Wednesday, April 3, 2013

Marriage as a Constitutional Issue and a Matter of Public Policy I


1.  Marriage, as a legal matter, is a civil contract between two adult individuals.

I want to start off this rant on marriage from this basic conclusion.  I see it as, ultimately, controlling of the entire contemporary debate over same-sex marriage, in the same sense that it could have been held to be controlling in past debates about interracial marriage.  Marriage is a civil contract entered into by two adults, with standing to enter into legal contracts, conferring on both a set of privileges and responsibilities relative to the accumulation and distribution of property/wealth and income and the guardianship of mutual biological or adopted offspring.  In this sense, marriage is only tangentially related to sexuality and human reproductive processes, by virtue of the connection between the civil marital contract and guardianship of children.  By contrast, legally it has nothing whatsoever to do with love or with a broader institution of monogamous pair bonding or with any other social, physiological, or psychological process that we customarily associate with intimate interpersonal relationships.  Beyond its connection to the guardianship of offspring, it is generally no different than civil contracts between two individuals regarding the transfer of ownership rights to real estate, the extension of credit/financing to purchase of goods and services, or adoption agreements on non-biologically related children.  The common thread between each of these contractual forms, mediated by the state and/or by private third parties, is that two parties are brought together by mutual consent to enter into an agreement by which each party will accept certain legally enforceable responsibilities and obtain certain legally enforceable privileges.  For that matter, the sort of explicit contract apparent in marriage is no different, in its generalities, than the implicit contract between an employer and employee in an at-will employment context, at least under circumstances in which the privileges and responsibilities of the two parties have not been legally circumscribed by, say, child-labor laws. 

            Having argued that, as a species of civil contract, marriage is no different from any other civil contract entered by two mutually consenting adults, in its particulars, a marriage contract convey a long list of legally enforceable economic and non-economic benefits, such as joint access to insurance policies, joint benefits from annuities and government sponsored entitlement programs (e.g. Social Security, Medicare), and joint parental rights in making decisions regarding the care of biological and non-biological/adopted offspring.  In a more general sense, married individuals enjoy the benefits apparent in pooling two income streams, facilitating enhanced accumulations of property and, especially, real estate.  For these reasons, legal reinterpretations of marriage enjoy a practical relevance that transcends that of other civil contracts.

            There are clearly practical issues that need to be considered in regard to the individuals entering into a marriage contract.  First, at what age should individuals be capable of entering into marriage?  In this sense, I would question the larger conceptual issue of an “age of majority” as it pertains not only to marriage but also to voting rights, military service, criminal prosecutions, and a long list of other issues.  There is something distinctly arbitrary in the conclusion that individuals, at the age of eighteen, should be legally capable of assuming responsibility in these areas.  We need more practical criteria to discern when an individual is capable of assuming adult responsibilities, which might entail some measure of legal determination.  On the other hand, lacking the legal specification of any other meaningful criterion to judge the practical/literal maturity of an individual, we are left with an age-based criterion. 

            Beyond age, there is, additionally, the practical question of why just two individuals?  Why not incorporate marriage contracts involving three or more individuals?  What about polygamous and polygynous (i.e. one male, multiple females) marriage contracts?  To my knowledge, polygamous and polygynous marriages are not allowed anywhere in the U.S.  At least in certain circumstances, moreover, entering into a marriage contract with another individual while another marriage contract with another individual remains in force (i.e. bigamy) may be criminally punishable, especially if the bigamous individual enters into the second marriage contract without the knowledge of one or both spouses.  With regard to my own state (Massachusetts), no civil or criminal penalties appear to be specified in the case of bigamy, other than the legal voiding of the second marriage (I may be mistaken on this, but you are welcome to check: http://www.malegislature.gov/Laws/GeneralLaws/PartII/TitleIII/Chapter207).  In any case, the issues involved in civil marital polygamy and polygyny deserve serious consideration as matters of legal policy.  Precisely, is there a good reason why a political jurisdiction should not want to allow the simultaneous civil marriage of more than two individuals?  Admittedly, I do not know what the answer is to this question.  It is a point for debate, especially with regard to issues concerning parental rights.  As I suggest above, I can see nothing, in and of itself, connecting the civil contract of marriage to monogamous pair bonding.  However, my meaning above concerned monogamy as a sexual practice rather than monogamy as a civil/legal contractual condition.  Insofar as marriage is just a contract like many other contracts, I cannot see why polygamous (multiple males, multiple females) marriage contracts should be prohibited.  I do not like the idea of polygyny for the simple reason that harem building connotes, to me, a degrading aspect toward women.   On the other hand, polygamy configured in terms of some sort of communal marriage arrangement between multiple individuals might hold some merit (e.g. to establish extended, non-biological claims to parental rights by surrogates).  Like any other contractual legal matter, this is a policy question that should be resolved democratically through the legislative or general referendum process.  In general, marriage contracts are creatures of public policy, open to democratic redefinition at the whim of a polity – there is nothing fixed or transcendental about the marriage contract, the responsibilities it imposes, or the privileges it confers.       

