13-4178 Amicus Brief of State of Michigan

8/13/2019 13-4178 Amicus Brief of State of Michigan

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No. 13-4178; 14-5003 & 14-5006

IN THE UNITED STATES COURT OF APPEALS

FOR THE TENTH CIRCUIT

DEREK KITCHEN, ET AL.,

Plaintiffs-Appellees,

v.

GARY R. HERBERT, ET AL.,

Defendants-Appellants.

Appeal from the United States District Court

for the District of Utah (No. 2:13-cv-00217)

MARY BISHOP, ET AL.,Plaintiffs-Appellees,

v.

SALLY HOWE SMITH, ET AL.,

Defendants-Appellants.

Appeal from the United States District Court

for the District of Oklahoma (No. 4:04-cv-00848)

BRIEF OFAMICUS CURIAE STATE OF MICHIGAN IN

SUPPORT OF STATES OF OKLAHOMA AND UTAH

Bill Schuette

Michigan Attorney General

Aaron D. Lindstrom

Solicitor General

Co-Counsel of Record

B. Eric Restuccia

Deputy Solicitor GeneralAttorneys forAmicus Curiae

Department of Attorney General

P.O. Box 30212

Lansing, Michigan 48909

(517) 373-1124

Dated: February 10, 2014

Appellate Case: 13-4178 Document: 01019200248 Date Filed: 02/10/2014 Page: 1Appellate Case: 13-4178 Document: 01019200300 Date Filed: 02/10/2014 Page: 1

Docket Reference Number: [10148389]


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TABLE OF CONTENTS

Page

Table of Authorities .................................................................................... iiStatement of Interest ofAmicus CuriaeState of Michigan ..................... 1Introduction ................................................................................................ 2

Argument .................................................................................................... 5I. The debate over the definition of marriage is ongoing and

should be left to the people of the States. ........................................ 5II. Voters could reasonably conclude that a family with both a

mom and a dad is the ideal setting in which to raise

children. ............................................................................................. 7A. Marriage is rooted in the unique capacity of the union

of one man and one woman to bear children. ......................... 8B. The definition of marriage enables both a mom and a

dad to serve as role models for their children....................... 10C. Marriage enables the parents to have a biological

relationship with their children. ........................................... 13III. Reaffirming the definition of marriage, which excludes other

relationships, is reasonable and does not denigrate anyone. ........ 15A. Other relationships do not share the unique

characteristics of marriage. ................................................... 16B. Upholding marriage is not a matter of animus. ................... 18

Conclusion and Relief Requested ............................................................. 21Certificate of Compliance ......................................................................... 22Certificate of Service ................................................................................ 23Certificate of Digital Submission ............................................................. 24



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TABLE OF AUTHORITIES

Page

CasesAndersen v. King County,

158 Wash. 2d 1 (2006) ....................................................................... 9, 13

Bishop v. Smith,

___ F. Supp. 2d ___; 2014 WL 116013 (N.D. Okla. 2014) ................... 19

Bobby v. Dixon,

132 S. Ct. 26 (2011) ............................................................................... 12

Dixon v. Houk,627 F.3d 553 (6th Cir. 2010) ................................................................. 11

Duren v. Missouri,

439 U.S. 357 (1979) ............................................................................... 11

Hernandez v. Robles,

7 N.Y.3d 338 (2006) ..................................................................... 9, 10, 14

In re Marriage of J.B.and H.B.,

326 S.W.3d 654 (Tx. Ct. App. 2010) ...................................................... 11

In re Winship,

397 U.S. 358 (1970) ............................................................................. 5, 6

Jackson v. Abercrombie,

884 F. Supp. 2d 1065 (D. Hawaii 2012) ................................................ 10

Lawrence v. Texas,

539 U.S. 558 (2003) ............................................................................... 18

Lewis v. Harris,

875 A.2d 259 (N.J. Sup. Ct. 2005)......................................................... 19

Lofton v. Secy of Dept of Children & Family Services,

358 F.3d 804 (11th Cir. 2004) ............................................................... 12



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Maher v.Roe,

432 U.S. 464 (1977) ................................................................................. 7

Maynard v. Hill,

125 U.S. 190 (1888) ............................................................................... 15

Sissung v. Sissung,

31 N.W. 770 (Mich. 1887) ........................................................................ 8

State v. Fry,

4 Mo. 120 (1835) ...................................................................................... 8

United States v. Windsor,

133 S. Ct. 2675 (2013) ..................................................................... 2, 3, 5

Statutes10 Okla St. Ann. 7503-1.1 ..................................................................... 14

