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NOS . 14-556, 14-562, 14-571, 14-574

In the Supreme Court of the United StatesIn the Supreme Court of the United StatesIn the Supreme Court of the United StatesIn the Supreme Court of the United StatesIn the Supreme Court of the United States JAMES OBERGEFELL, et al ., Petitioners ,

v. RICHARD HODGES, DIRECTOR, OHIO DEPARTMENT

OF HEALTH, et al ., Respondents .

VALERIA TANCO, et al ., Petitioners , v.

BILL HASLAM, GOVERNOR OF TENNESSEE, et al ., Respondents .

APRIL DEBOER, et al ., Petitioners , v.

RICK SNYDER, GOVERNOR OF MICHIGAN, et al ., Respondents .

GREGORY BOURKE, et al ., Petitioners , v.

STEVE BESHEAR, GOVERNOR OF KENTUCKY, et al ., Respondents .

On Writs of Certiorari to the United States Court of Appeals for the Sixth Circuit

BRIEF OF AMICUS CURIAE AMERICAN SOCIOLOGICAL ASSOCIATION IN SUPPORT OF PETITIONERS

Carmine D. Boccuzzi, Jr. (Counsel of Record)

Mark A. LightnerGrant A. Bermann

Alexandra EberCLEARY G OTTLIEB S TEEN & H AMILTON LLPOne Liberty PlazaNew York, NY 10006(212) [email protected]

Counsel for Amicus Curiae

Becker Gallagher · Cincinnati, OH · Washington, D.C. · 800.890.5001

mailto:[email protected]:[email protected]


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TABLE OF CONTENTS

TABLE OF AUTHORITIES . . . . . . . . . . . . . . . . . . . ii

INTEREST OF AMICUS CURIAE . . . . . . . . . . . . . 1

SUMMARY OF ARGUMENT . . . . . . . . . . . . . . . . . . 2

ARGUMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

I. THE SCHOLARLY CONSENSUS IS CLEAR AND CONSISTENT: CHILDREN OF SAME-SEX PARENTS FARE JUST AS WELL

AS CHILDREN OF DIFFERENT-SEXPARENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

II. CLAIMS THAT CHILDREN FARE BETTERWITH DIFFERENT-SEX PARENTS THANW I T H S AM E - S E X PAR E NT S AR EUNSUPPORTED BY SOCIAL SCIENCERESEARCH . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

A. STUDIES EXAMINING DIFFERENT-SEXCOUPLES CANNOT BE USED BYMARRIAGE OPPONENTS TO MAKECLAIMS ABOUT SAME-SEX PARENTS

AND DO NOT UNDERMINE THECONSENSUS . . . . . . . . . . . . . . . . . . . . . . . . 14

B. THE REGNERUS PAPERS DO NOTSUPPORT CONCLUSIONS ABOUTCHILDREN RAISED BY SAME-SEXPARENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27


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TABLE OF AUTHORITIES

CASES

Atkins v. Virginia ,536 U.S. 304 (2002) . . . . . . . . . . . . . . . . . . . . . . . 1

Bostic v. Schaefer ,760 F.3d 352 (4th Cir. 2014) . . . . . . . . . . . . . . . . 4

Craig v. Boren ,429 U.S. 190 (1976) . . . . . . . . . . . . . . . . . . . . . . 20

DeBoer v. Snyder ,973 F. Supp. 2d 757 (E.D. Mich. 2014) . . . . . 2, 25

DeBoer v. Snyder ,772 F.3d 388 (6th Cir. 2014) . . . . . . . . . . . . . . . . 2

Hall v. Florida ,134 S. Ct. 1986 (2014) . . . . . . . . . . . . . . . . . . . . . 1

Kitchen v. Herbert ,755 F.3d 1193 (10th Cir. 2014) . . . . . . . . . . . . . . 4

Price Waterhouse v. Hopkins ,490 U.S. 228 (1989) . . . . . . . . . . . . . . . . . . . . . . 20

Roper v. Simmons ,543 U.S. 551 (2005) . . . . . . . . . . . . . . . . . . . . . . . 1

OTHER AUTHORITIES

Abbie E. Goldberg & JuliAnna Z. Smith, Predictorsof Psychological Adjustment in Early Placed

Adopted Children with Lesbian, Gay, and Heterosexual Parents, 27 Journal of FamilyPsychology 431 (2013) . . . . . . . . . . . . . . . . . . 9, 15


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Alicia L. Fedewa & Teresa P. Clark, Parent Practices and Home-School Partnerships: A Differential Effect for Children with Same-SexCoupled Parents? , 5 Journal of GLBT FamilyStudies 312 (2009) . . . . . . . . . . . . . . . . . . . . . . 6, 8

American Community Survey Data on Same SexCouples (2013), United States Census Bureau,available at https://www.census.gov/hhes /samesex/files/ssex-tables-2013.xlsx . . . . . . . . . . 3

Andrew J. Perrin, Are Children of Parents Who Had

Same-Sex Relationships Disadvantaged? A Scientific Evaluation of the No-Differences Hypothesis , 17 Journal of Gay & Lesbian MentalHealth 327 (2013) . . . . . . . . . . . . . . . . . . . . . . . 25

Brent Miller et al., Comparisons of Adopted and Non-Adopted Adolescents in a Large, Nationally Representative Sample , 71 Child Development1458 (2000) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Charles A. Nelson & Michelle Bosquet, Neurobiology of Fetal and Infant Development: Implications for Infant Mental Health , in Handbook of Infant Mental Health (C.H. ZeanahJr. ed., 2d ed. 2000) . . . . . . . . . . . . . . . . . . . . . . 18

Charlotte J. Patterson & Jennifer L. Wainright, Adolescents with Same-Sex Parents: Findings from the National Longitudinal Study of Adolescent Health , in Adoption by Lesbians andGay Men: A New Dimension in Family Diversity(David M. Brodzinsky & Adam Pertman eds.,2012) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-12

https://www.census.gov/hheshttps://www.census.gov/hhes


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Daniel Potter, Same-Sex Parent Families andChildren’s Academic Achievement , 74 Journal ofMarriage & Family 556 (June 2012) . . . . . . . . . . 6

