woman for whom I had great affection, and we subsequently had two children

together. I hoped and prayed that somehow I would find contentment and satisfaction living a

heterosexual life. I did not, and it became unfair to my wife, to our children, and to myself to

continue being married because it felt untrue to who I was and am. We separated in October of

2010 and later divorced amicably. My former spouse and I share custody of our children.

6. My parents were married for about 30 years. Although my parents’ marriage did

not last a lifetime, I grew up understanding that marriage was important, defined a couple as

committed, and was the means by which a couple communicated to their family, their

community and each other the depth of their relationship. I was deeply distressed when I could

not make my own marriage work as I gained a growing understanding and acceptance of my

identity as a gay man. Marriage is part of my values. I want to get it right this time and fulfill my

dream of being married for the rest of my life to Will, the person I love.

7. Will and I live together in a home in the Forest Hills neighborhood of Huntington,

West Virginia. My two children, ages 8 and 9, live with us three or four days a week. We also

live with and care for our pet dog, an 8 year old pug named Penny.


8/22/2019 3:13-cv-24068 #40


3

8. I met Will in January, 2011. I was instantly smitten, and soon fell very much in

love with him. After a few dates, I knew he was the man I wanted to spend my life with.

9. Because I knew that Will was the man I hoped to spend my life with and because

my faith is very important to me, on one of our first dates, I took him to my church, First

Congregational United Church of Christ, to meet my church “family.” I learned that Will was

also a Christian and that faith was important to him. My love for him grew deeper.

10. The feelings I felt and still feel for Will eclipse any love I have ever known. I

believe he is my soul mate, my chosen one, my life’s love. The emotions, attraction and

attachment I feel to him surpasses any connection I have had with anyone else.

11. Will and I feel like a family, and I love the life we share together. During the

days when my children stay with us, we all interact as a family. Together and separately, Will

and I help the children with their homework, take and pick them up from school and

extracurricular activities, church and volunteer activities, eat our meals together, read stories, and

do everything else a family does. My children sometimes refer to Will as “Daddy Two.”

12. My children love and adore Will. The children have other friends with same-sex

parents, and understand that Will and I are a couple and love each other very much. Will loves

them as if they were his own. To watch my children interact with Will is profoundly moving.

13. Will always keeps me on my toes and I love that about him. We complement each

other in many ways. Will engages me, interests me, never bores me, and our life together is

dynamic and wonderful.

14. I want to marry Will because marriage is the only way to communicate how

important Will is to me. Marriage is the only way to communicate to Will and to the world that

we are family to each other. Will is much more than my “boyfriend,” a “roommate,” a


8/22/2019 3:13-cv-24068 #40


4

“significant other” or any of the words unmarried couples are relegated to using. None of those

words signify the depth of our relationship.

15. In January of 2012, I bought a ring and asked Will if he would marry me. He

said yes to the cheers and delight of dozens of our friends with whom we shared the happy

occasion. That was an incredible day.

16. Today, Will is my fiancé, which carries a measure of the significance of our

relationship. It demeans us for our government to make us be perpetual fiancés to each other.

As all engaged couples do, we wish to marry and to refer to each other with the words that

signify our commitment: married, spouse, and husband.

17. West Virginia is our home. My children live here, attend school here, their mother

is here, their relatives are here and their communities are here. My family business is here. For

the sake of my children and to be close to my extended family, I intend to live in West Virginia

for many years to come. Will and I should be able to marry here.

18. The inability to marry leaves our family vulnerable in a range of contexts. Will is

relegated to being treated as a “family friend” in situations large and small, when he should be

viewed as my spouse and as my children’s stepparent.

19. Will was close to his father and grandmother, but both passed away before he and

I met. He does not have a close relationship with surviving family and I have never met any of

them. This causes both of us anxiety given our inability to marry. While we are both young and

healthy, I still worry that if Will should ever become unable to speak for himself, his remaining

family members might prevent me from caring for him, and prevent my children from seeing

him and being by his side. I fear that I would not be able to carry out his wishes if he should pass

away.


8/22/2019 3:13-cv-24068 #40


5

20. Will and I have struggled to identify our family on forms that require us to

indicate our marital status. On a daily basis, in ways both profound and mundane, we are

reminded that West Virginia intentionally relegates us to being strangers to each other. Will and

I long for the day that our family and commitment to each other can be recognized for what it is:

equally loving and devoted, and worthy of the same vital protections granted to other couples

who may marry and their families.

21. Will and I are able and eager to assume the responsibilities of marriage. We meet

all of the requirements to marry under West Virginia law, except for the fact that we are a same-

sex couple:

a. I am 32 years old, and therefore over the age of 18.

b. I am legally competent.

c. I am not related to Will.

d. I am not married to any other person.