2.  Marriage has NOTHING to do with religious/sacramental matrimony. 

In asserting this conclusion, I want to underscore the point that allowing religious ecclesiastical officials to sign legal documentation certifying that two parties have entered into a civil contract of marriage, upon completion of a matrimonial ceremony, is, in my view, a terrible mistake, promoting the conflation of a civil contract with a religious ritual.  This conflation is at the root of contemporary debates over same-sex marriage that could be, to a significant extent, resolved if civil marriage documentation strictly required the written certification of a public officials (e.g. a municipal clerk, judge, or magistrate).  It is one thing for the Catholic Church to refuse to allow priests to celebrate the sacrament of holy matrimony for two same-sex individuals.  It is a wholly different matter for a city clerk or magistrate to disallow the same two individuals from entering into a civil marriage contract, under the legal terms outlined by a state.  The former case implicates the constitutional liberty of the Catholic Church to decide, based on theological principles, who can participate in sacramental matrimony.  The latter case is a matter of civil law, subject, at least in some way, to state or federal constitutional provisions governing the ability of individuals to freely enter into civil contracts.  To the extent that, practically speaking, we conflate holy matrimony and the civil marriage contract, the Catholic Church is quite right to question whether its religious liberties will be violated in states where same-sex individuals enjoy permission to enter into marriage contracts.  Clearly, there needs to be a practical distinction between unions sanctified “in the eyes of God” and contractual agreements between consenting adults, legitimated by public officials in the eyes of legally competent witnesses.  Ecclesiastical officials should not be capable of officiating over processes through which a marriage contract is publicly legitimized.

            Having made this point, the present “crisis” in the institution of civil marriage (i.e. rates of divorce over fifty percent nationally) may, likewise, reflect a crisis in the religious/sacramental institution of matrimony (i.e. increased requests for annulments of matrimonial unions).  This is something that churches need to take seriously, but same-sex civil marriages do not constitute the root cause of such a crisis.  Rather, any problems with matrimony are innately intertwined with the role of religion in the everyday lives of followers, their comprehensions of the responsibilities entailed for partners within the institution of holy matrimony (e.g. toward sexuality, reproduction, and the raising of children), and the interaction between religious/spiritual living and the everyday compulsions of economic processes (e.g. work, consumption), non-religious cultural processes (e.g. the effects of mass media), and the physical and emotional needs of involved individuals (e.g. sexual desires).  Religious organizations need to address their problems with holy matrimony among their followers to the exclusion of broader political discussions on civil marriage. 

In these circumstances, religious thinkers might be on to something when they argue that the institution of same-sex civil marriage undermines the institution of holy matrimony (incrementally), but only insofar as it is contained within a broader everyday cultural reality lived by the adherents to religion (i.e. incongruities between scriptural admonishment forbidding same-sex relations and the presence of constitutional liberties to enter into same-sex marriage).  It can, further, be argued that, insofar as civil society is constituted, in part, by the free practice of religion and that religious practices shape the views of individuals toward public policy, there is no practical way to separate church from state.  I am going to concede this point – the boundary line between church and state is invariably a question to resolve by means of democratic deliberation and, in no sense, a rigorously enforceable constitutional matter (as if there were any rigorously enforceable constitutional matters!).  On the other hand, if we do not begin discursively from the proposition that church and state exist as distinct institutions, then we risk collapsing theological questions into political policy matters in a way that threatens the religious liberty of the larger polity.  It is in this sense that I mean to argue that we need to separate marriage from holy matrimony in order to prevent the two institutions from contaminating each other to the detriment of both. 

3.  Love is distinct from sexuality, sexuality is distinct from processes of human reproduction, human reproduction is distinct from functional parenthood, and all four are distinct from the contractual institution of civil marriage.

My purpose so far in this rant has been to strip the institution of civil marriage as bare as I can!  My initial conclusion, for example, sought to paint marriage as something akin to a business contract – a piece of paper conferring a set of legally enforceable privileges and exacting a set of legally enforceable responsibilities between two consenting adults.  States can enforce compliance with a set of defined standards attached to the institution of marriage – they cannot enforce the notion that there will be “wedded bliss.”  Love, however it is defined, enjoys no connection to the institution of civil marriage.  Rather, love, as an emotional process characterizing the relationship of two individuals, might be a motive for entering into marriage, especially in relation to the intention of the individuals to mutually engage in parenthood/guardianship of children, but there is no meaningful way for a state to stop two mutually consenting adults who do not love each other from entering into a marriage contract for reasons other than an emotional connection and a emotionally-centered commitment to sexual monogamy. 