Darren E. Sherkat, The Editorial Process and Politicized Scholarship: Monday Morning Editorial Quarterbacking and a Call for Scientific Vigilance , 41 Social Science Research1346 (2012) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

David Popenoe, Life Without Father: Compelling New Evidence that Fatherhood & Marriage Are

Indispensable for the Good of Children & Society(1996) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19, 20

D. Paul Sullins, Child Attention-Deficit Hyperactivity Disorder (ADHD) in Same-Sex Parent Families in the United States: Prevalenceand Comorbidities , 6 British Journal of Medicine& Medical Research 987 (Feb. 2015) . . . . . . . . . 10

D. Paul Sullins, Emotional Problems AmongChildren with Same-sex Parents: Differenceby Definition , 7 British Journal ofEducation, Society & Behavioural Science 100(Feb. 2015) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Douglas W. Allen, High School Graduation Rates Among Children of Same-Sex Households , 11Review of Economics of the Household, 635(Sept. 2013) . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-8

Douglas W. Allen et al., Nontraditional Familiesand Childhood Progress Through School: AComment on Rosenfeld , 50 Demography 955

(June 2013) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7


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Eleanor Maccoby, The Two Sexes (1998) . . . . . . . . 18

Elizabeth Marquardt et al., Institute for American Values, My Daddy’s Name is Donor: A New Study of Young Adults Conceived Through Sperm Donation (2010) . . . . . . . . . . . . . . . . 14-15

Fiona Tasker, Lesbian Mothers, Gay Fathers andTheir Children: A Review , 26 Developmental andBehavioral Pediatrics 224 (June 2005) . . . . . . . . 9

Gary J. Gates, LGB Families and Relationships:

Analyses of the 2013 National Health Interview Survey , The Williams Institute (Oct.2014), http://williamsinstitute.law.ucla.edu /wp-content/uploads/lgb-families-nhis-sep-2014.pdf . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4

Gary J. Gates, LGBT Parenting in the United States , The Williams Institute (Feb. 2013),http://williamsinstitute.law.ucla.edu/wp -content/uploads/LGBT-Parenting.pdf. . . . . . . . . 3

Gary J. Gates et al., Letter to the Editor and

Advisory Editors of Social Science Research , 41Social Science Research 1350 (2012) . . . . . . . . . 25

Jennifer L. Wainright & Charlotte J. Patterson, Delinquency, Victimization, and Substance Use Among Adolescents with Female Same-Sex Parents , 20 Journal of Family Psychology 526(2006) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Jennifer L. Wainright & Charlotte J. Patterson, Peer Relations Among Adolescents with Female Same-Sex Parents , 44 Developmental Psychology117 (2008) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-9

http:///reader/full/http://williamsinstitute.law.ucla.eduhttp://williamsinstitute.law.ucla.edu/wphttp:///reader/full/http://williamsinstitute.law.ucla.eduhttp://williamsinstitute.law.ucla.edu/wp


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Jennifer L. Wainright et al., Psychosocial Adjustment, School Outcomes, and Romantic Relationships of Adolescents with Same- Sex Parents , 75 Child Development 1886 (Dec.2004) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7, 9

Justin A. Lavner et al., Can Gay and Lesbian Parents Promote Healthy Development in High- Risk Children Adopted from Foster Care? ,82 American Journal of Orthopsychiatry 465(2012) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Krista K. Payne, Demographic Profile of Same-SexCouple Households with Minor Children, 2012 ,National Center for Family & MarriageResearch (FP-14-03) (2014), http://www.bgsu .edu/content/dam/BGSU/college-of-arts-and-sciences/NCFMR/documents/FP/FP-14-03_DemoSSCoupleHH.pdf . . . . . . . . . . . . . . . . . . . . 3

Kristin Anderson Moore et al., Marriage from aChild’s Perspective: How Does Family Structure

Affect Children, and What Can We Do About It?

Child Trends (June 2002), http://www .childtrends.org/wp-content/uploads/2013/03/MarriageRB602.pdf . . . . . . . . . . . . . 16, 17-18

Loes van Gelderen et al., Quality of Life of Adolescents Raised from Birth by Lesbian Mothers: The US National Longitudinal Family Study , 33 Journal of Developmental &Behavioral Pediatrics 1 (2012) . . . . . . . . . . . . . . 9

http://www.bgsu/http://www/http://www.bgsu/http://www/


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Loren Marks, Same-Sex Parenting and Children’sOutcomes: A Closer Examination of the American Psychological Association’s Brief on Lesbian and Gay Parenting , 41 Social ScienceResearch 735 (2012) . . . . . . . . . . . . . . . . . . . . . . 13

Marilyn Coleman et al., Reinvestigating Remarriage: Another Decade of Progress , 62Journal of Marriage & Family 1288 (2000) . . . 16

Mark Regnerus, How Different Are the AdultChildren of Parents Who Have Same-Sex

Relationships? Findings from the New Family Structures Study , 41 Social Science Research752 (2012) . . . . . . . . . . . . . . . . . . . . . . . . . . passim

Mark Regnerus, Parental Same-Sex Relationships, Family Instability, and Subsequent LifeOutcomes for Adult Children: Answering Criticsof the New Family Structures Study with

Additional Analyses , 41 Social Science Research1367 (2012) . . . . . . . . . . . . . . . . . . . . . . . . . . 21, 26

Mark V. Flinn et al., Growth and Fluctuating Asymmetry of Stepchildren , 20 EvolutionaryHuman Behavior 465 (1999) . . . . . . . . . . . . . . . 16

Michael J. Rosenfeld, Nontraditional Families andChildhood Progress Through School , 47Demography 755 (Aug. 2010) . . . . . . . . . . . . . . . 6

Michael J. Rosenfeld, Reply to Allen et al ., 50Demography 963 (June 2013) . . . . . . . . . . . . . . . 7