22. Will and I have requested a marriage license application three times. In each

attempt, we were prepared to present the requisite identification, fill out the requisite paperwork

and pay the required fee.

23. On the last attempt to seek a marriage license, on or about September 24, 2013, an

employee of the Cabell County Clerk’s office handed us a copy of a letter prohibiting clerks

from issuing marriage licenses or registering marriage licenses of same-sex couples. She told us

“you know we can’t give you a form to fill out.” Will and I were accordingly denied the ability

to obtain a marriage license by the Cabell County Clerk’s office based solely on our sex and

sexual orientations.


foregoing is true and correct.


8/22/2019 3:13-cv-24068 #40


1



HUNTINGTON DIVISION




Plaintiffs,

v.




Defendants,

and



GENERAL,

Intervenor.

No. 3:13-cv-24068

DECLARATION OF WILLAM GLAVARIS

I, William Glavaris, hereby declare as follows:



2. I am 31 years old and a life-long West Virginian. I currently live in Huntington,

West Virginia, and have been in a committed and loving relationship with Justin Murdock


8/22/2019 3:13-cv-24068 #40


2

(“Justin”) for nearly three years. We wish to marry each other. Justin also has provided a

declaration, and we will try not to repeat each other.

3. I am a network engineer working for a company based in Belmont, CA, and I

work from home.

4. I am a gay man. I grew up in West Virginia, and moved to Huntington to

become a student at Marshall University. I have lived in the area ever since.

5. My views on marriage have been fixed since I was a young child. I believe that

marriage is vitally important to reflect the depth of your commitment to your chosen mate.

6.

When I met Justin, I was instantly attracted. Justin was very persistent in

pursuing a romantic relationship, and I soon fell very much in love with him. After a few

months, I knew he was the man I wanted to spend my life with. We each knew there was

something special about the other. On one of our first dates, Justin took me to his church. I was

impressed by the depth of his commitment to his church and faith. I am also a Christian and my

faith is similarly important to me.

7. Among the reasons I love Justin is because he is such a great person, and a great

father. He sets his mind to things and gets them accomplished with a smile. He motivates me to

be a better person. He makes me happy and makes me smile, too. He makes bad days good.

8. His energy is infectious; I love to be around him. We challenge each other and he

is my best friend.

9. I love and adore Justin’s children. I have a close relationship with both of them.

We interact as a family. I am also very close to Justin’s parents and extended family and they

have embraced me as a part of their family. This is very important to me because there are very


8/22/2019 3:13-cv-24068 #40


3

few surviving members of my family. Marriage would allow me to rebuild my family. It would

make me officially a part of Justin’s family.

10. My father died of cancer. We were very close and I know it would have meant a

great deal to him to see me get married. He was very proud of me.

11. I have two sisters living in West Virginia but we are estranged. Other than my

sisters, the closest surviving member of my family is a great aunt in South Carolina. This is

particularly worrying because if something were to happen to me, who would make decisions for

me and take care of me? I would want Justin to be able to make those decisions. Without being

married, Justin most likely wouldn’t be given the power to make important medical decisions on

my behalf, and he may not even be permitted to be by my side. This is very scary to me.

12. The day that the Supreme Court decided the Windsor and Perry cases, I remember

being really happy and crying because I felt like we had taken a huge step toward equality. I was

so happy for all the people who were finally going to be able to have their marriages recognized

by the federal government, but then I felt sad. I felt sad because it still wasn’t an option for Justin

and me.

13. Being able to finally legally marry would be incredible. I cannot express how

important it would be for us. There are no words to explain how it would feel. I want the people

in my state to understand that Justin and I are a couple. We are a family.

14. I am a life-long West Virginian. This is my home, and I love it here. I have

travelled all over the country, but my home is and always will be here. It is important to me that I

be able to marry in my home state and it is important that West Virginia recognize and respect

our relationship the way that straight couples are recognized and respected. Even though our

dream is to marry in our home state, if we were able to travel to another state to marry and return


8/22/2019 3:13-cv-24068 #40


4

home to have our marriage registered and respected here in West Virginia, we would do it

because our need to be legally recognized as a family is such a priority for us. However, we

know that the clerk would refuse to register our out-of-state marriage.

15. Marriage is the only word that could express the depth and importance of my and

Justin’s commitment to each other. “Partner” isn’t enough, it isn’t clear. Only “marriage” will

do.

