Steven C. Berman, OSB No.

951769
Email: sberman@stollberne.com
Nadine A. Gartner, OSB No. 103864
Email: ngartner@stollberne.com
STOLL STOLL BERNE LOKTING & SHLACHTER P.C.
209 S.W. Oak Street, Suite 500
Portland, Oregon 97204
Telephone: (503) 227-1600
Facsimile: (503) 227-6840

Attorneys on behalf of Oregon United for
Marriage and Oregon Says I do





IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
EUGENE DIVISION
DEANNA L. GEIGER and JANINE M.
NELSON, ROBERT DUEHMIG and
WILLIAM GRIESAR,

Plaintiffs,

v.

JOHN KITZHABER, in his official
capacity as Governor of Oregon, ELLEN
ROSENBLUM, in her official capacity as
Attorney General of Oregon, JENNIFER
WOODWARD, in her official capacity as
State Registrar, Center for Health
Statistics, Oregon Health Authority, and
RANDY WALRUFF, in his official
capacity as Multnomah County Assessor,

Defendants.

Case No. 6:13-cv-01834-MC
(Lead Case)


OREGON SAYS I DO AND
OREGON UNITED FOR
MARRIAGE’S UNCONTESTED
MOTION FOR LEAVE TO FILE
AMICI CURIAE MEMORANDUM IN
SUPPORT OF PLAINTIFFS’
MOTIONS FOR SUMMARY
JUDGMENT AND AMICI CURIAE
MEMORANDUM

Case 6:l3-cv-02256-MC Document 56 Filed 04/0l/l4 Page l of l9 Page lD#: 653


PAUL RUMMELL and BENJAMIN
WEST; LISA CHICKADONZ and
CHRISTINE TANNER; BASIC RIGHTS
EDUCATION FUND,

Plaintiffs,

v.

JOHN KITZHABER, in his official
capacity as Governor of Oregon; ELLEN
ROSENBLUM, in her official capacity as
Attorney General of Oregon; JENNIFER
WOODWARD, in her official capacity as
State Registrar, Center for Health
Statistics, Oregon Health Authority, and
RANDY WALRUFF, in his official
capacity as Multnomah County Assessor,

Defendants.


Case No. 6:13-cv-02256-MC






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MEMORANDUM IN SUPPORT OF PLAINTIFFS’ MOTIONS FOR
SUMMARY JUDGMENT
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Oregon United for Marriage and Oregon Says I Do respectfully request that the Court
grant leave to file the attached amici curiae memorandum in support of Plaintiffs’ Motions for
Summary Judgment (“Plaintiffs’ Motions”).
Local Rule 7.1 Certification
Prior to filing this motion, Counsel for Oregon United for Marriage and Oregon Says I
Do conferred with counsel for Plaintiffs and Defendants. All have consented to the
organizations appearing as amici curiae.
Movants’ Interest and the Relevance of an Amici Curiae Memorandum
Oregon United for Marriage and Oregon Says I Do are the Oregon statewide
organizations working to qualify and pass Oregon Initiative Petition No. 8 (2014), the Freedom
to Marry and Religious Protection Initiative (the “Initiative”). The Initiative would overturn
Oregon’s constitutional same-sex marriage ban. If the Initiative qualifies for the ballot and is
approved by the voters, same-sex couples in Oregon would be granted the right to marry.
However, if the Court grants Plaintiffs’ Motions in the near future, the Initiative may become
unnecessary. Oregon Says I Do and Oregon United for Marriage seek leave to appear as amici
curiae to set forth how the timing of the Court’s decision impacts the campaign and all
Oregonians.
Movants’ Interest: Oregon Says I Do is a Petition Committee under Or. Rev. Stat.
§ 260.005(17) and Or. Rev. Stat. § 260.118. Oregon Says I Do is in the process of collecting
signatures to qualify the Initiative for the November 2014 ballot. Oregon United for Marriage is
a non-profit organization, organized under 26 U.S.C. § 501(c)(4), and registered with the Oregon
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Secretary of State. Oregon United for Marriage is comprised of a broad coalition of individuals
and entities, including: business, labor, progressive, and nonpartisan organizations; communities
of color; people of faith; current and former elected officials; students; business and community
leaders; and, members of various political parties. If the Initiative qualifies for the ballot,
Oregon United for Marriage will form a political committee to fund and run the political
campaign in support of the Initiative. Declaration of Mike Marshall in Support of Oregon Says I
Do and Oregon United for Marriage’s Motion for Leave to Appear as Amici Curie in Support of
Plaintiffs’ Motions for Summary Judgment and Amici Curiae Memorandum at ¶ 3.
Why an amici curiae memorandum is desirable and relevant: An amici curiae
memorandum is desirable and relevant because Oregon United for Marriage and Oregon Says I
Do can demonstrate to the Court that the timing of the Court’s ruling on Plaintiffs’ Motions will
determine whether the Initiative will go before the voters. If a ruling providing same-sex couples
the right to marry comes soon enough – before May 23, 2014 – then Oregon Says I Do will not
submit signatures to the Oregon Secretary of State to qualify the Initiative for the November
2014 ballot, and Oregon United for Marriage will not proceed with the subsequent political
campaign. However, if a ruling is delayed, then the Initiative campaign may go forward.
Oregon United for Marriage and Oregon Says I Do file herewith their proposed amici
curiae memorandum in support of Plaintiffs’ Motions for Summary Judgment.