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Nanette K. Gartrell & Henny Bos , US National Longitudinal Lesbian Family Study: Psychological Adjustment of 17-Year-Old Adolescents , 126 Pediatrics 28 (2010) availableat http://pediatrics.aappublications.org /content/early/2010/06/07/peds.2009-3153.full.pdf+html . . . . . . . . . . . . . . . . . . . 9-10, 12, 15

Nanette K. Gartrell et al., New Trends in Same-Sex Sexual Contact for American Adolescents? , 41 Archives of Sexual Behavior 5 (2011) . . . . . . . . 12

Nicholas H. Wolfinger, Understanding the DivorceCycle: The Children of Divorce in Their Own

Marriages (2005) . . . . . . . . . . . . . . . . . . . . . . . . 16

Pamela J. Smock & Wendy D. Manning, LivingTogether Unmarried in the United States:

Demographic Perspectives and Implications for Family Policy , 26 Law & Policy 87 (2004) . . . . 18

Paul R. Amato & Fernando Rivera, Paternal Involvement and Children’s Behavior Problems ,61 Journal of Marriage & Family 375 (May1999) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Paul R. Amato & Frieda Fowler, Parenting Practices, Child Adjustment, and Family Diversity , 64 Journal of Marriage & Family 703(Aug. 2002) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Rachel H. Farr et al., Parenting and Child Development in Adoptive Families: Does Parental Sexual Orientation Matter? , 14 AppliedDevelopmental Science 164 (2010) . . . . . . . . . . 10

http:///reader/full/http://pediatrics.aappublications.orghttp:///reader/full/http://pediatrics.aappublications.org


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Rand D. Conger et al., Socioeconomic Status, Family Processes, and Individual Development ,72 Journal of Marriage & Family 685 (June2010) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Sara McLanahan & Gary Sandefur, Growing Upwith a Single Parent (1994) . . . . . . . . . . . . . . . 16

Scott Ryan, Parent-Child Interaction Styles BetweenGay and Lesbian Parents and Their AdoptedChildren , 3 Journal of GLBT Family Studies 105(2007) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Shmuel Shulman & Moshe M. Klein, Distinctive Role of the Father in Adolescent Separation- Individuation , 62 New Directions for Child & Adolescent Development 41 (1993) . . . . . . . 18-19

Stephen Erich et al., A Comparative Analysis of Adoptive Family Functioning with Gay, Lesbian,and Heterosexual Parents and Their Children , 1Journal of GLBT Family Studies 43 (2005) . . . 10

Wendy D. Manning & Kathleen A. Lamb,

Adolescent Well-Being in Cohabiting, Married,and Single-Parent Families , 65 Journal ofMarriage & Family 876 (Nov. 2003) . . . . . . . . . 18


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INTEREST OF AMICUS CURIAE 1

The American Sociological Association (“ASA”) isthe national non-profit and non-partisan professionaland scholarly association of sociologists in the UnitedStates. The ASA was founded in 1905 and has morethan 13,000 members, including most sociologistsholding doctoral degrees from accredited universities.The ASA publishes nine leading peer-reviewed

journals, is committed to and bound by the higheststandards of research methodology and objectivity, andis dedicated to advancing sociology as a scientificdiscipline and profession that serves the public good.

The ASA has a long history of presenting theconsensus research findings of social scientists to

American courts for their use in evaluating evidenceand legal issues, and courts often rely on social scienceresearch in their decisions. 2 As part of that mission,the ASA submits this brief to present to this Court theconsensus view of social scientists on the effects ofsame-sex parents on the wellbeing of children.

1 Respondents have lodged blanket letters of consent to the filingof amicus briefs with the Clerk of the Court, and Petitioners haveconsented in writing to the filing of this brief in accordance withSupreme Court Rule 37.3. Pursuant to Rule 37.6, amicus curiaestates that no counsel for a party authored any part of this brief inwhole or in part, and no counsel or party made a monetarycontribution intended to fund the preparation or submission of thisbrief.

2 This Court has often relied on social science research to inform itsdecisions. See, e.g. , Hall v. Florida , 134 S. Ct. 1986, 1993 (2014);

Roper v. Simmons , 543 U.S. 551, 569-70 (2005); Atkins v. Virginia ,536 U.S. 304, 318 (2002).


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SUMMARY OF ARGUMENT

The clear and consistent social science consensus isthat children raised by same-sex parents fare just aswell as children raised by different-sex parents.Decades of methodologically sound social scienceresearch, including multiple nationally representativestudies and expert evidence introduced in courtsaround the country, confirm that positive childwellbeing is the product of stability in the relationshipbetween the two parents, stability in the relationshipbetween the parents and the child, and sufficientparental socioeconomic resources. The wellbeing ofchildren does not depend on the sex or sexualorientation of their parents. Unsurprisingly, the courtsbelow recognized this fact. 3

Notwithstanding the social science consensus, manyopponents of marriage rights for same-sex couples (the“Marriage Opponents”), including amici that filedbriefs below, continue to support laws that denymarriage or limit the recognition of marriage to same-sex couples (collectively, the “Marriage Bans”) based onunfounded assertions that children fare better withdifferent-sex parents than with same-sex parents.They contend that same-sex parents produce worse

3 DeBoer v. Snyder , 772 F.3d 388, 405 (6th Cir. 2014) (“[G]aycouples, no less than straight couples, are capable of raisingchildren and providing stable families for them. The quality ofsuch relationships, and the capacity to raise children within them,turns not on sexual orientation but on individual choices andindividual commitment.”); DeBoer v. Snyder , 973 F. Supp. 2d 757,770-71 (E.D. Mich. 2014) (rejecting the assertion that childrenraised by same-sex parents fare worse than those raised bydifferent-sex parents).


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child outcomes—either because such families lack botha male and female parent, or because both parents arenot the biological parents of their children. MarriageOpponents also claim that social science studiessupport this assertion.