            Moreover, the enormity of the concept of love implies that it is irreducible to relationships that have a sexual component.  Some emotional relationships characterized by love between individuals involve sexual processes and the satisfaction of sexual desires, but others (e.g. some child-parent relationships, “platonic” friendships) generally do not involve sexuality.  Expanding on the concept of sexuality and sexual relationships, it is conceivable that certain monogamous sexual relationships between individuals do not involve love (e.g. individuals in arranged marriages), while, in other cases, relationships involving mutually acknowledged polygamous sexual practices by two individuals might be characterized by love (e.g. a sexually open relationship between two individuals inside or outside of a legal marital or practical cohabitational bond). 

            Going further, sexual practices are irreducible to heterosexual pairings.  It is at least conceivable to graft the sorts of relationships between love and monogamous or polygamous sexual practices onto homosexual practices.  Taken as a whole, sexual practices are, thus, irreducible to biological human reproductive processes, on the one hand, because homosexual practices eliminate the possibility of human reproduction without a heterosexual surrogate relationship, and, on the other hand, because access to and utilization of reliable birth control technologies functionally separates heterosexual practices from conception through coitus (among the wider range of possible, non-coital heterosexual practices).  In any such case, lacking the utilization of birth control technologies to inhibit a pregnancy, it should be self-evident that the incidence of biological human reproduction bears no connection to the institution of civil marriage.  Teenagers who possess no capacity to legally enter into a marriage contract often experiment with unprotected heterosexual activity with the obvious possible consequences.  “Abstinence only until marriage” constitutes a political position, and a distinctly unpopular among young adults in the U.S., rather than a legally enforceable policy to restrict heterosexual practices connected to human reproduction to marital relationships. 

Finally, there is no axiomatic connection between human reproduction, as a biological process culminating in a live birth, and the processes of parenting, guardianship, and nurturing of children.  If most legal guardians of children in the U.S. are simultaneously biological parents, the institutions of foster parenting, legally-sanctioned adoption, and, even, stewardship of minors by state agencies tasked with guarding the welfare of children against negligent or abusive parents facilitate the creation of a conceptual distinction between human reproduction and parenting.  This conceptual distinction is important in approaching the larger relationship of parenting and civil marriage.  Following the arguments of the defenders of traditional marriage (e.g. ProtectMarriage.com, one of the private organizations defending California’s Proposition 8 in Hollingsworth v. Perry, currently being adjudicated by the U.S. Supreme Court), an underlying purpose of civil marriage is to reinforce the traditional biological conceptions of parenthood (one father, one mother).  Acknowledging that there is abundant evidence supporting the relevance to personal development of having multiple nurturing parental resources in the lives of children, there is no axiomatic connection between the existence of a marriage contract (i.e. a piece of legal documentation conferring privileges and responsibilities on two mutually consenting adults) and the functional performance of parental nurturing by two individuals, with or without a biological connection to the children for whom they are acting as guardians and mentors.  While I must confess that I have not significantly researched the subject, it is unclear to me that there is any fundamental distinction in parenting skills or outcomes for cohabitational partners with or without a marital contract beyond outcomes resulting from the existence of disproportional parental privileges to non-biologically parenting figures in mixed relationships (i.e. one biological parent plus a non-biological partner/spouse). (For an alternative perspective on this subject, see Moore et al. “Marriage from a child’s perspective: How does family structure affect children, and What can we do about it?” at: http://www.childtrends.org/files/marriagerb602.pdf.  This article has been used as an argument against gay marriage and gay parenting, contrary to the intentions of the authors.  Whatever theses intentions are, I do not find their argument intrinsically convincing.)   

Moreover, the comparative value to the personal development of children of divergent heterosexual, homosexual, or other (e.g. polygamous/communal) parental structures appears to be an open question.  Citing a number of different research studies on gay and lesbian parents, Pappas (see “Gay Parents Better Than Straight Parents? What Research Says,” at: http://www.huffingtonpost.com/2012/01/16/gay-parents-better-than-straights_n_1208659.html) suggests that adoptive homosexual couples are often more willing than adoptive heterosexuals to adopt children across racial groupings, children at older ages where placement is often difficult, and children with special physical or emotional needs.  She, likewise, cites evidence that children of gay and lesbian couples demonstrate no significant developmental differences from children of heterosexual couples, with the possible exception that children of homosexual parents tend to display greater empathy and tolerance than children of heterosexual couples.  Pappas’ evidence seems supported, at least in part, by a 2004 policy statement from the American Psychological Association (APA) (see “Sexual Orientation, Parents, & Children,” at: http://www.apa.org/about/policy/parenting.aspx), which states that “the results of research suggest that the development, adjustment, and well-being of children with lesbian and gay parents do not differ markedly from that of children with heterosexual parents.” 