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AMICI CURIAE MEMORANDUM
I. !"#$%&'(#!%"
The date the Court issues its decision on Plaintiffs’ pending summary judgment motions
(“Plaintiffs’ Motions”) may determine whether the Oregon electorate is asked to vote to amend
Oregon’s Constitution. Oregon is one of 29 states with a constitutional provision that prohibits
same-sex marriage.
1
Oregon United for Marriage and Oregon Says I Do (collectively “Oregon
United for Marriage”) are leading the campaign in support of Oregon Initiative Petition No. 8
(2014), the Freedom to Marry and Religious Protection Initiative (the “Initiative”). The
Initiative would eliminate Oregon’s constitutional same-sex marriage ban and provide full rights
and responsibilities of civil marriage to same-sex couples.
2
A timely decision from the Court
could render the Initiative unnecessary and spare all Oregonians the cost, expense and emotional
strain of a difficult election fight.
Oregon United for Marriage’s goal is to obtain marriage equality for all Oregonians by
the most expeditious means possible. In February 2013, when the campaign kicked off its efforts
to qualify the Initiative for the ballot, it was unclear whether discriminatory marriage
prohibitions such as Oregon’s could survive challenge under the United States Constitution. A
statewide initiative appeared to be the most efficient and effective way to obtain marriage

1
That prohibition is found in Article XV, section 5(a) of the Oregon Constitution. Article XV,
section 5(a) was added to the Oregon Constitution by Initiative Petition, Measure 36, in the 2004
General Election.
2
A copy of the Initiative is attached to the Declaration of Steven C. Berman in Support of Oregon
Says I Do and Oregon United for Marriage’s Motion for Leave to File Amici Curiae
Memorandum in Support of Plaintiffs’ Motion for Summary Judgment and Amici Curiae
Memorandum (“Berman Dec.”) as Exhibit 1.
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equality in Oregon. However, in the past year, a series of federal court decisions has clarified
that Oregon’s same-sex marriage ban cannot survive federal constitutional scrutiny.
Accordingly, an election on whether to allow same-sex marriage in Oregon may be unnecessary.
The campaign to qualify and pass the Initiative will be difficult and expensive, and the
outcome of an election is uncertain. Lesbian, gay, bisexual and transgender (“LGBT”)
individuals and their families’ basic civil liberties are at stake. The emotional toll of an election
would be immeasurable. Oregon taxpayers will incur significant costs associated with
conducting the election. No one gains from a potentially unnecessary election on a fundamental
human right.
The timeline for the Initiative campaign is tight. Under Oregon law, signatures to qualify
the Initiative may be submitted to the Secretary of State by May 23, 2014, and all signatures
must be submitted to the Secretary of State by July 3, 2014. Once qualification signatures are
submitted, the Initiative cannot be withdrawn, even if the Court subsequently determines that
Oregon’s same-sex marriage ban is unconstitutional.
The Court has the power to spare Oregonians the anxiety, conflict, uncertainty and costs
of an election on marriage equality. The federal courts have long been the guardians of civil
rights in this country, and this case is no exception. The Court can grant marriage equality
sooner than Oregonians can achieve it through the Initiative. If the Court grants Plaintiffs’
Motions in advance of the legal deadlines for submitting signatures, the campaign will be able to
withdraw the Initiative. The Court can provide Plaintiffs the legal relief to which they are
entitled, and spare the LGBT community, its allies, and Oregon the tremendous monetary and
emotional costs inherent to a civil rights ballot initiative campaign.
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Amici curiae recognize the burdens that this case and their request for speedy resolution
place on the Court. The legal issues are demanding and extremely important. Civil liberties and
fundamental human rights merit serious judicial contemplation and review. Fortunately, recent
federal court decisions offer meaningful guidance, plaintiffs’ counsel filed detailed memoranda
in support of their motions, and defendants also have filed detailed memoranda in which they
agree that Oregon’s same-sex marriage ban and related statutes are unconstitutional. Oregon
United for Marriage believes that those factors provide the Court the necessary information to
reach a well-reasoned but swift determination that Oregon’s constitutional same-sex marriage
prohibition and statutes that exclude same-sex couples from marriage violate the Constitution of
the United States.
II. *#+#,-,"# %. (%"*,"# %. #/, 0+$#!,*
Counsel for Plaintiffs and Defendants have each given their consent for Oregon United
for Marriage to appear in this case as amici curiae.
III. *#+#,-,"# %. +'#/%$*/!0
This brief was authored by Steven C. Berman and Nadine A. Gartner, counsel for Oregon
United for Marriage. No party or other person provided money that was intended to fund the
preparation or submission of this brief.
IV. *#+#,-,"# %. !"#,$,*#
Oregon United for Marriage is a broad coalition of individuals and organizations working
to win the freedom to marry for same-sex couples in Oregon. Oregon United for Marriage
believes that marriage and family are about love and commitment, working together, bettering
the community, raising children, and growing old together. Oregon United for Marriage further
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believes that allowing marriage licenses for same-sex couples strengthens families and
strengthens Oregon. Declaration of Mike Marshall in Support of Oregon Says I Do and Oregon
United for Marriage’s Motion for Leave to Appear as Amici Curiae in Support of Plaintiffs’
Motions for Summary Judgment and Amici Curiae Memorandum (“Marshall Dec.”) at ¶ 4.
The Court’s ruling on Plaintiffs’ Motions directly impacts Oregon United for Marriage
and its campaign in support of the Initiative. If the Court grants Plaintiffs’ Motions and same-
sex couples have immediate access to civil marriage, the Initiative will become unnecessary.
However, once the campaign submits the signatures required to qualify the Initiative for the
November 4, 2014 general election, the Initiative will appear on the ballot, regardless of the
Court’s ruling on Plaintiffs’ Motions. In other words, after signatures are submitted, the
campaign loses the ability to withdraw the Initiative and will have to pursue the campaign no
matter what the Court decides. Marshall Dec. at ¶ 5.
V. +$1'-,"#
A. Oregonians Should Not Face Further Delay in Obtaining Marriage Equality.
Marriage is a basic human right that should not be denied to anyone. “The right to marry
is of fundamental importance for all individuals.” Zablocki v. Redhall, 434 U.S. 374, 384
(1978). That right encompasses the freedom to marry the partner of one’s choosing. See
generally Loving v. Virginia, 388 U.S. 1, 12 (1967) (anti-miscegenation laws violate due
process). The Supreme Court has recognized that marriage involves one of “the most intimate
and personal choices a person may make in a lifetime.” Lawrence v. Texas, 539 U.S. 558, 574
(2003) (internal quotation marks omitted; citation omitted). The right to marry is “central to
personal dignity and autonomy . . . central to the liberty protected by the Fourteenth
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Amendment.” Id. (internal quotation marks omitted; citation omitted). “Persons in a
homosexual relationship may seek autonomy for these purposes, just as heterosexual persons
do.” Id. In its last term, the Supreme Court held that restricting the federal definition of
marriage to only heterosexual unions was unconstitutional and invalidated the Defense of
Marriage Act. United States v. Windsor, ___ U.S. ___, 133 S. Ct. 2675 (2013). District courts
around the country subsequently have declared unconstitutional same-sex marriage prohibitions
and have enjoined states from continuing to apply those prohibitions.
3