MICH.COMP.LAWS 710.24 ..................................................................... 14

Utah Code 78B-6-117(2), (3) .................................................................. 14

RulesFED. R. APP. P. 29(a) ................................................................................... 1

Constitutional ProvisionsMICH.CONST. art. I, 25 ............................................................................ 1



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STATEMENT OF INTEREST OF

AMICUS CURIAESTATE OF MICHIGAN

Like voters in a majority of States, the people of Michigan define

marriage as the union between one man and one woman. Michigans

citizens recently reaffirmed this definition, which dates back to 1846, by

amending the state constitution in 2004. RS 1846, Ch. 83, 1; MICH.

CONST. art. I, 25.

The people of Oklahoma and Utah have also reaffirmed their long-

held understanding of marriage by voting on the issue. But the federal-

court decisions below nullified this democratic process, taking this

fundamental policy decision away from ordinary citizens by concluding

that the peoples view that a child benefits from having both a mother

and a father is irrational.

The State of Michigan files to make three points: (1) the people of

the States, not federal courts, should decide the definition of marriage;

(2) marriage encourages the commonsense point that it benefits a child

to have a mom and a dad; and (3) this time-honored definition does not

disparage anyone but is based on a conclusion about raising children.1

1This brief is being filed pursuant to Federal Rule of Appellate

Procedure 29(a).



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INTRODUCTION

The current debate on marriage presents different ways of under-

standing what marriage should be. People of good will may reasonably

disagree about the issue. It is for precisely that reason that the debate

should continue and be resolved through the democratic process. This

Court should not overturn the peoples decision and impose its own

vision, thereby removing the issue from the democratic process and

effectively silencing those who support marriage between a man and a

woman. The views of the people of the Statessome of their most

deeply held and reveredare reasonable ones. Voters may have pre-

served the definition of marriage on the reasonable belief that children

are better off with both a mom and a dad. And even if these views may

be debated, they cannot rightly be dismissed as irrational or bigoted.

The judgment of the people on these questions is particularly

compelling because marriage falls within the States dominion. The

area of domestic relations has long been regarded as a virtually

exclusive province of the States. Indeed, the Supreme Court just

affirmed this long-established rule in United States v. Windsor, 133 S.

Ct. 2675 (2013), recognizing that [b]y history and tradition the



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definition and regulation of marriage . . . has been treated as being

within the authority and realm of the separate States. Id. at 268990.

Given the States authority over marriage, federal courts should not

easily set aside the peoples will.

The laws reaffirming the definition of marriage here rest on the

fact that no other relationship is like that of the union of one man and

one woman. It is uniquely suited for the creation and rearing of

children. Only marriage reflects the natural capacity of this

relationship to bear children, to provide a role model of both manhood

and womanhood to the children, and to enable any children born of the

marriage to have a biological relationship with each parent. The point

is a modest one: it is reasonable to conclude that, all things being

equal, it is better for a child to be raised by the childs mom and dad.

This definition does not disparage or demean other important

relationships, including ones in which children are raised outside the

umbrella of marriage. It simply recognizes that the justification for

legally recognizing marriage in the first place is that it promotes the

best interests of children. The law encourages citizens to enter into

marriage, fostering that ideal setting for raising children.



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This definition has existed from time immemorial and is not

rooted in animus toward same-sex couples or even in an unwarranted

stereotype that same-sex couples cannot provide a loving setting for

children. They clearly can. Rather, the definition simply acknowledges

the reality that same-sex relationships are different because they lack

the natural capacity to bear children and the ability to provide

biologically connected role modelsa mom and a dadto the children.

It is rational to define marriage based on the relationship out of which

children are ordinarily born. Every child has a mom and a dad. The

definition of marriage gives legal form to this reality.

Marriage, if it is to have any meaning, has to have a definition.

Every relationship between consenting adults does not constitute a

marriage, even where the adults are raising children together. But

courts should leave the contentious social issue of marriage to the

democratic process rather than cutting short the peoples deliberations.

This is the exact sort of decision that a democracy entrusts to the

people.