The studies cited by Marriage Opponents, however,do not and cannot serve as the basis for any conclusionabout same-sex parents and their children. Nor dothey undermine the social science consensus thatchildren fare just as well with same-sex parents. Tothe contrary, many of the studies show that stabilityimproves child outcomes. This confirms that marriagefor same-sex couples is likely to improve the wellbeingof the more than 200,000 children in the United Statesliving with same-sex parents, 4 many of whom are

4 Over 200,000 children live in same-sex couple households basedon the U.S. Census Bureau’s American Community Survey. SeeKrista K. Payne, Demographic Profile of Same-Sex Couple

Households with Minor Children, 2012 , National Center for Family& Marriage Research (FP-14-03), 1 (2014), http://www.bgsu.edu /content/dam/BGSU/college-of-arts-and-sciences/NCFMR/documents/FP/FP-14-03_DemoSSCoupleHH.pdf; Gary J. Gates,

LGBT Parenting in the United States , The Williams Institute, 1(Feb. 2013), http://williamsinstitute.law.ucla.edu/wp -content/uploads/LGBT-Parenting.pdf. More recent data from theU.S. Census Bureau’s American Community Survey, however,suggests that the number is in fact higher, at approximately250,000 children. See American Community Survey Data on Same

Sex Couples (2013) , United States Census Bureau, available athttps://www.census.gov/hhes/samesex/files/ssex-tables-2013.xlsx .In either case, this number does not include the over one millionchildren living with one parent who identifies as gay, lesbian, orbisexual. Gary J. Gates, LGB Families and Relationships:

Analyses of the 2013 National Health Interview Survey , The

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currently deprived of the enhanced stability thatmarriage provides.

The research presented in this brief articulates allof these points in great detail, and it demonstrates thatpromoting the wellbeing of children is neithersubstantially nor rationally related to the MarriageBans because the scientific evidence shows that same-sex parents are equally capable of raising children. 5

When the social science evidence is exhaustivelyexamined—which the ASA has done—the factsdemonstrate that children fare just as well when raisedby same-sex parents as when raised by different-sexparents. Unsubstantiated fears about children of same-

Williams Institute, 1 (Oct. 2014), http://williamsinstitute .law.ucla.edu/wp-content/uploads/lgb-families-nhis-sep-2014.pdf.

5 The Marriage Bans in no way affect whether children will beraised by same-sex or different-sex parents. They do notencourage gay and lesbian individuals to enter into different-sexmarriages, nor do they deter such individuals from having childrenwithin same-sex relationships. Various courts have made thispoint when assessing the constitutionality of the Marriage Bans.

See, e.g. , Bostic v. Schaefer , 760 F.3d 352, 384 (4th Cir. 2014)(“There is absolutely no reason to suspect that prohibiting same-sex couples from marrying and refusing to recognize their out-of-state marriages will cause same-sex couples to raise fewer childrenor impel married opposite-sex couples to raise more children.”);

Kitchen v. Herbert , 755 F.3d 1193, 1214 (10th Cir. 2014) (“Althoughcohabitating same-sex couples are prohibited from jointly adoptingchildren under Utah law as a result of the same-sex marriageban . . ., the record shows that nearly 3,000 Utah children arebeing raised by same-sex couples. Thus childrearing, a libertyclosely related to the right to marry, is one exercised by same-sexand opposite-sex couples alike, as well as by single individuals.”).

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sex parents do not overcome these facts and do not justify upholding the Marriage Bans.

ARGUMENT

I. THE SCHOLARLY CONSENSUS IS CLEAR AND CONSISTENT: CHILDREN OF SAME-SEX PARENTS FARE JUST AS WELL ASCHILDREN OF DIFFERENT-SEX PARENTS

The clear and consistent social science consensus isthat children raised by same-sex parents fare just as

well as children raised by different-sex parents.Numerous credible and methodologically sound socialscience studies, including several employing nationallyrepresentative samples, form the basis of thisconsensus. 6 These studies reveal that children raisedby same-sex parents fare just as well as children raisedby different-sex parents across a wide spectrum offactors used by social scientists to measure childwellbeing. These factors include academic performanceand cognitive development, social development,psychological health, early sexual activity, and

substance abuse and behavioral problems. Academic Performance and Cognitive Development

Social science research confirms that the academicperformance of children raised by same-sex parents is

6 Nationally representative studies are useful to understand childwellbeing in same-sex parent households. Nonetheless, asignificant amount of social science research is based onqualitative or convenience samples, and such samples areappropriate when there are subsamples that are hard to capturein large data collections or on topics that require intensiveinterviewing to advance the understanding of an issue.


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indistinguishable from that of children raised bydifferent-sex parents. A leading study by Daniel Potterthat was based on nationally representative,longitudinal data found no significant difference inacademic achievement between children of same-sexparents and children of different-sex parents. 7 SeeDaniel Potter, Same-Sex Parent Families andChildren’s Academic Achievement, 74 Journal ofMarriage & Family 556 (June 2012). Similarly,another leading study by sociologists Alicia Fedewaand Teresa Clark employed nationally representative

data, examined the academic achievement of first-grade children, and reported no significant differencesin academic achievement between children raised bysame-sex parents and children raised by different-sexparents. See Alicia L. Fedewa & Teresa P. Clark,

Parent Practices and Home-School Partnerships: A Differential Effect for Children with Same-Sex Coupled Parents? , 5 Journal of GLBT Family Studies 312(2009); see also Michael J. Rosenfeld, Nontraditional

Families and Childhood Progress Through School , 47Demography 755 (Aug. 2010) (demonstrating that

children of residentially stable same-sex parents are aslikely to make normal progress through school aschildren from residentially stable different-sex marriedparents); Douglas W. Allen et al., Nontraditional

Families and Childhood Progress Through School: AComment on Rosenfeld , 50 Demography 955 (June2013) (confirming similar results of academic

Unlike cross-sectional studies, which compare differentindividuals at one point in time ( i.e. , a snapshot), longitudinalstudies allow assessments of family living circumstances over thecourse of the child’s life.


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sex parent families for five years and controlled forparental marital status and education levels, he foundthat there were no differences at all. Id. at 639 n.10.

See also Transcript of Record at 128-29, DeBoer v. Snyder , No. 12-10285 (E.D. Mich. Mar. 13, 2014), ECFNo. 148 (Allen accepting that his “report finds nostatistically significant difference in graduation rateswhen you control for parental education and maritalstatus and when you do control for five years ofresidential stability”). Allen’s paper does nothing toundermine the social science consensus.