As is set forth in Plaintiffs’ Motions, Oregonians in same-sex relationships cannot legally
marry in Oregon. Oregon United for Marriage came into existence to pursue the Initiative to
remedy that injustice. However, the Initiative (if it qualifies) would not be voted on until
November 2014, and the outcome of the election is uncertain. The Court has the authority to
deliver justice much more swiftly and without the uncertainty inherent in an election. By
granting Plaintiffs’ Motions, the Court can end the current discrimination against same-sex
couples immediately. See Lee v. Orr, 2014 WL 683680 at *2 (N.D. Ill. Feb. 21, 2014) (“[t]here

3
See, e.g., Tanco v. Haslam, 2014 WL 997525 (M.D. Tenn. Mar. 14, 2014) (enjoining Tennessee
from enforcing any law that bars recognition of the plaintiffs’ same-sex marriages); De Leon v.
Perry, 2014 WL 715741 (W.D. Tex. Feb. 26, 2014) (enjoining enforcement of Texas’ ban on
same-sex marriage); Lee v. Orr, 2014 WL 683680 (N.D. Ill. Feb. 21, 2014) (granting summary
judgment in favor of the plaintiffs and declaring that Illinois’s ban on same-sex marriage violates
the Equal Protection Clause); Bostic v. Rainey, 2014 WL 561978 (E.D. Va. Feb. 13, 2014)
(finding Virginia’s law barring same-sex marriage or prohibiting Virginia’s recognition of lawful
same-sex marriages from other jurisdictions unconstitutional and enjoining Virginia from
enforcing such laws); Bishop v. United States ex rel. Holder, 962 F. Supp. 2d 1252 (N.D. Okla.
2014) (declaring that Oklahoma’s constitutional amendment barring same-sex marriage violates
the Equal Protection Clause and permanently enjoining enforcement of that law); Kitchen v.
Herbert, 961 F. Supp. 2d 1181(Utah 2013) (declaring Utah’s constitutional amendment barring
same-sex marriage unconstitutional because it denies the plaintiffs their rights to due process and
equal protection, and enjoining the state from enforcing that law).
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is no reason to delay further when . . . committed gay and lesbian couples have already suffered
from the denial of their fundamental right to marry”). There is no reason that Plaintiffs and all
other Oregonians in committed same-sex relationships should continue to be denied the right to
marry or be asked to wait until after an election in November.
B. Oregon Law Requires the Campaign to Decide Whether to Proceed with the
Initiative in the Near Future.
Oregon United for Marriage must submit signatures to qualify the Initiative no later than
July 3, 2014 and, ideally, by May 23, 2014. An initiative petition cannot be withdrawn after the
total number of signatures necessary to qualify for the ballot has been submitted to the Secretary
of State. Or. Rev. Stat. § 250.029(2). See also Oregon Secretary of State, 2014 State Initiative
and Referendum Manual at 13 (so providing);
4
Or. Admin. R. 165-014-0005(1) (designating the
2014 State Initiative and Referendum Manual “as the procedures and forms to be used for the
state initiative and referendum process”). In other words, once the signatures are submitted,
there is no way to stop the process from continuing. If the Secretary of State determines that a
sufficient number of valid signatures have been submitted, the Initiative will appear on the ballot.
Putting an initiative on a statewide ballot is a long and arduous process. Voter initiated
measures may only appear on the ballots for general elections, which occur in November of even
numbered years. Or. Const. art. IV, § 1(4)(c). An initiative to amend the Oregon Constitution
must be signed by a number of qualified voters equal to at least eight percent of the total number
of votes cast in the last gubernatorial election. Or. Const. art. IV, § 1(2)(c). For the 2014
election cycle, 116,284 signatures are required. 2014 State Initiative and Referendum Manual at