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ARGUMENT

I. The debate over the definition of marriage is ongoingand should be left to the people of the States.

Since this nations founding, the institution of marriage and its

legal parameters have been within the authority and realm of the

separate States. Windsor, 133 S. Ct. at 2690. Citizens in States

around the nation are currently engaging in a robust debate on whether

marriage should be extended to same-sex couples. This debate should

be allowed to play out in our democratic institutions; it should not be

short-circuited by the courts. When this Court assumes for itself the

power to declare any lawstate or federalunconstitutional because it

offends [a] majority[ ] [of the courts] own views of what is fundamental

and decent in our society, our Nation ceases to be governed according to

the law of the land and instead becomes one governed ultimately by

the law of the judges. In re Winship, 397 U.S. 358, 384 (1970). (Black,

J., dissenting). The deeply rooted definition of marriage should be left

to the political arena where the people can decide.

An open democratic process ensures full vetting of matters

involving the ideal societal structure. Federal courts should not halt

these democratic principles by judicial fiat. And any social policy



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regarding definitions of marriage should come by way of democratic

processes, not judicial activism.

As Justice Black recognized, perhaps the most fundamental

individual liberty of citizens is the right of each person to participate in

the self-government of their society. In re Winship, 397 U.S. at 385

(Black, J., dissenting). The people . . . may of course be wrong in

making . . . determinations [of fairness], but the right of self-

government that our Constitution preserves is just as important as any

of the specific individual freedoms preserved in the Bill of Rights. Id.

State laws necessarily promote a vision of what is the ideal. And

different communities will have different visions of what constitutes the

ideal. The view in some communities is that marriage is only about

recognizing the emotional fulfillment of adults, separate from

encouraging a legal attachment between children and their biological

parents. The view in others is that sexual identity is inconsequential in

marriage, rendering mothers and fathers entirely interchangeable. And

all citizens are free to argue about the current understanding of the

ideal of marriage. People of good will may genuinely and reasonably

disagree about the issue without holding any sort of discriminatory



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animus. The democratic processes of this country are ill-served by the

judiciary stepping in and branding one side of the debate as irrational.

To arrogate this decision to themselves, the courts will dismiss some of

the most ancient and cherished beliefs of half of the country as animus.

Democracy should not work that way.

It is well settled that there is a basic difference between direct

state interference with a protected activity and state encouragement of

an alternative activity consonant with legislative policy. Maher v.Roe,

432 U.S. 464, 475 (1977). By preserving the definition of marriage, the

States here do not interfere with the right of adults to commit each

other to an exclusive, loving relationship. But the people of Oklahoma

and Utahlike the citizens in a majority of Stateshave established

marriage between a man and a woman as the ideal setting for the

raising of children. There is nothing unconstitutional about this

conclusion.

II.

Voters could reasonably conclude that a family with both amom and a dad is the ideal setting in which to raise

children.

The primary justification for marriage historically has been for

the procreation and rearing of children. SeeSissung v. Sissung, 31



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N.W. 770, 772 (Mich. 1887) ([T]he first purpose of matrimony, by the

laws of nature and society, is procreation.). Consequently, marriage

has always been understood to be between one man and one woman,

throughout the States from the beginning, because this was the

common-law understanding of marriage. E.g., State v. Fry,4 Mo. 120,

126 (1835) (quoting Sir Francis Bacon, 6 Bacon Abr. 523, 530 (mar-

riage is a compact between a man and a woman for the procreation and

education of children)). Underlying this definition of marriage is the

basic point that marriage between two persons of the opposite sex has

certain characteristics that make it ideal for the raising of children.

A. Marriage is rooted in the unique capacity of the unionof one man and one woman to bear children.

There are two sexes, each necessary for the procreation of

children. A man and a woman generally have the inherent ability

together to produce a child biologically connected to both parents. This

unique capacity to conceive a child is based on their complementarity in

a conjugal union. There is, of course, no obligation to have children in

marriage. But there is no dispute that it is through the sexual union of

a man and a woman that the vast majority of children are created.



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This fact has been true from the beginning of time. Thus, the

States decision to solemnize this reality by recognizing the unique

capacity of a man and woman to produce a child is a reasonable one. By

defining marriage as between one man and one woman, the State

elevates this union, identifying it as the ideal standard for families.