16. Justin and I are able and eager to assume the responsibilities of marriage. We

meet all of the requirements to marry under West Virginia law, except for the fact that we are a

same-sex couple:

a. I am 31 years old, and therefore over the age of 18.

b. I am legally competent.

c. I am not related to Justin.

d. I am not married to any other person.

17. Justin and I have requested a marriage license application three times. In each

attempt, we were prepared to present the requisite identification, fill out the requisite paperwork

and pay the required fee.

18. On the last attempt to seek a marriage license, on or about September 24, 2013, an

employee of the Cabell County Clerk’s office handed us a copy of a letter prohibiting clerks

from issuing marriage licenses or registering marriage licenses of same-sex couples. Justin and I

were accordingly denied the ability to obtain a marriage license by the Cabell County Clerk’s

office based solely on our sex and sexual orientations.


foregoing is true and correct.


8/22/2019 3:13-cv-24068 #40


1



HUNTINGTON DIVISION




Plaintiffs,

v.




Defendants,

and



GENERAL,

Intervenor.

No. 3:13-cv-24068

DECLARATION OF NANCY ELIZABETH MICHAEL

I, Nancy Elizabeth Michael, hereby declare as follows:



2. I am 43 years old and I live in Saint Albans, West Virginia, with Jane Louise

Fenton (“Jane”), with whom I have been in a loving and committed relationship for more than 16


8/22/2019 3:13-cv-24068 #40


2

years. Jane and I have a son, A.S.M., who is 6 years old. Jane and I wish to marry each other.

Jane also has submitted a declaration, and we will try not to repeat each other.

3. Jane and I own an information technology consulting business together.

4. I was raised in St. Albans, graduated from Marshall University, and have lived in

this area for most of my life.

5. Jane and I met in an online chat room in 1995 and were instant friends. Jane was

living in Oklahoma and I was in Huntington. I thought she was so nice and so funny, I really

enjoyed our conversations. We lost touch for a little while, but several months later, we

“bumped” into each other again online and picked up right where we had left off.

6. Over the course of a few months, our friendship grew into something more. I

realized that I was growing very fond of Jane. In September of 1997, I was out with some friends

for my birthday and I should have been having fun and celebrating, but instead I was miserable.

All I could think about was Jane and I wanted to go home and talk to her. I wished that I was

spending my birthday with her.

7. That night, I called her and told her about my feelings for her. Shortly after, I

bought a plane ticket to Oklahoma, and in October of 1997, I got on a plane for the very first

time in my life. I spent three days with Jane and by the time I was returning home, we were

planning her visit to West Virginia for Christmas. Jane and I both knew at that time that this was

something special and that we wanted to be together. It just felt right.

8. I moved to Oklahoma, to be with Jane, in March of 1998. I wanted Jane to move

to West Virginia, but she had a steady job at Oklahoma State University and I was only working

a temporary job. Moving to Oklahoma was the most practical choice at that time. Jane flew out

to West Virginia to help me pack my things into a U-Haul truck that we drove to Oklahoma.


8/22/2019 3:13-cv-24068 #40


3

9. I found work, alongside Jane, at Oklahoma State University. However, we were

never open about our relationship. We feared discrimination, and therefore did not feel that we

could disclose how important we were to one another. Though a few of our co-workers

eventually knew, most people just assumed that we were roommates. This was difficult and

hurtful. Jane was not my roommate, she was my life partner and I couldn’t tell people about that

for fear that we would lose our jobs.

10. I was quickly approaching 35 years old and felt that if I was going to ever have a

child that I needed to do it soon. Jane and I hadn’t seriously discussed starting a family, so I was

scared that she wouldn’t be on board. I approached her, already in tears, and told her that I

wanted to have a child. Jane was quiet for a minute and to my surprise she responded, “Ok!” I

encouraged her to take some time to think about it because I was really serious and she said

again, “Really… ok!” I was so happy. I really had feared that I was going to miss out on the

experience of being a mother.

11. A.S.M. was conceived through assisted reproductive technology with an

anonymous donor Jane and I selected together. After several heartbreaking failed attempts, we

were overjoyed when we found out I was pregnant.

12. We were really eager to tell everyone that we were expecting. We told our

parents as well as our closest friends. However, because we feared losing our jobs, we waited for

months to tell our supervisor at work. During this time, no one in our office talked out loud about

the fact that I was pregnant, but would quietly congratulate Jane when the supervisor wasn’t

around.

13. When it was no longer possible to hide my pregnancy, I went to my supervisor

and let him know that I was, in fact, pregnant, and that nothing was going to change about my


8/22/2019 3:13-cv-24068 #40


4

work in our office. I couldn’t tell him anything more than that, and I certainly could not mention

that Jane was the baby’s other parent, for fear of us both losing our jobs.