4
The 2014 State Initiative and Referendum Manual is available on line at
sos.oregon.gov/elections/documents/stateIR.pdf.
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5. Signatures must be submitted at least four months prior to the election. Or. Const. art. IV, §§
1(2)(e), 1(4)(a). For the 2014 cycle, the signature submission deadline is July 3, 2014. If
signatures are submitted more than 165 days before the election at which a proposed initiative is
to be voted on, the Secretary of State will conduct an early review of the signatures; “if the
secretary determines that insufficient signatures have been submitted, but the deadline for filing
signatures on the petition has not passed, the petitioners may submit additional signatures.” Or.
Rev. Stat. § 250.105(4). May 23, 2014 is 165 days before the November 4, 2014 election and,
accordingly, the deadline for early submission to determine whether Oregon United for Marriage
has collected a sufficient number of signatures to qualify the Initiative for the November 4, 2014
ballot.
Oregon United for Marriage and its volunteers have undertaken extensive efforts to
collect signatures for the Initiative. Signature collection for the Initiative began in earnest in July
2013, after the ballot title for the Initiative was approved by the Oregon Supreme Court. The
campaign has used paid signature collectors, but the vast majority of signatures obtained to date
have been collected by volunteers. Marshall Dec. at ¶ 7. In order to conserve financial and
volunteer resources, the campaign has paused signature collection efforts pending the outcome of
the Court’s ruling on Plaintiffs’ Motions. However, if the court rules against Plaintiffs or does
not rule swiftly, then the campaign immediately will need to resume signature collection efforts.
Specifically, the campaign will need to organize and sort the signatures it has obtained to prepare
those collected signatures for submission. Oregon United for Marriage estimates it could take
two to three weeks to prepare the signatures for submission. Marshall Dec. at ¶ 8.
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Oregon United for Marriage cannot make an informed decision about how to proceed
until the Court rules. Oregon United for Marriage does not want to pursue the Initiative if a
court ruling renders a political campaign unnecessary. But, Oregon United for Marriage will not
squander its work to date if the Court does not issue a timely ruling or an election is otherwise
necessary. Marshall Dec. at ¶ 13.
The May 23, 2014 initial submission deadline is significant for the campaign. Some of
the signatories may have moved residences since signing the petition and not re-registered to
vote, potentially disqualifying their signatures. The campaign intends to use the Secretary of
State’s early screening process to review the signatures and cure possible deficiencies. If the
campaign files signatures on May 23, 2014, the Secretary of State will process the signatures
within a couple of weeks. This means that, by mid-June, the campaign will know whether it has
sufficient valid signatures for the Initiative to qualify; if it does not, then the campaign will have
additional time, through July 3, 2014, to obtain additional signatures. Marshall Dec. at ¶¶ 9-10.
Oregon United for Marriage does not intend to pursue the Initiative if the Court grants
Plaintiffs’ Motions and same-sex couples are able to legally marry in Oregon before the filing
deadline passes. Marshall Dec. at ¶ 13. If the Court timely grants Plaintiffs’ Motions, the
campaign will be unnecessary. The financial and emotional costs associated with an election can
be avoided.
C. An Initiative Campaign Will Be Expensive for Oregonians and Oregon
Businesses.
Running a statewide campaign is costly in terms of money and labor. Oregon United for
Marriage has been preparing for those expenses for months by raising funds and recruiting
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volunteers. To date, more than 4,000 volunteers have worked on behalf of Oregon United for
Marriage, and Oregon United for Marriage has over 10,500 donors. Marshall Dec. at ¶ 14.
Oregon United for Marriage has raised over $2 million in support of the Initiative, and it
will need to raise an additional $10 million to run a successful campaign through November.
Marshall Dec. at ¶ 15. Those funds have come from individuals, families and businesses.
Oregonians are digging deeply into their personal finances in order to donate to the campaign.
Money that could be spent on one’s health care or a child’s college tuition is instead being spent
to protect that person’s or family’s legal rights.
Additionally, businesses across Oregon have donated and pledged hundreds of thousands
of dollars in support of the Initiative. Those businesses represent all sectors of Oregon’s
economy and range from neighborhood shops to Fortune 500 companies. Marshall Dec. at ¶ 16.
Oregon’s business leaders recognize that marriage for same-sex couples would put Oregon
businesses in the strongest, most competitive position to attract, recruit and retain the best and
brightest employees, and to keep talent in the state. Eliminating the taint of discriminatory
policies will help employers hire and retain the most qualified pool of employees and will
encourage business to relocate to Oregon. Oregon business will benefit from speedy resolution
of Plaintiffs’ Motions.
D. A Ballot Initiative Costs the State and Taxpayers.
A statewide election on an Initiative has significant costs for the State of Oregon. The
State, through the Office of the Secretary of State’s Elections Division, administers elections,
and prints and distributes voters’ pamphlets. The Secretary of State does not maintain detailed
information on the expenses associated with an election on a statewide initiative petition.
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However, distributing voters’ pamphlets and ballots to over 2 million registered voters, and
subsequently tallying their votes, is not inexpensive.
E. Continued State Discrimination Adversely Impacts the LGBT Community
and Particularly LGBT Youth.
Discriminatory state policies place members of Oregon’s LGBT community at significant
risk. “Recent research has shown that social policies negatively targeting gays and lesbians,
including constitutional amendments banning same-sex marriage . . . are robust predictors of
psychiatric morbidity among LGB adults.” Mark L. Hatzenbuehler, Ph.D. and Katherine M.
Keyes, Ph.D., Inclusive Anti-bullying Policies and Reduced Risk of Suicide Attempts in Lesbian
and Gay Youth, 53 J. Adolescent Health S21, S22 (2013) (footnotes omitted).
5
Simply put,
lesbian, gay and bisexual (“LGB”) adults in states with same-sex marriage bans are more likely
to suffer from mental illness than lesbian, gay and bisexual adults in states without such bans.
The impact of discriminatory marriage laws may be even more devastating on lesbian,
gay and bisexual youth. According to a recent study, “the risk of suicide attempts was 20%
higher among LGB youths living in communities characterized by lower support for gays and
lesbians (e.g. counties with a lower density of same-sex couples and fewer schools with
protective policies), compared with LGB youths living in more supportive communities.”
Inclusive Anti-bullying Policies at S24 (footnote omitted). In Oregon, suicide is the second
leading cause of death for people aged 15-24 years old, and the attempted suicide rate of LGB
youth is more than twice that of heterosexual youth. Oregon Health Authority, Healthy People