Case law across the country has identified this dynamic as one

reflecting the binary nature of the human procreation. SeeAndersen

v. King County,158 Wash. 2d 1, 54 (2006) (Johnson, J., concurring in

judgment) (The unique and binary biological nature of marriage and

its exclusive link with procreation and responsible child rearing has

defined the institution at common law and in statutory codes and

express constitutional provisions of many states.); Hernandez v. Robles,

7 N.Y.3d 338, 370 (2006) (Graffeo, J., concurring) (The binary nature of

marriageits inclusion of one woman and one manreflects the

biological fact that human procreation cannot be accomplished without

the genetic contribution of both a male and a female.). In other words,

sexual complementary is an irreducible difference; no other

arrangement has the capacity to create a new life, no matter how

committed or loving the relationship.



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Defining marriage as it has been defined throughout history

therefore reflects a basic reality about how children are createdin a

relationship between a man and a woman. Id.

B. The definition of marriage enables both a mom and adad to serve as role models for their children.

Historically, marriage has also provided a male and female role

modela mom and a dadfor any children born of the marriage. This

fact again is rooted in the reality of family life.

As one of their key family roles, moms and dads educate their

children and provide them with tools that assist them in reaching

adulthood. Specifically, moms and dads together teach their boys in

their transition to manhood and their girls in reaching womanhood.

And voters could reasonably believe that children benefit from having

both a male and a female example to grow up with. SeeHernandez,7

N.Y.3d at 359 (plurality opinion) (Intuition and experience suggest

that a child benefits from having before his or her eyes, every day,

living models of what both a man and a woman are like.); accord

Jackson v. Abercrombie,884 F. Supp. 2d 1065, 1116 (D. Hawaii 2012).



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In the absence of both a man and a woman, the child is missing a role

model:

The state also could have rationally concluded that childrenare benefited by being exposed to and influenced by the

beneficial and distinguishing attributes a man and a woman

individually and collectively contribute to the relationship.

[In re Marriage of J.B.and H.B., 326 S.W.3d 654, 678 (Tx.

Ct. App. 2010).]

Women and men bring unique gifts to parenting, gifts that are

different and complementary. As Justice Ginsburg explained in a

different context, Yes, men and women are persons of equal dignity

and they should count equally before the law but they are not the same.

There are differences between them that most of us value highly[.] Tr.

of Oral Arg. inDuren v. Missouri, 439 U.S. 357 (1979).

Moreover, having a dad who serves as a male role model for a

young boy in becoming a man is particularly important, as is having a

mom to serve as a female role model for a young girl. This concept

appears in cases involving divorce, termination of parental rights, or

even in evaluating mitigating factors in the sentencing phase of a

criminal case. See, e.g.,Dixon v. Houk,627 F.3d 553, 568 (6th Cir.

2010) (approvingly identifying lack of father figure as a mitigating



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factor for punishment from previous case), revd on other grounds,

Bobby v. Dixon,132 S. Ct. 26 (2011).

The conclusion that it benefits a child to have both a male and

female role model in the childs transition to adulthood is a reasonable

one. SeeLofton v. Secy of Dept of Children & Family Services, 358 F.3d

804, 819822 (11th Cir. 2004) (It is chiefly from parental figures that

children learn about the world and their place in it, and the formative

influence of parents extends well beyond the years spent under their

roof, shaping their childrens psychology, character, and personality for

years to come.). The point is that having both a mom and a dad is

beneficial for the raising of children.

To be sure, single mothers, single fathers, and same-sex couples

can be loving and nurturing parents, rearing happy, well-adjusted

children, while married, opposite-sex couples can be inadequate

parents. But there is nothing unconstitutional about a State choosing

to honor the mother-father-child relationship as an ideal family setting.



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C. Marriage enables the parents to have a biologicalrelationship with their children.

For any child born from the marital relationship between a man

and a woman, the child is the offspring of each parent. This fact creates

a bond between a child and the childs parents. SeeAndersen,158

Wash. 2d at 37 (Heterosexual couples are the only couples who can

produce biological offspring of the couple). The parents and the

children share not only a legal identity as a family but also a physical

affinity. In this way, the biological parents of a child are also the legal

parents.

In contrast, for same-sex couples, their conjugal union will never

yield a child. For any children, there will always be at least one

biological parent who is outside of the marital union, and there always

will be at least one legal parent who is not a biological one. See id.