Being fair to the other side, contrary perspectives on parenting by gay and lesbian parents have been academically formulated and utilized as arguments against both gay marriage and extension of privileges to adoption of children for gay couples.  Most recently, an article from the New Family Structures Study by University of Texas sociologist Mark Regnerus (see “How different are the adult children of parents who have same-sex relationships? Findings from the New Family Structures Study,” in Social Science Research (41:4, 752-770), at: http://www.sciencedirect.com/science/article/pii/S0049089X12000610) suggests that, under a range of quality of life indicators measured by dichotomous, continuously distributed, and event-count outcome variables, adult children of gay or lesbian parents fair worse than adult children of “intact biological families” (i.e. one biological mother, one biological father), especially children of lesbian mothers.  Proceeding from these results, Regnerus advances the conclusion, in relation to the analysis of his data sample, that family structures are pertinent to outcomes in the development of children, that intact biological families appear to provide the best possible family structure relative to the development of children, and that declines in the share of intact biological families will heighten social dependence on “public health organizations, state and federal public assistance, psychotherapeutic resources, substance abuse programs, and the criminal justice system,” by implication inflicting tangible social costs.  For the simple reason that his conclusions appear to not only depreciate the value of parenting by gay parents but, more importantly for my purposes, establish a definitive functional connection between the marriage contract and parental outcomes, I want to consider some problems with Regnerus’ argument.

First, it is apparent that various organizations opposing same-sex marriage have employed Regnerus’ argument in order to argue that a connection exists between the passage of state laws defining marriage as a union of one man and one woman and the interest of states in supporting intact biological families as the best possible family structure for child developmental outcomes.  Precisely, Charles Cooper, the attorney representing proponents of California’s Proposition 8 in Hollingsworth v. Perry, employs this connection as a basis against which to argue that, in the lexicon of constitutional law, a rational individual might conclude that a linkage existed between the maintenance of a gender specific definition of marriage and the interest of states in protecting the welfare of children and that, against this standard of rationality, California voters were entitled to retain a gender specific definition of marriage as a use of power emanating from their capacity to exercise general self-government through the referendum process.  I want to consider this constitutional issue further below, but for my purposes here, the problem concerns the partisan/rhetorical use of Regnerus’ analysis. 

NO statistical argument worth being published is value neutral.  Any analyst who assembles cross-sectional, time-series, or panel data and manipulates them through an ordinary least squares regression, a binominal probit analysis, or a vector auto-regression analysis is doing so because she has some partisan agenda to uphold and wants to put numbers together to smash her argument over the heads of her opponents.  I do not know anything about Regnerus’ politics, but I can only guess that he is a political conservative, probably connected to the cultural/religious right, and supportive a priori of traditional conceptions of marriage.  Notwithstanding the caveats he posits in his analysis regarding planned families by homosexual couples and their potential to achieve positive developmental outcomes for children, the responses by adult children of homosexual parents that form the basis for his analysis are overwhelmingly taken from individuals from broken heterosexual marriages where one parent subsequently experimented with same-sex relationships.  Regnerus' data set includes, by his own admission, almost no adult children raised by homosexual partners in a planned familial context.  As the American Sociological Association (ASA) notes in its amicus curiae brief in Hollingsworth v. Perry (see “Brief Amicus Curiae American Sociological Association in Support of Respondent Kristin M. Perry and Respondent Edith Schlain Windsor” at: http://www.asanet.org/documents/ASA/pdfs/12-144_307_Amicus_%20%28C_%20Gottlieb%29_ASA_Same-Sex_Marriage.pdf), this analysis does not, in any meaningful way, address the outcomes of parenting by actual same-sex couples (i.e. situations where a same-sex couple adopts a child or raises a child conceived through in-vitro fertilization) and the methodologies employed by Regnerus (i.e. separating children from intact biological families from children of opposite-sex unions resulting in divorce, step parenting, and single parenting) generate misleading conclusions about the value of same-sex parenting relative to heterosexual parenting. 
Acknowledging the relative validity of both Regnerus’ position (in its own terms) and that of ASA in contesting his argument, the overall question here concerns not the truth of either side but the persuasiveness of divergent arguments from divergent partisan perspectives.  For my purposes, the ASA position carries the day in this regard – the capacity of two (or more) individuals to serve as mutually loving and nurturing parents, mentors, and guardians (whether unified by a marriage contract or not) in the lives of children trumps any requirements for biological connections or gender specificities in the legitimization of marriage.  In this regard, moreover, the actual existence of a marriage contract is secondary.  The grand arbiter of both positions will, however, be a majority on the U.S. Supreme Court (at least with respect to the final judgment in Hollingsworth v. Perry).

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