5
A copy of Dr. Hatzenbuehler and Dr. Keyes’ analysis is attached to the Berman Dec. as Exhibit
2.
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2020: Critical Indicators for Adolescents and Young Adults (June 2012) at 1-2.
6
In 2008,
among eleventh graders in Oregon who attempted suicide once in the past year, about 2.5%
identified as heterosexual whereas about 10% identified as lesbian, gay, or bisexual. Id. at 2.
For those who attempted suicide two or more times, about 2% identified as heterosexual, about
22% identified as gay or lesbian, and about 12% identified as bisexual. Id.
There is a substantial “geographic variation” in the prevalence of suicide attempts by
lesbian and gay adolescents. The more inclusive the setting, the less likely a lesbian or gay
adolescent is to attempt suicide. In other words, suicide rates among lesbian and gay youth
decrease in communities where inclusive measures are taken. Inclusive Anti-bullying Polices, at
S24.
7
When inclusive social policies are adopted, the potential for lesbian and gay youth
suffering debilitating psychological harm is reduced. One simple, pragmatic way to lessen
suicide attempts among lesbian and gay youth is to eliminate discriminatory laws.
Oregon’s same-sex marriage ban is a social policy that deprives Oregon’s LGBT
community from the “status and dignity” that civil marriage confers. Windsor, 133 S. Ct. at
2689. See also id. at 2694 (“[r]esponsibilities, as well as rights, enhance the dignity and integrity
of the person”); State Defendants’ Response to Motion for Summary Judgment [Dkt. #64] at 24-
25 (discussing harm Oregon’s same-sex marriage ban causes children). There is a substantial
risk that feelings of isolation and alienation experienced by LGBT individuals, and particularly

6
A copy of the Oregon Heath Authority’s report is attached to the Berman Dec. as Exhibit 3.
7
For example, “[w]hereas 31% of lesbian and gay adolescents attempted suicide in counties
where school districts were the least likely to adopt inclusive anti-bullying policies, only 17%
attempted suicide in counties with the greatest proportion of school districts with inclusive
policies.” Inclusive Anti-bullying Policies, at S24. Additionally, “peer victimization of all youth
was also less likely to occur in counties with inclusive anti-bullying policies.” Id.
Case 6:l3-cv-02256-MC Document 56 Filed 04/0l/l4 Page l5 of l9 Page lD#: 667
Page 12 – AMICI CURIAE MEMORANDUM OF OREGON SAYS I DO AND
OREGON UNITED FOR MARRIAGE
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LGBT youth, are exacerbated by Oregon’s constitutionally enshrined discriminatory marriage
ban. For those individuals particularly at risk, time may be a life-determining factor. Enjoining
Oregon’s discriminatory policies may well prevent on-going mental harm to LGBT Oregonians.
F. Voting on a Group’s Civil Rights Makes That Group Vulnerable and Divides
Communities.
Vindicating civil rights at the ballot box comes with substantial social costs. If an
election is the only way to obtain equal treatment under the law, then Oregon United for
Marriage will so proceed. The LGBT community and its supporters will not sit idly by and
allow this grave social injustice to continue indefinitely. The long-term harm that comes from
ongoing discrimination is greater than the immediate harm that will occur during an election
battle. However, the harm that will occur during an election battle is substantial, and the Court
can prevent that harm by ruling swiftly on Plaintiffs’ Motions.
Members of the LGBT community and their families pay a high emotional price when
their basic civil rights are up for debate. “While a referendum might seem like a democratic way
to decide a highly controversial issue, experience with past referenda on gay issues in other states
shows a clear and disturbing down side to the process of voting on a group’s civil rights.”
Glenda M. Russell, The Dangers of a Same-Sex Marriage Referendum for Community and
Individual Well-Being: A Summary of Research Findings, 7 The Policy Journal for the Institute
for Gay and Lesbian Strategic Studies 1, 1 (June 2004).
8

Voting on a group’s civil rights brings out the hostile and extreme rhetoric that has
become commonplace in the political arena, and that rhetoric damages all participants in the

8
A copy of Dr. Russell’s article is attached to the Berman Dec. as Exhibit 4.
Case 6:l3-cv-02256-MC Document 56 Filed 04/0l/l4 Page l6 of l9 Page lD#: 668
Page 13 – AMICI CURIAE MEMORANDUM OF OREGON SAYS I DO AND
OREGON UNITED FOR MARRIAGE
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debate. “The net effect of such rhetoric is the dissemination of misinformation that revives old
prejudices and reinforces divisions within communities.” The Dangers of a Same-Sex Marriage
Referendum at 2 (citation omitted). Supporters of an LGBT rights initiative are negatively, and
often hostilely, portrayed by opponents. Id. LGBT people are dehumanized. “LGBT people, in
particular, are rendered as the ‘other’ – objectified, disenfranchised, and ultimately treated as
non-persons.” Id. at 2 (citation omitted). Children of LGBT adults encounter ridicule at school.
Id. at 3. The effects on individuals are long-lasting. Citizens “in Colorado report continuing
alienation and isolation more than ten years after a 1992 referendum on gay issues in that state.”
Id. at 3 (citation omitted). Statewide votes on LGBT rights also can negatively impact the
greater community. “Elections that call into question the rights of LGBT people create sharp
divisions in communities.” Id. at 1. “In places where LGBT rights have become the focus of
political debate, once-friendly neighborhood networks were disrupted and fear and hostility
became more commonplace in communities.” Id. (citation omitted). The rhetoric and
divisiveness surrounding the vote in Oregon on Measure 36 in 2004 was not a fluke.
9
If the
court rules quickly on Plaintiffs’ Motions, Oregon can secure marriage equality without the
hostility surrounding a statewide election.
LGBT individuals suffer long-lasting harm from discriminatory state policies. The ballot
box is one way to eliminate those policies, although the ballot box is far from ideal. LGBT
individuals, families, their allies and the community are negatively affected when marriage
equality is put to a statewide vote. There are, of course, circumstances where an election is the