Social science research also confirms that childrenraised by same-sex parents and children raised bydifferent-sex parents show similar levels of cognitivedevelopment. See Justin A. Lavner et al., Can Gay and

Lesbian Parents Promote Healthy Development in High- Risk Children Adopted from Foster Care? , 82 AmericanJournal of Orthopsychiatry 465 (2012).

Social Development

Social science research confirms that social

development of children raised by same-sex parents isequivalent to that of children raised by different-sexparents. Analysis of nationally representative datareveals no differences in social adjustment dependingon whether a child was raised by same-sex or different-sex parents. See Fedewa & Clark at 312. Moreover,nationally representative studies of adolescents findthat the number, support, and quality of peerrelationships and friendships are similar for teensraised by female same-sex parents and those raised bydifferent-sex parents. See Jennifer L. Wainright &

Charlotte J. Patterson, Peer Relations Among Adolescents with Female Same-Sex Parents , 44


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Developmental Psychology 117 (2008); see also FionaTasker, Lesbian Mothers, Gay Fathers and TheirChildren: A Review , 26 Developmental and BehavioralPediatrics 224 (June 2005) (discussing studies that findthat children of same-sex parents experiencepsychosocial development outcomes similar to thoseexperienced by children of different-sex parents).

Mental Health

Social science studies also confirm that children ofsame-sex parents are just as psychologically healthy as

children of different-sex parents. According to anationally representative study, adolescents raised bysame-sex and different-sex parents report similarlevels of self-esteem and depression. See Wainright etal. at 1886. Other reliable studies corroborate theseresults. See Loes van Gelderen et al., Quality of Life of

Adolescents Raised from Birth by Lesbian Mothers: TheUS National Longitudinal Family Study , 33 Journal ofDevelopmental & Behavioral Pediatrics 1, 1 (Jan. 2012)(concluding that “[a]dolescent offspring in plannedlesbian families do not show differences in [quality oflife] when compared with a matched group ofadolescents reared in heterosexual families”). Recentresearch on young children shows that the ability ofadopted children to externalize and internalizebehaviors does not depend on whether they are raisedin male same-sex, female same-sex, or different-sexparent families. See Abbie E. Goldberg & JuliAnna Z.Smith, Predictors of Psychological Adjustment in Early

Placed Adopted Children with Lesbian, Gay, and Heterosexual Parents , 27 Journal of Family Psychology431 (2013). Similarly, studies reveal no greater levelsof anxiety or attention deficit disorder among teenagers


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raised by same-sex parents than among those raised bydifferent-sex parents. See Nanette K. Gartrell &Henny Bos , US National Longitudinal Lesbian Family

Study: Psychological Adjustment of 17-Year-Old Adolescents , 126 Pediatrics 28 (2010), available ath t t p : / / p e d i a t r i c s . a a p p u b l i c a t i o n s . o r g /content /early/2010/06/07/peds.2009-3153.ful l .pdf+html. 9

Marriage Opponents may cite two recentlypublished papers by sociologist Paul Sullins, whichpurport to show that school-age children of same-sexparents have high rates of attention-deficithyperactivity disorder and emotional problems. See D.Paul Sullins, Child Attention-Deficit Hyperactivity

Disorder (ADHD) in Same-Sex Parent Families in theUnited States: Prevalence and Comorbidities , 6 BritishJournal of Medicine & Medical Research 987(Feb. 2015); D. Paul Sullins, Emotional Problems

Among Children with Same-sex Parents: Difference by Definition , 7 British Journal of Education, Society &Behavioural Science 100 (Feb. 2015). These two papersin no way undermine the decades of methodologicallysound studies reflecting the consensus view discussed

9 See also Rachel H. Farr et al., Parenting and Child Developmentin Adoptive Families: Does Parental Sexual Orientation Matter? , 14

Applied Developmental Science 164 (2010) (reporting similarfindings); Scott Ryan, Parent-Child Interaction Styles Between Gayand Lesbian Parents and Their Adopted Children , 3 Journal ofGLBT Family Studies 105 (2007) (same); Stephen Erich et al., AComparative Analysis of Adoptive Family Functioning with Gay,

Lesbian, and Heterosexual Parents and Their Children , 1 Journalof GLBT Family Studies 43 (2005) (same).

http:///reader/full/http://pediatrics.aappublications.orghttp:///reader/full/http://pediatrics.aappublications.org


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herein.10

The two papers fail to account for familystability—the length of time the children spent residingwith their same-sex or different-sex parents, and theirfamily histories. The papers also ignored any familytransitions for children of same-sex parents thatoccurred prior to the interview (this includes changesin family arrangements prior to a child’s living withsame-sex parents), which paints an incomplete pictureof a child’s family experiences. In fact, one papercontains no measure of family stability whatsoever (ortransitions for same-sex parents), and the other falsely

equates housing status (renting versus owning a home,which only measures socioeconomic means) with familystability. By failing to account for changes that mayhave occurred prior to children joining a same-sexparent family, the papers provide no basis toextrapolate about the wellbeing of children who are, infact, raised by same-sex parents in stable households.

Early Sexual Activity

Social science studies also demonstrate thatteenagers raised by same-sex parents and those raisedby different-sex parents engage in similar levels ofteenage sexual activity. For instance, nationallyrepresentative studies show that similar proportions ofteenagers raised by same-sex parents and by different-sex parents have had sexual intercourse or a romantic

10 The Sullins papers failed to undergo a rigorous review byestablished family scholars, which would take months to completeand be required to undermine decades worth of methodically soundsocial science research. In fact, one paper was accepted forpublication sixteen calendar days after submission (this periodspanned the academic winter break and holiday period).

http:///reader/full/herein.10http:///reader/full/herein.10http:///reader/full/herein.10


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relationship. See Charlotte J. Patterson & Jennifer L.Wainright, Adolescents with Same-Sex Parents: Findings from the National Longitudinal Study of Adolescent Health , in Adoption by Lesbians and Gay Men: A New Dimension in Family Diversity (David M.Brodzinsky & Adam Pertman eds., 2012). One studyfound that reports by 17-year-olds raised by lesbianmothers of their sexual behavior indicate that the ageat which they first engaged in sexual intercourse wasslightly older than those in a gender- and age-matchednational sample of children raised by different-sex

parents. See Nanette K. Gartrell et al., New Trends in Same-Sex Sexual Contact for American Adolescents? , 41 Archives of Sexual Behavior 5 (2011).

