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different-sex couples through access to the status of marriage. Yet the State, without anyadequate justification, has deprived lesbian and gay Nevadans of the right to marry, or to havetheir valid marriages from other jurisdictions recognized as marriages, based solely on theirsexual orientation and sex. This discrimination (referred to herein as the State’s “marriage ban”)is enshrined both in Nevada statutes, and in article 1, section 21 of the Nevada Constitution,which limits marriage solely to couples composed of “a male and female.”3.
After barring lesbians and gay men from civil marriage, the State created analternative status that they are allowed to enter that, with only a few exceptions, provides “thesame rights, protections and benefits” and “the same responsibilities, obligations and duties . . . asare granted to and imposed upon spouses.” Nev. Rev. Stat. § 122A.200(1)(a). The State’sselective bar to access to marriage—despite a public policy recognizing that same-sex couplesmerit the same family, parenting, and relationship rights and responsibilities as different-sexspouses—serves no purpose other than to impose a stigmatizing government label of inferiorityupon lesbians and gay men and their relationships and denies Plaintiffs equal treatment based ontheir sexual orientation and sex.4.
This exclusion from marriage and relegation to a second-class status inflictsserious and irreparable harms upon Plaintiffs and other same-sex couples and their children.Plaintiffs seek equal access to the institution of marriage as the only means to fully eliminate themyriad harms inflicted by the State on them and other same-sex couples.
Plaintiffs Beverly Sevcik and Mary Baranovich are lesbian individuals who are acommitted same-sex couple residing in Carson City, Nevada.6.
Plaintiffs Antioco Carrillo and Theodore Small are gay male individuals who are acommitted same-sex couple residing in Las Vegas, Nevada.7.
Plaintiffs Karen Goody and Karen Vibe are lesbian individuals who are acommitted same-sex couple residing in Reno, Nevada.
Case 2:12-cv-00578 Document 1 Filed 04/10/12 Page 3 of 30