Ten Things the 2012–13 Term Tells Us About the Roberts Court

During the 2012–13 Term, the Court decided seventy-eight cases on the merits, an increase from the previous Term (when there were seventy-five such opinions), but still far fewer decisions than some years earlier. Almost half (49%) of the 2012–13 Term’s cases were unanimous. Harmony was not, however, the Court’s predominant mood. Nearly a third of the cases (29%) were decided by votes of 5-4—an increase of 9% from the previous Term. Another 8% of cases were decided 6-3. As has been true in previous Terms, Justice Kennedy was most often in the majority (91% of all cases and 83% in divided cases). The figures on agreement among various Justices are a bit more surprising. In prior years, we had seen the highest rate of agreement to be among pairs of Justices on the Court’s right. In the 2012–13 Term, however, it was the trio of female Justices—Ginsburg, Sotomayor, and Kagan—who most often agreed. Justice Kagan agreed with her sister Justices in 96% of cases, and Sotomayor and Ginsburg were in agreement in 94% of cases.

What does the 2012–13 Term tell us about the Roberts Court? No one Term can reveal the whole story, of course. But I venture a few observations. I style them as “Ten Things the 2012–13 Term Tells Us About the Roberts Court.”
 

United States v. Windsor And The Role Of State Law In Defining Rights Claims

The Supreme Court’s recent decision in United States v. Windsor is best understood from a Legal Process perspective. Windsor struck down Section 3 of the federal Defense of Marriage Act (“DOMA”), which defined marriage as exclusively between a man and a woman for purposes of federal law. Much early commentary, including Professor Neomi Rao’s essay in these pages, has found Justice Kennedy’s opinion for the Court to be “muddled” and unclear as to its actual rationale. But the trouble with Windsor is not that the opinion is muddled or vague; the rationale is actually quite evident on the face of Justice Kennedy’s opinion. The trouble is simply that it is not the rationale that many observers expected or wanted.

 

The Trouble With Dignity And Rights Of Recognition

In United States v. Windsor, the Supreme Court held that Section 3 of the Defense of Marriage Act violated the Fifth Amendment. This Essay examines the unusual right to recognition that forms the basis of the Court’s decision and explains how such dignity rights have a problematic relationship to individual rights and to the structural protections of federalism. A right to recognition, standing alone, has never been part of our constitutional jurisprudence. To the extent that dignitary themes arose in previous cases, they were incidental to the finding of individual rights. I argue that there is good reason why recognition has not been afforded constitutional protection. Claims for recognition are only derivative of individual rights and cannot apply universally. Moreover, the dignity of recognition, because not an individual right, creates an unresolved tension with existing state laws that prohibit same-sex marriage—a tension between the dignity of recognition and the dignity of state sovereignty.