9
See Memorandum in Support of Motion for Summary Judgment [Dkt. #44] at 7-9 (discussing
campaign in support of Measure 36).
Case 6:l3-cv-02256-MC Document 56 Filed 04/0l/l4 Page l7 of l9 Page lD#: 669
Page 14 – AMICI CURIAE MEMORANDUM OF OREGON SAYS I DO AND
OREGON UNITED FOR MARRIAGE
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only means available to change social policy. In those circumstances, the shorter-term
consequences of an election (with a positive outcome) outweigh the longer-term consequences of
allowing discriminatory policies to continue unabated. Although Oregon United for Marriage is
responsible for bringing the Initiative to the public, that ballot measure has always been a means
to an end. When the effort behind the Initiative began, holding a public vote seemed to be the
best route to marriage equality. However, that is not necessarily the case now, because of recent
clarification in federal law following the Supreme Court’s decision in Windsor. Oregon United
for Marriage will proceed with an election, if necessary. However, the Court can eliminate
Oregon’s unconstitutional discriminatory same-sex marriage ban and spare Oregon the burdens
of an election by acting swiftly on Plaintiffs’ Motions.
G. This Court Is Best Suited to Grant Same-Sex Couples Access to Marriage.
A statewide campaign to win the right to marry for same-sex couples would come at a
great cost to Oregon individuals, businesses, communities, and the State. Moreover, the outcome
of the election is uncertain.
“One of the court’s main responsibilities is to ensure that individuals are treated
equally under the law. Equal treatment of all individuals under the law is not
merely an aspiration – it is a constitutional mandate.”
De Leon v. Perry, 2014 WL 715741 at *27 (W.D. Tex. Feb. 26, 2014). Amici curiae respectfully
submit that the Court is best-suited to ensure immediately that same-sex couples are treated
equally under the law.
Case 6:l3-cv-02256-MC Document 56 Filed 04/0l/l4 Page l8 of l9 Page lD#: 670
Page 15 – AMICI CURIAE MEMORANDUM OF OREGON SAYS I DO AND
OREGON UNITED FOR MARRIAGE
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VI. (%"(2'*!%"
For the reasons stated above, amici curiae respectfully request that the Court grant
Plaintiffs’ Motions as soon as practicable.
DATED this 1
st
day of April, 2014.
STOLL STOLL BERNE LOKTING & SHLACHTER P.C.


By: /s/ Steven C. Berman
Steven C. Berman, OSB No. 951769
Nadine A. Gartner, OSB No. 103864

209 SW Oak Street, Suite 500
Portland, OR 97204
Telephone: (503) 227-1600
Facsimile: (503) 227-6840
Email: sberman@stollberne.com
Email: ngartner@stollberne.com

Attorneys on behalf of Oregon United for Marriage and
Oregon Says I Do
Case 6:l3-cv-02256-MC Document 56 Filed 04/0l/l4 Page l9 of l9 Page lD#: 67l

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Steven C. Berman, OSB No. 951769
Email: sberman@stollberne.com
Nadine A. Gartner, OSB No. 103864
Email: ngartner@stollberne.com
STOLL STOLL BERNE LOKTING & SHLACHTER P.C.
209 S.W. Oak Street, Suite 500
Portland, Oregon 97204
Telephone: (503) 227-1600
Facsimile: (503) 227-6840

Attorneys on behalf of Oregon United for
Marriage and Oregon Says I do





IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
EUGENE DIVISION
DEANNA L. GEIGER and JANINE M.
NELSON, ROBERT DUEHMIG and
WILLIAM GRIESAR,

Plaintiffs,

v.

JOHN KITZHABER, in his official
capacity as Governor of Oregon, ELLEN
ROSENBLUM, in her official capacity as
Attorney General of Oregon, JENNIFER
WOODWARD, in her official capacity as
State Registrar, Center for Health
Statistics, Oregon Health Authority, and
RANDY WALRUFF, in his official
capacity as Multnomah County Assessor,

Defendants.

Case No. 6:13-cv-01834-MC
(Lead Case)


DECLARATION OF MIKE
MARSHALL IN SUPPORT OF
OREGON SAYS I DO AND
OREGON UNITED FOR
MARRIAGE’S MOTION FOR
LEAVE TO APPEAR AS AMICI
CURIAE IN SUPPORT OF
PLAINTIFFS’ MOTIONS FOR
SUMMARY JUDGMENT AND
AMICI CURIAE MEMORANDUM
Case 6:l3-cv-0l834-MC Document 67 Filed 04/0l/l4 Page l of 6 Page lD#: 677

!"#$$ !"#$$ &'()' $#*"+), - !.$/0."'( 1202
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Page 1 - DECLARATION OF MIKE MARSHALL





PAUL RUMMELL and BENJAMIN
WEST; LISA CHICKADONZ and
CHRISTINE TANNER; BASIC RIGHTS
EDUCATION FUND,

Plaintiffs,

v.

JOHN KITZHABER, in his official
capacity as Governor of Oregon; ELLEN
ROSENBLUM, in her official capacity as
Attorney General of Oregon; JENNIFER
WOODWARD, in her official capacity as
State Registrar, Center for Health
Statistics, Oregon Health Authority, and
RANDY WALRUFF, in his official
capacity as Multnomah County Assessor,

Defendants.