14. I gave birth to a beautiful and healthy baby boy on April 24, 2007. Jane and I

could not have been more thrilled to welcome A.S.M. into our family. Jane and I decided that

we no longer could bear to keep our relationship secret, especially now that we had a child. We

didn’t want A.S.M. ever to feel shame about his family. We needed to be open about the fact that

we were two women raising our son. We decided to move to my hometown of St. Albans, West

Virginia. There, we would be near family and would be able to live openly and be accepted.

15. However, because West Virginia law prevents us from marrying, we fear that our

son will grow up internalizing the message that there is something wrong with his family. We

worry that A.S.M. will feel shame about his family because our government does not believe our

family to be worthy of marriage. It pains us to think that our state brands our family as unworthy

of the dignity and status of marriage, and that our state tells A.S.M. that he and his parents do not

deserve the support for their relationships that other children and their parents receive. We fear

that A.S.M. will feel humiliated by our family being labeled by our government as second-class

and that those feelings of shame will interfere with his sense of our being a close, integrated

family unit just like the other families in our community that he interacts with on a daily basis.

We do not want our son or his family to have less dignity or legitimacy, in his own eyes and the

eyes of many others and under law.

16. We are just like many other families.. We are raising A.S.M. a mile and a half

from the home that I grew up in. He has a two-parent family, he goes to the school that I went to

as an elementary school student, and we go to the same pool in the summer. His life is not any


8/22/2019 3:13-cv-24068 #40


5

different from my life when I was a kid. We live in a traditional neighborhood with other

traditional families. I’m the president of the local school improvement council and a crossing

guard, Jane is the homeroom mom for A.S.M.’s 1st grade class, and we’re both involved in the

parent-teacher organization.

17. Despite how similar we are to the other families in our community, Jane and I are

not treated the same way as other couples because we can’t marry. I want to marry Jane because

I love her and I want our relationship to be respected and protected like everyone else’s.

Marriage means something to us, to our families, and to our community, and it is the only status

that reflects the commitment Jane and I have.

18. Marriage is important to Jane and me as a couple, but it is also really important

for A.S.M. The three of us were together when we heard the news about the Supreme Court

decision in the Windsor case. A.S.M. asked why we were so happy, and I explained to him, “the

law said that maybe one day me and mom could get married,” to which he responded, “instead of

just partners?”

19. A.S.M. understands that we are different. He understands what “marriage” means

and that “partners” is less than “married.” Even at his age, he understands that being married

means being committed, and being in a permanent family. Jane and I want to marry because we

love each other, but we also want to marry because A.S.M. should be able to say that his parents

are married. He should be able to feel the pride and security about his family that our state

currently denies him.

20. It harms our son that Jane cannot be legally recognized as my family, and that our

state denies us all access to laws that establish and protect the parentage of children born to


8/22/2019 3:13-cv-24068 #40


6

married couples. Like Jane, I fear that our familial relationship will be disrespected in times of

crisis, and want to be able to plan a secure future for the three of us.

21. Recognition of our family in West Virginia is the most significant reason why we

want to marry. West Virginia is our home. We love this community. We want to get married by

our pastor, surrounded by our friends and family and surrounded by the West Virginia scenery

we love. It’s a dream that can’t be fulfilled anywhere else.

22. That said, if West Virginia were to allow us to marry in another state and return

home to register our marriage with the county clerk and have our marriage recognized here in

West Virginia, we would gladly do that just so we could be married here in our home state.

However, we know that attempting to do that would be futile. Even if we married in another

state, our marriage would receive no respect under West Virginia law.

23. On or about September 19, 2013, Jane and I appeared in person at the office of

Defendant McCormick in Charleston, Kanawha County, West Virginia, to seek a marriage

license because we wish to marry each other. We both presented valid forms of identification,

provided the required personal information, and were prepared to pay the required fee and

complete a marriage application. When we requested a marriage license, an employee of

Defendant McCormick asked, "Where is your groom?" We explained that we wanted to marry

each other, to which she responded, “That’s not recognized in the State of West Virginia. There’s

nothing we can do here.”




8/22/2019 3:13-cv-24068 #40


1



HUNTINGTON DIVISION




Plaintiffs,

v.




Defendants,

and



GENERAL,

Intervenor.

No. 3:13-cv-24068

DECLARATION OF JANE LOUISE FENTON

I, Jane Louise Fenton, hereby declare as follows:



2. I live in Saint Albans, West Virginia, with Nancy Elizabeth Michael (“Nancy”),

with whom I have been in a loving and committed relationship for more than 16 years. Nancy

and I have a son, A.S.M., who is 6 years old.