Substance Abuse and Behavioral Problems

Social science studies confirm that children of same-sex parents are no more likely to abuse substancesthan children of different-sex parents. A nationallyrepresentative sample of adolescents living withfemale, same-sex parents reveals that the adolescentsare similar to their counterparts raised by different-sexparents in terms of frequency of and problems withsubstance use ( i.e. , tobacco, alcohol, and marijuana)and delinquent behavior. See Jennifer L. Wainright &Charlotte J. Patterson, Delinquency, Victimization, and

Substance Use Among Adolescents with Female Same- Sex Parents , 20 Journal of Family Psychology 526(2006). Furthermore, children of different-sex andsame-sex parents report similar levels of problematic,rule-breaking, and inappropriately aggressivebehaviors. See Gartrell & Bos.

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The overwhelming body of social science researchconfirms that a child’s wellbeing is not dependent onwhether the child’s parents are of the same or differentsex. 11 Instead, the consensus is that the key factorsaffecting child wellbeing are stable familyenvironments and sufficient parental socioeconomicresources, neither of which is related to the sex orsexual orientation of a child’s parents. See Rand D.Conger et al., Socioeconomic Status, Family Processes,and Individual Development , 72 Journal of Marriage &Family 685 (June 2010). This research indicates that

we should encourage stable and financially securefamilies—including same-sex parent families—ratherthan exclude the hundreds of thousands of childrenliving with same-sex couples from the stability andeconomic security that marriage provides.

II. CLAIMS THAT CHILDREN FARE BETTERWITH DIFFERENT-SEX PARENTS THANW I T H S A M E - S E X PA R E N T S A R EUNSUPPORTED BY SOCIAL SCIENCERESEARCH

Claims that children fare better with different-sexparents than with same-sex parents are unsupportedby existing social science research and are incorrect forthe following two general reasons. First , almost none

11 Some critics make near-blanket dismissals of the studiesunderlying the social science research consensus. See, e.g. , LorenMarks, Same-Sex Parenting and Children’s Outcomes: A Closer

Examination of the American Psychological Association’s Brief on Lesbian and Gay Parenting , 41 Social Science Research 735 (2012).The ASA’s review of the studies confirms that they aremethodologically sound and conform to the highest standards ofsocial science research.


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of the studies cited by Marriage Opponents purport toexamine same-sex parents or their children. Accordingly, these studies cannot be used to drawconclusions about the outcomes of children raised bysame-sex parents. Second , the few studies cited byMarriage Opponents that do purport to examinechildren of same-sex parents have been discredited,including one of the primary studies offered byMarriage Opponents in the U.S. District Court for theEastern District of Michigan below. In sum, thestudies relied upon by Marriage Opponents do not and

cannot change the social science consensus. A. STUDIES EXAMINING DIFFERENT-SEX

COUPLES CANNOT BE USED BYMARRIAGE OPPONENTS TO MAKECLAIMS ABOUT SAME-SEX PARENTS

AN D DO NO T UN DE RM IN E TH ECONSENSUS

Studies analyzing different-sex parents—whetherthey analyze adoptive parents, stepparents, divorcedparents, or single parents—cannot be used by MarriageOpponents to speculate about the wellbeing of childrenof same-sex parents because those studies do notexamine same-sex parents or their children. Instead,these studies show that parental stability and higherparental socioeconomic resources—not the sex orsexual orientation of a child’s parents—are the keydrivers of positive child outcomes.

Studies on Adoptive Families

Studies examining children of adoptive parents andchildren conceived by donor sperm cannot be used toargue that children are raised best by biological


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parents. See, e.g. , Elizabeth Marquardt et al., Institutefor American Values, My Daddy’s Name is Donor: A New Study of Young Adults Conceived Through Sperm Donation (2010). 12 There is no basis in social scienceresearch for such a claim. In fact, studies indicate thatchildren raised in adoptive families since infancy or infamilies utilizing assisted reproduction techniques fare

just as well as other children. See Gartrell & Bos at 33-34 (showing that “adolescents who have been raisedsince birth in planned lesbian families demonstratehealthy psychological adjustment” and that they

“demonstrated higher levels of social, school/academic,and total competence than gender-matched normativesamples of American teenagers”); Brent Miller et al.,Comparisons of Adopted and Non-Adopted Adolescentsin a Large, Nationally Representative Sample , 71 ChildDevelopment 1458 (2000) (finding little differencebetween adoptees and non-adoptees who live in two-parent families). The recent 2013 study by Goldbergand Smith, cited above, corroborates this finding. Thatstudy examined 120 families who have adoptedchildren younger than 18 months old. Utilizing

longitudinal data, the study reported that adoptedchildren across families with male same-sex, femalesame-sex, and different-sex parents fare equally well interms of externalizing and internalizing behaviors,which are well established factors for measuring childwellbeing. See Goldberg & Smith.