Defining marriage to include a relationship that is not biologically

capable of producing children separates the marital sexual union from

the procreation of children. Same-sex couples must generally rely on

some artificial intervention for the conception of any child, necessarily

separating the child from one or both biological parents. Id.at 983

(single-sex couples raise children and have children with third party



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assistance or through adoption). In contrast, children routinely result

from the conjugal relationship between husband and wife. Because this

can never be true for same-sex couples, they are differently situated.

Again, this conclusion does not disparage the ability of same-sex

couples or others to provide loving homes or to establish a stable,

nurturing setting for children. The point is that the citizens of a State

may elect to encourage the ideal setting by providing legal support for

it, upholding it as the archetype for all families, and fostering it as the

optimal arrangement. The State may reasonably conclude that it is

better, other things being equal, for children to grow up with both a

mother and a father. Hernandez,7 N.Y.3d at 359 (plurality opinion).

This point is even more true where the parents are that childs

biological mother and father.

Of course, there are opposite-sex couples who are unable to have

children of their own and who adopt children. As in Michigan, see

MICH.COMP.LAWS 710.24, the laws of Oklahoma and Utah authorize

married persons or single adults to adopt children, but not two

unmarried persons. 10 Okla St. Ann. 7503-1.1; Utah Code 78B-6-

117(2), (3). This distinction reflects the fundamental difference between



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a same-sex couple and a married man and woman seeking to adopt. As

explained above, the married couples reflect the complementarity of the

sexes and offer the role modeling helpful to the optimal raising of

children. And even the marriage of a man and woman who are unable

or unwilling to have children nevertheless reinforces the family ideal by

establishing an example for other couples of the opposite sex who will

have children.

The law does not require that a married couple intend to have

children or even that the couple have a sexual relationship for a couple

to enter the married state. But the interest of the citizenry in marriage

arises from the fact that children are ordinarily born from a

relationship between a man and a woman, and voters could reasonably

seek to encourage the ideal in the raising of these children.

III. Reaffirming the definition of marriage, which excludesother relationships, is reasonable and does not denigrate

anyone.

The definition of marriage as the union of one man and one

woman has its origin in the common law. It is the foundation of society.

Maynard v. Hill,125 U.S. 190, 211 (1888) (It is an institution, in the

maintenance of which in its purity the public is deeply interested, for it



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is the foundation of the family and of society, without which there

would be neither civilization nor progress.).

Contrary to the conclusion of the federal district courts here, the

effort to reaffirm the definition of marriage is not based on animus

toward same-sex couples. It simply reflects an affirmative statement

about the best environment for raising children. In fact, the historic

definition of marriage as the union of one man and one woman long

precedes the entire debate on same-sex marriage, which has only arisen

in the last 50 years.

A. Other relationships do not share the uniquecharacteristics of marriage.

In contrast to same-sex relationships, the marriage relationship

reflects the inherent capacity of a man and a woman, based on the

complementarity of the sexes, to produce children. And in marriage

there is both a mother and a father to serve as role models for the

children, and the potential for the children to be the offspring of the

married couple. For same-sex couples, there is always an issue about

parentage. And there is always only one sex represented among the

parents. The decision of the citizens of Oklahoma, Utah, Michigan, and



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other States to promote the ideal for families by recognizing only the

union of one man and one woman in marriage rests on the benefits this

relationship offers for children.

True, many traditional families fail to meet this ideal. And many

same-sex couples provide a nurturing and loving setting for children.

But this does not answer the point. The law serves the goal of

establishing ideal standards, encouraging the public to align themselves

to these archetypes. And the State may foster the ideal for children.

The question is whether it is reasonable to believe that these

attributes of marriage, unique to the marriage of one man and one

woman, further the end of providing the ideal setting for the raising of

children. From the beginning of recorded history, this relationship has

been the hallmark of family life. Until this past century, all children

were conceived in the relationship between a man and a woman, and

the law ratified and codified the reality of an institution already in

place. The fact that other committed same-sex adults may provide a

loving setting for children does not impeach this fact.



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B. Upholding marriage is not a matter of animus.The effort to reaffirm the definition of marriage is not based in

animus toward same-sex couples or individuals who experience same-

sex attraction. Every human life has inherent dignity and is of

immense worth. Rather, the reaffirmation is a policy decision that

expresses the electorates view about the ideal of family life. See

Lawrence v. Texas,539 U.S. 558, 585 (2003) (OConnor, J., concurring)

(Unlike the moral disapproval of same-sex relationsthe asserted

state interest in [Lawrence]other reasons exist to promote the

institution of marriage beyond mere moral disapproval of an excluded

group.). These affirmative reasons, as discussed above, support the

marriage laws of Oklahoma and Utah.