8/22/2019 3:13-cv-24068 #40


2

3. Nancy and I wish to marry each other. We love each other and want our

relationship to be fully recognized and protected.

4. We also wish to marry because of what it would mean for our son, A.S.M. Nancy

and I decided together to bring A.S.M. into our family. We planned together for the pregnancy,

using assisted reproductive technology and an anonymous donor, and Nancy and I have co-

parented him since his birth. When A.S.M. was born, Nancy and I gave him a middle name that

is very special to my family. It ties him to the five generations of Fenton men before him who

have had that same middle name. It’s a tradition that I was really happy and proud to have been

able to continue.

5. Even though I have been A.S.M.’s parent in every way, I am not legally

recognized as his parent, nor he as my child. Only Nancy is listed on A.S.M.’s birth certificate.

Because Nancy and I are not permitted to marry, we were told that West Virginia law does not

permit me to adopt A.S.M. In an attempt to safeguard my relationship to our son, we have paid

for expensive, yet inadequate protections such as powers of attorney for healthcare and

paperwork to make me a legal guardian to A.S.M. While these steps have helped to clarify that I

am authorized to make certain decisions for my son, we must remember to carry important legal

documents wherever we go and we remain vulnerable to misunderstandings, blatant refusal to

recognize us, or disrespect of our parent-child relationship. Additionally, these legal papers were

costly, and we would have preferred to put the money toward other child-centered expenses.

6. Marriage would provide our family a much needed sense of security. We often

fear that our family structure will not be understood or respected in various situations when

recognition of our familial relationships is vital. Being a two-mom family without the benefit of

marriage, we are required to take a lot of steps to ensure that our family will be respected. For


8/22/2019 3:13-cv-24068 #40


3

example, when planning for the birth of A.S.M., we clarified with the hospital beforehand that

we were a lesbian couple, that we were the two parents of the child we were expecting and that

they needed to understand that. We made sure they had copies of our medical powers of

attorney, and emphasized over and over that I was to be recognized as Nancy’s partner and that I

was to be recognized as our child’s other parent. As much as we tried to prepare and clarify that

we were equal co-parents to the child Nancy was carrying before his birth, there was a risk and a

fear that the medical personnel would ignore our paperwork and deny me the ability to be treated

as family during the birth of our son and afterward. We felt very vulnerable. We always worry

that in an emergency, I will not be recognized as A.S.M.’s parent or even family member, or

otherwise as a person authorized to make medical decisions for him.

7. I recently started a new job and was filling out tax forms. When asked how many

children I had, I had to select “0” because I knew that my relationship to A.S.M. wasn’t

recognized. Being forced to deny my child felt indescribably horrible, like someone had stabbed

me.

8. Because West Virginia law bars Nancy and me from marrying, we and our son

lack the financial safety net available to married couples and their children. For example, we

were not able to afford to purchase a separate insurance plan for Nancy for some time, and the

plan that we could afford to buy for A.S.M. is not very good. Were we married, our family

would have superior access to health care through health insurance coverage. As well, we live

with the anxiety of knowing that Nancy and A.S.M. do not have access to survivor benefits if

something were to happen to me. As a former employee of Oklahoma State University I have

retirement benefits that I could pass on to a spouse or children. I would also like for Nancy and


8/22/2019 3:13-cv-24068 #40


A.S.M. to receive Social Security survivor benefits my spouse and child would receive. We wish

to marry in part so that Nancy and A.S.M. have greater financial security.

9. Aside from all of the very real and tangible benefits marriage would bring to our

family, it is also really important for the simple reason that Nancy is the love of my life. She has

helped me to be the person that I am today. She is my family. My best days are when we have

to share a car so we can be together the whole time. I would love to be able to marry her,

surrounded by our friends and family, most importantly A.S.M., and in the place that we

consider home.

10.

On or about September 19, 2013, Nancy and I appeared in person at the office of

Defendant McCormick in Charleston, Kanawha County, West Virginia, to seek a marriage

license because we wish to marry each other. We both presented valid forms of identification,

provided the required personal information, and were prepared to pay the required fee and

complete a marriage application. When we requested a marriage license, an employee of

Defendant McCormick asked, "Where is your groom?" We explained that we wanted to marry

each other, to which she responded, “That’s not recognized in the State of West Virginia.

There’s nothing we can do here.”




Date post:	08-Aug-2018
Category:	Documents
Upload:	equality-case-files
View:	215 times
Download:	0 times

3:13-cv-24068 #40

Documents