12 It is hard to see the relevance of reports about the significanceof biological parenting on the issue of marriage rights for same-sexcouples given that both adoption and assisted reproduction arewidely used by different-sex couples, as reflected in the verysources often cited in support of the Marriage Bans.

http:///reader/full/2010).12http:///reader/full/2010).12http:///reader/full/2010).12


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Studies on Stepparents, Divorced Parents, or Single Parents

Studies examining the impact that stepparents,divorced parents, and single parents have on childwellbeing cannot be used to claim that being raised bytwo biological parents is better for children. First ,these studies do not examine same-sex parents or theirimpact on child wellbeing. See, e.g. , Kristin AndersonMoore et al., Marriage from a Child’s Perspective: How

Does Family Structure Affect Children, and What CanWe Do About It? , Child Trends 1-2, 6 (June 2002),http://www.childtrends.org/wp-content/uploads/2013 /03/MarriageRB602.pdf (comparing the wellbeing ofchildren raised by stepparents and single parents tothat of children raised by stable, two parent families);Sara McLanahan & Gary Sandefur, Growing Up witha Single Parent 38 (1994) (comparing “disrupted”families with “intact” families, but nowhere discussingsame-sex parents); Marilyn Coleman et al.,

Reinvestigating Remarriage: Another Decade of Progress , 62 Journal of Marriage & Family 1288 (2000)(comparing stepparents to non-divorced parents, butnot addressing same-sex parents); Mark V. Flinn et al.,Growth and Fluctuating Asymmetry of Stepchildren , 20Evolutionary Human Behavior 465 (1999) (analyzingthe wellbeing of children raised by stepfathers, but notaddressing same-sex parents); Nicholas H. Wolfinger,Understanding the Divorce Cycle: The Children of

Divorce in Their Own Marriages (2005) (analyzing theimpact of divorce, but not addressing same-sexparents). Accordingly, these studies do not bear onsame-sex parenting.

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Second , to the extent studies show that children ofstepparents, divorced parents, or single parentsexperience, on average, not as positive outcomes aschildren raised by intact biological parent couples, it isdue to the disruption caused by divorce or theintroduction of a new parent into the family. See, e.g. ,Moore et al. at 1 (“Divorce is linked to academic andbehavior problems among children, includingdepression, antisocial behavior, impulsive/hyperactivebehavior, and school behavior problems. Mental healthproblems linked to marital disruption have also been

identified among young adults.”). These studies do notindicate that the negative outcomes are at all related tothe fact that the stepparent is not biologically relatedto the child. Accordingly, any contention that thesestudies about single parents, stepparents, or divorcedparents can be used to draw conclusions about same-sex parents is wrong.

Finally , and critically, the authors of one of thestudies cited most frequently by Marriage Opponents,including by some amici below—the Child Trendsstudy by Kristin Anderson Moore, et al.—have publiclyrebuked Marriage Opponents for distorting theirfindings. Before this Court considered Windsor and

Perry , the authors expressly disclaimed the misuse oftheir study by the Bipartisan Legal Advisory Group,which defended the Defense of Marriage Act (DOMA),explaining that “no conclusions can be drawn from thisresearch about the well-being of children raised bysame-sex parents or adoptive parents.” See Moore etal. Even if this study were applicable to same-sexparents, the authors stated that “when researchers

have compared marriage to cohabitation, they havefound that marriage is associated with better outcomes


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for children.” Id. at 2. Far from undermining the casefor same-sex marriage, this conclusion demonstratesthat recognition of marriage rights of same-sex coupleswould improve the wellbeing of children being raisedby currently unmarried same-sex parents. See alsoWendy D. Manning & Kathleen A. Lamb, AdolescentWell-Being in Cohabiting, Married, and Single-Parent

Families , 65 Journal of Marriage & Family 876 (Nov.2003) (noting that marriage provides enhancedsocioeconomic resources to families, improving childwellbeing outcomes); Pamela J. Smock & Wendy D.

Manning, Living Together Unmarried in the United States: Demographic Perspectives and Implications for Family Policy , 26 Law & Policy 87, 94 (2004)(discussing the role of marriage in contributing to thestability of a family).

Studies on Parenting Styles in Families with Different- Sex Parents

Studies examining the parental roles of mothersand fathers within the context of different-sex parentfamilies cannot be used to argue that child wellbeingdepends on having both a male and female parent. See,

e.g. , Charles A. Nelson & Michelle Bosquet, Neurobiology of Fetal and Infant Development: Implications for Infant Mental Health, in Handbook of Infant Mental Health 37-59 (C.H. Zeanah Jr. ed., 2d ed.2000); Eleanor Maccoby, The Two Sexes 266-68 (1998);Paul R. Amato & Fernando Rivera, Paternal

Involvement and Children’s Behavior Problems , 61Journal of Marriage & Family 375 (May 1999); ShmuelShulman & Moshe M. Klein, Distinctive Role of the

Father in Adolescent Separation-Individuation , 62 New


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Directions for Child & Adolescent Development 41, 53(1993).

First , studies about the parenting and disciplinarypractices of different-sex parents simply do notexamine same-sex parents. Accordingly, they cannotbe used to draw any conclusions about same-sexparents or their children, let alone specific conclusionsabout the purported parenting styles of same-sexparents and the supposed effects of those styles onchildren.

Second , social science research shows that there area range of parenting styles and that children do notneed their parents to adhere to sex-stereotypedparenting styles to be well adjusted. See Paul R.

Amato & Frieda Fowler, Parenting Practices, Child Adjustment, and Family Diversity , 64 Journal ofMarriage & Family 703, 714 (2002) (“When parentsspend time with children, help with homework, talkabout problems, provide encouragement, and showaffection, children do well.”).

Third , even if research showed that parents neededto perform different parenting roles to raise well-adjusted children (which it does not), nothing in thesocial science literature indicates that same-sex couplesare incapable of performing such roles. See DavidPopenoe, Life Without Father: Compelling New

Evidence that Fatherhood & Marriage Are Indispensable for the Good of Children & Society 147(1996) (noting that among same-sex parents, onepartner commonly fills the “male-instrumental rolewhile the other fills the female-expressive role” in

rearing their children).


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Fourth , arguments based on rigid gender rolesshould be rejected outright, and there is no basis to relyon “outdated misconceptions” and “loose-fittingcharacterizations” regarding gender. See Craig v.

Boren , 429 U.S. 190, 198–99 (1976); see also PriceWaterhouse v. Hopkins , 490 U.S. 228, 251, 255-56(1989) (“[W]e are beyond the day when an employercould evaluate employees by assuming or insisting thatthey matched the stereotype associated with theirgroup[.]”).

Finally , studies examining the role of absenteefathers, see, e.g. , Popenoe at 146, cannot be used toclaim that, within the context of same-sex parents,having a male and female parent is necessary to achild’s wellbeing. In fact, the research showing thenegative impact of absentee fathers, such as DavidPopenoe’s, has nothing to do with the uniquecontributions of fathers, but rather with the loss of aparental relationship more generally. Id . at 139(“Much of what fathers contribute to childdevelopment, of course, is simply the result of being asecond adult in the home. Other things being equal,two adults are far better than one at raising children.