Case No. 6:13-cv-02256-MC


I, Mike Marshall, declare:
1. This declaration is based on my personal knowledge, and, if called to testify to the
following facts, I could and would competently do so. I submit this declaration in support of
Oregon Says I Do and Oregon United for Marriage’s Motion for Leave to Appear as Amici
Curiae in Support of Plaintiffs’ Motions for Summary Judgment and Amici Curiae
Memorandum.
2. I am the campaign manager for Oregon United for Marriage.
3. Oregon Says I Do is a Petition Committee organized under Or. Rev. Stat.
§ 260.005(17) and Or. Rev. Stat. § 260.118. Oregon Says I Do is in the process of collecting
signatures to qualify Oregon Initiative Petition No. 8 (2014), the Freedom to Marry and
Religious Protection Initiative (the “Initiative”), for the November 2014 ballot.
Case 6:l3-cv-0l834-MC Document 67 Filed 04/0l/l4 Page 2 of 6 Page lD#: 678

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Page 2 - DECLARATION OF MIKE MARSHALL



4. Oregon United for Marriage is a non-profit organization, organized under 26
U.S.C. § 501(c)(4), and registered with the Oregon Secretary of State. Oregon United for
Marriage is comprised of a broad coalition of individuals and entities, working to win the
freedom to marry for same-sex couples in Oregon. Oregon United for Marriage includes:
business, labor, progressive, and nonpartisan organizations; communities of color; people of
faith; current and former elected officials; students; business and community leaders; and,
members of various political parties. Oregon United for Marriage believes that marriage and
family are about love and commitment, working together, bettering the community, raising
children, and growing old together. Oregon United for Marriage further believes that allowing
marriage licenses for same-sex couples strengthens families and strengthens Oregon. If the
Initiative qualifies for the ballot, Oregon United for Marriage will form a political committee to
fund and run the political campaign in support of the Initiative.
5. Throughout this declaration, I refer to Oregon Says I Do and Oregon United for
Marriage collectively as “Oregon United for Marriage” or “the campaign,” unless the context
requires otherwise.
6. If the Court grants Plaintiffs’ Motions for Summary Judgment (“Plaintiffs’
Motions”) and same-sex couples have immediate access to civil marriage, the Initiative will
become unnecessary. However, under Oregon statutes and rules adopted by the Oregon
Secretary of State, once the campaign submits the signatures required to qualify the Initiative for
the November 4, 2014 general election, the Initiative will appear on the ballot, regardless of the
Court’s ruling on Plaintiffs’ Motions. In other words, after signatures are submitted, the
campaign loses the ability to withdraw the Initiative and will have to pursue the campaign no
matter what the Court decides.
Case 6:l3-cv-0l834-MC Document 67 Filed 04/0l/l4 Page 3 of 6 Page lD#: 679

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Page 3 - DECLARATION OF MIKE MARSHALL



7. Signature collection for the Initiative began in earnest in July 2013, after the
ballot title for the Initiative was approved by the Oregon Supreme Court. The campaign has
used paid signature collectors, but almost all of the signatures obtained to date have been
collected by volunteers.
8. In order to conserve financial and volunteer resources, the campaign has paused
signature collection pending the outcome of the Court’s ruling on Plaintiffs’ Motions. However,
if the Court rules against Plaintiffs or does not rule swiftly, then the campaign immediately will
need to resume signature collection efforts. Specifically, the campaign will need to organize and
sort through the signatures it has obtained in order to prepare the signatures for submission to the
Secretary of State. That is a substantial task, and one that the campaign estimates could take two
to three weeks.
9. There are two deadlines for submitting signatures on the Initiative to the Secretary
of State. The initial submission deadline is May 23, 2014. If the campaign files signatures on or
before May 23, 2014, the Secretary of State will conduct an early review of the signatures. If the
Secretary of State determines that insufficient signatures have been submitted and the final
deadline for submitting signatures has not passed, then the campaign may obtain and submit
additional signatures.
10. The May 23, 2014 initial submission deadline is significant for the campaign.
Some of the Oregon electors who signed the Initiative may have moved residences since signing
the Initiative and not re-registered to vote, which could disqualify their signatures. The
campaign intends to use the Secretary of State’s early screening process to review the signatures
and cure possible deficiencies. If the campaign files signatures on May 23, 2014, the Secretary
of State will process the signatures within a couple of weeks. This means that, by mid-June, the
Case 6:l3-cv-0l834-MC Document 67 Filed 04/0l/l4 Page 4 of 6 Page lD#: 680

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Page 4 - DECLARATION OF MIKE MARSHALL



campaign will know whether it has sufficient valid signatures for the Initiative to qualify; if it
does not, then the campaign will have additional time, through July 3, 2014, to obtain additional
signatures.
11. July 3, 2014 is the final deadline for submitting signatures. Signatures cannot be
submitted after that date.
12. As I stated above, Oregon United for Marriage will need to begin the process of
preparing signatures for submission well in advance of the deadlines. Signature sheets must be
presented to the Secretary of State pursuant to certain rules and statutes.
13. Oregon United for Marriage cannot make a fully informed decision about how to
proceed, absent a timely decision from the Court. Oregon United for Marriage does not intend to
pursue the Initiative if the Court grants Plaintiffs’ Motions and same-sex couples are able to
legally marry in Oregon before the filing deadlines pass.
14. To date, more than 4,000 volunteers have worked on behalf of the campaign, and
the campaign has over 10,500 donors.
15. Oregon United for Marriage has raised over $2 million in support of the Initiative,
and it will need to raise an additional $10 million to run a successful campaign through
November.
16. Businesses across Oregon have donated or pledged hundreds of thousands of
dollars in support of the Initiative. These businesses represent all sectors of Oregon’s economy
and range from neighborhood shops to Fortune 500 companies.
/ / / /
/ / / /
Case 6:l3-cv-0l834-MC Document 67 Filed 04/0l/l4 Page 5 of 6 Page lD#: 68l

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Page 5 - DECLARATION OF MIKE MARSHALL



Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing
is true and correct.

DATED this 1
st
day of April, 2014.



