Law School Case Brief
Rappaport v. Katz - 380 F. Supp. 808 (S.D.N.Y. 1974)
The United States Constitution and statutes do not expressly or out of any necessity impose on the federal courts the duty and responsibility of supervising the mode of dress in which an intended groom and bride may take their marriage vows in the office of the City Clerk of The City of New York.
Two couples, one having been married by the clerk and one who had been planning marriage and was looking forward to a ceremony to have been performed by the city clerk, filed this action complaining that they were subjected, or were to have been subjected, to dress guidelines promulgated by the city clerk to have been observed for wedding ceremonies at city hall, including the exchange of a ring or rings. Those guidelines were said to deprive them of due process of law in violation of their constitutional rights. Both parties filed motions for summary judgment.
Should federal courts supervise marriage forms and procedures in city clerk’s offices?
The Court held that the forms and the degree of decorum at weddings in the city clerk's office did not sufficiently justify provoking a federal-state conflict. According to the Court, federal judgment had too much to do to become involved in that type of dispute which was best and most appropriately resolved by the State and the city council to whom the city clerk was responsible. Hence, summary judgment was granted in favor of the clerk.
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