Historically, the primary competing understanding of family life

has been plural marriage. More than 40 countries currently permit

plural marriage. But excluding plural marriage does not imply animus

or bigotry against cultures that tolerate plural marriage. Instead, this

reaffirmation celebrates the virtues of the union of one man and one

woman in marriage; it does not condemn other relationships.



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Significantly, a rejection by this Court of the States definition of

marriage may require the acceptance of plural marriage. The

underlying rationale for the decisions below, after all, is that two adult

persons who are dedicated to one another and seek to raise a child

should be able to marry. See, e.g., Bishop v. Smith,___ F. Supp. 2d ___;

2014 WL 116013, *33 (N.D. Okla. 2014) (the Bishop couple has been in

a loving, committed relationship for many years and cannot be

excluded from the definition of marriage without a legally sufficient

justification.). But any number of adults can be committed to one

another and seek to raise children together. Once the courts reject a

States ability to promote the view that the ideal family structure

consists of a mother, father, and children, the reasoned ability to limit

marriage to two adults is weakened. Lewis v. Harris,875 A.2d 259, 277

(N.J. Sup. Ct. 2005) (Parrillo, J., concurring) (If, for instance, marriage

were only defined with reference to emotional or financial

interdependence, couched only in terms of privacy, intimacy, and

autonomy, then what non-arbitrary ground is there for denying the

benefit to polygamous or endogamous unions whose members claim the

arrangement is necessary for their self-fulfillment?).



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In sum, a State may reasonably reserve marriage to one man and

one woman because of that relationships unique characteristics. This

union alone is inherently capable of producing life while also enabling

the married personsin the idealto have children who have a

biological relationship to each parent, who may then serve as role

models of both sexes for their children.



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CONCLUSION AND RELIEF REQUESTED

This Court should reverse the decisions of the district courts below

and affirm the constitutionality of the marriage laws in Oklahoma and

Utah.

Respectfully submitted,

Bill Schuette

Michigan Attorney General

/s/ Aaron D. Lindstrom

Aaron D. Lindstrom

Solicitor General


B. Eric Restuccia

Deputy Solicitor General

Assistant Attorneys General

Attorneys forAmicus Curiae

State of Michigan

P.O. Box 30212


(517) 373-1124

[email protected]

Dated: February 10, 2014



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CERTIFICATE OF COMPLIANCE

Certificate of Compliance with Type-Volume Limitation,

Typeface Requirements, and Type Style Requirements

1. This brief complies with the type-volume limitation of Fed.

R. App. P. 29(d) because this brief contains no more than 7,000 words,

excluding the parts of the brief exempted by Fed. R. App. P.

32(a)(7)(B)(iii). There are a total of 3,881 words.

2. This brief complies with the typeface requirements of Fed. R.

App. P. 32(a)(5) and the type style requirements of Fed. R. App. P.

32(a)(6) because this brief has been prepared in a proportionally spaced

typeface using Word 2010 in 14 point Century Schoolbook.


Aaron D. Lindstrom

Solicitor GeneralCo-Counsel of Record


State of Michigan

P.O. Box 30212


(517) 373-1124

[email protected]



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CERTIFICATE OF SERVICE

I certify that on February 10, 2014, the foregoing document was

served on all parties or their counsel of record through the CM/ECF

system if they are registered users or, if they are not, by placing a true

and correct copy in the United States mail, postage prepaid, to their

address of record.


Aaron D. Lindstrom

Solicitor General



State of Michigan

P.O. Box 30212


(517) 373-1124

[email protected]



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CERTIFICATE OF DIGITAL SUBMISSION

I hereby certify that with respect to the foregoing:

(1) all required privacy redactions have been made per 10thCir. R.

25.5;

(2) if required to file additional hard copies, that the ECF

submission is an exact copy of those documents;

(3) the digital submissions have been scanned for viruses with the

most recent version of a commercial virus scanning program, Symantec

Endpoint Protection 11.0 (February 9, 2014, r19) and according to the

program are free of viruses.


Aaron D. Lindstrom

Solicitor General



State of Michigan

P.O. Box 30212


(517) [email protected]


13-4178 Amicus Brief of State of Michigan

Documents

Transcript of 13-4178 Amicus Brief of State of Michigan