As the distinguished developmental psychologist UrieBronfenbrenner has noted, the quality of interactionbetween principal caregiver and child depends heavilyon the availability and involvement of another adult, athird party who assists, encourages, spells off, givesstatus to, and expresses admiration and affection forthe person caring for and engaging in joint activitywith the child.” (internal quotations omitted)).Children being raised by same-sex parents would be

raised by two parents. Therefore, this research doesnot apply to them.


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point during their childhood experienced inferioroutcomes. Although this paper never actually studiedchildren raised by same-sex parents, MarriageOpponents often extrapolate from this limited studythat children raised by same-sex parents experienceoutcomes inferior to those of children raised bydifferent-sex parents. Over one hundred fellowscientists publicly criticized Regnerus for his study’sfailings. Regnerus then published a second paper,Regnerus 2012b, in which he attempted to remedy thefact that Regnerus 2012a did not analyze whether the

children had actually lived with the parent who had atsome point engaged in a same-sex romanticrelationship. As discussed below, both papers areflawed, and neither paper undermines the socialscience consensus.

The Regnerus 2012a Paper Offers No Basis forConclusions About Same-Sex Parents

The Regnerus 2012a paper offers no basis forconclusions about same-sex parents for the followingreasons. First , Regnerus 2012a does not examinechildren born or adopted into same-sex parent families,but instead examines children who, from the time theywere born until they were 18 or moved out, had aparent who at some time had “a same-sex romanticrelationship.” See Regnerus 2012a at 756. Regnerusnoted that “just under half” of the individualscharacterized by him as children of ‘lesbian mothers’and ‘gay fathers’ were the offspring of failed different-sex marriages whose parent subsequently had a same-sex relationship. Id . at 757. In other words, the studydid not analyze children of two same-sex parents.


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Second , Regnerus 2012a compared (i) the childrenof parents who at some point had a “same-sex romanticrelationship,” and who had experienced a familydissolution or single motherhood, to (ii) children raisedby two biological, married different-sex parents. Thestudy also stripped away all divorced, single, andstepparent families from the different-sex parentgroup, leaving only stable, married, different-sexparent families as the comparison. Id. (the comparisongroup consisted of individuals who “[l]ived in intactbiological famil[ies] (with mother and father) from 0 to

18, and parents are still married at present”). It washardly surprising that this select different-sex parentgroup had better outcomes given that stability, asnoted above, is a key predictor of child wellbeing. Byremoving divorced, single, and step-parent familiesfrom the different-sex parent group, the Regnerus2012a paper makes inappropriate apples-to-orangescomparisons.

Third , the Regnerus 2012a paper failed to considerwhether the children lived with, or were raised by, theparent who was at some point apparently involved in “aromantic relationship with someone of the same sex”and that same-sex partner. Id . at 756. Instead,Regnerus categorized children as raised by a parent ina same-sex relationship regardless of whether theywere in fact raised by the parent and the parent’ssame-sex romantic partner, and regardless of theamount of time that they spent under that parent’scare. In fact, Regnerus himself acknowledged thatthere were “only [a] handful of cases where there wasa nonstop presence of mom and her partner in the

household the entire childhood of the respondent.” SeeTranscript of Record at 55, DeBoer v. Snyder , No. 12-


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critiques and published a second analysis of the data,which is referred to as Regnerus 2012b. Regnerus2012b attempted to remedy the fact that Regnerus2012a did not analyze whether the children hadactually lived with the parent who had at some pointbeen “romantically involved” with someone of the samesex. But Regnerus 2012b does not remedy Regnerus2012a’s shortcomings.

First , Regnerus 2012b maintains the same flawedand extremely broad definition of what constitutes“lesbian mothers” and “gay fathers”—that is, a motheror father who ever had a romantic relationship withsomeone of the same-sex during the period from thebirth of the child until the child turned eighteen (or lefthome to be on their own). Regnerus 2012b at 1368.

Accordingly, Regnerus 2012b continues to ignorestability as the primary factor in child outcomes.

Second , Regnerus 2012b fails to account for theduration of time spent with a mother and the same-sexpartner with whom she was “romantically involved.”

See id. at 1372. Only two of the eighty-five childrenwho at some point lived with a mother who was“romantically involved” with another woman reportedthat they did so for the entire duration of theirchildhood. Id. at 1370. Finally , Regnerus 2012b doesnot address the wellbeing of children raised by same-sex parents because Regnerus did not determinewhether the recorded childhood experiences occurredwhile the mother lived with a same-sex partner orduring another family living arrangement.

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If any conclusion can be reached from Regnerus2012a and 2012b, it is that family stability is predictiveof child wellbeing. Indeed, Regnerus noted that familystructure (for instance, whether the family has a singleparent or two parents) matters significantly to childoutcomes. See Regnerus 2012a at 761.

CONCLUSION

The clear and consistent social science consensus isthat children raised by same-sex parents fare just aswell as children of different-sex parents. This

consensus holds true across a wide range of childoutcome indicators and is supported by numerousreliable studies, including those using nationallyrepresentative data. The research supports theconclusion that the extension of marriage rights tosame-sex couples has the potential to improve childwellbeing insofar as the institution of marriage mayprovide social and legal support to families andenhance family stability, which are key drivers ofpositive child outcomes. Claims by MarriageOpponents about the wellbeing of children areunsupported by any social science study published todate. Their claims neither undermine the socialscience consensus nor establish a basis for upholdingthe Marriage Bans.


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Respectfully submitted,

Carmine D. Boccuzzi, Jr. (Counsel of Record)Mark A. LightnerGrant A. Bermann

Alexandra EberCLEARY GOTTLIEB STEEN & H AMILTON LLPOne Liberty PlazaNew York, NY 10006(212) 225-2000 [email protected]

Counsel for Amicus Curiae American Sociological Association

March 5, 2015
mailto:[email protected]:[email protected]

14-556 american sociological association

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