/s/ Mike Marshall
Mike Marshall

Case 6:l3-cv-0l834-MC Document 67 Filed 04/0l/l4 Page 6 of 6 Page lD#: 682
1
Danielle M. Luethe
From: Steve Berman
Sent: Tuesday, April 01, 2014 9:39 AM
To: Danielle M. Luethe
Subject: FW: Activity in Case 6:13-cv-01834-MC Geiger et al v. Kitzhaber et al Declaration


From: info@ord.uscourts.gov [mailto:info@ord.uscourts.gov]
Sent: Tuesday, April 01, 2014 9:37 AM
To: nobody@ord.uscourts.gov
Subject: Activity in Case 6:13-cv-01834-MC Geiger et al v. Kitzhaber et al Declaration

This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to
this e-mail because the mail box is unattended.
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not
apply.
U.S. District Court
District of Oregon
Notice of Electronic Filing

The following transaction was entered by Berman, Steven on 4/1/2014 at 9:36 AM PDT and filed on 4/1/2014
Case Name: Geiger et al v. Kitzhaber et al
Case Number: 6:13-cv-01834-MC
Filer: Oregon Says I Do
Oregon United for Marriage
Document Number: 67
Docket Text:
Declaration of Mike Marshall in Support of Oregon Says I Do and Oregon United for Marriage's
Motion for Leave to File Amici Curiae Memorandum in Support of Plaintiffs' Motions for
Summary Judgment and Amici Curiae Memorandum. Filed by Oregon Says I Do, Oregon
United for Marriage. (Related document(s): Motion for Leave, (56 in 6:13-cv-02256-MC, 66 in
6:13-cv-01834-MC).)Associated Cases: 6:13-cv-01834-MC, 6:13-cv-02256-MC (Berman, Steven)
Case Name: Rummell et al v. Kitzhaber et al
Case Number: 6:13-cv-02256-MC
Filer: Oregon Says I Do
Oregon United for Marriage
Document Number: 57
2
Docket Text:
Declaration of Mike Marshall in Support of Oregon Says I Do and Oregon United for Marriage's
Motion for Leave to File Amici Curiae Memorandum in Support of Plaintiffs' Motions for
Summary Judgment and Amici Curiae Memorandum. Filed by Oregon Says I Do, Oregon
United for Marriage. (Related document(s): Motion for Leave, (56 in 6:13-cv-02256-MC, 66 in
6:13-cv-01834-MC).)Associated Cases: 6:13-cv-01834-MC, 6:13-cv-02256-MC (Berman, Steven)

6:13-cv-01834-MC Notice has been electronically mailed to:

Anna M. Joyce anna.joyce@doj.state.or.us

Jennifer J. Middleton jjls@justicelawyers.com, jmiddleton@justicelawyers.com,
pjenkins@justicelawyers.com

Katharine Von Ter Stegge katevts@multco.us, amy.goodale@multco.us

Kevin Diaz kdiaz@aclu-or.org

Kristina J. Holm KJHolm@perkinscoie.com, DAnderson@perkinscoie.com, docketpor@perkinscoie.com

Lake James H. Perriguey lake@law-works.com

Lea Ann Easton leaston@dorsayindianlaw.com, jj@dorsayindianlaw.com, kellyd@dorsayindianlaw.com

Mary Williams mary_h_williams@msn.com

Misha A.D. Isaak MIsaak@perkinscoie.com, docketpor@perkinscoie.com, maguero@perkinscoie.com,
sroberts@perkinscoie.com

Nadine A. Gartner ngartner@stollberne.com, tkim@stollberne.com

Sheila H. Potter sheila.potter@doj.state.or.us, mary.c.hamilton@doj.state.or.us,
samantha.moon@doj.state.or.us, shiori.iinuma@doj.state.or.us

Steven C. Berman sberman@stollberne.com, jsloan@stollberne.com

Thomas R. Johnson TRJohnson@perkinscoie.com, ADargis@perkinscoie.com, ajaclark@perkinscoie.com,
docketpor@perkinscoie.com, skroberts@perkinscoie.com

6:13-cv-01834-MC Notice will not be electronically mailed to:

6:13-cv-02256-MC Notice has been electronically mailed to:

Amanda C. Goad agoad@aclu.org, aspiegel@aclu.org

Anna M. Joyce anna.joyce@doj.state.or.us

Jennifer J. Middleton jmiddleton@justicelawyers.com, jjls@justicelawyers.com,
pjenkins@justicelawyers.com

3
Katharine Von Ter Stegge katevts@multco.us, amy.goodale@multco.us

Kevin Diaz kdiaz@aclu-or.org

Kristina J. Holm KJHolm@perkinscoie.com, DAnderson@perkinscoie.com, docketpor@perkinscoie.com

Lake James H. Perriguey lake@law-works.com

Mary Williams mary_h_williams@msn.com

Misha A.D. Isaak MIsaak@perkinscoie.com, docketpor@perkinscoie.com, maguero@perkinscoie.com,
sroberts@perkinscoie.com

Nadine A. Gartner ngartner@stollberne.com, tkim@stollberne.com

Rose A. Saxe rsaxe@aclu.org

Sheila H. Potter sheila.potter@doj.state.or.us, mary.c.hamilton@doj.state.or.us,
samantha.moon@doj.state.or.us, shiori.iinuma@doj.state.or.us

Steven C. Berman sberman@stollberne.com, jsloan@stollberne.com

Thomas R. Johnson TRJohnson@perkinscoie.com, ADargis@perkinscoie.com, ajaclark@perkinscoie.com,
docketpor@perkinscoie.com, skroberts@perkinscoie.com

6:13-cv-02256-MC Notice will not be electronically mailed to:
The following document(s) are associated with this transaction:
Document description:Main Document
Original filename:Not Available
Electronic document Stamp:
[STAMP ordStamp_ID=875559790 [Date=4/1/2014] [FileNumber=4708209-0] [2
886a94fb6d27ef62f938185c55d9634d3cd126918633840a907f1f95e692d46b28b4b2
f6579262315dcbae3449b4e997ec16ce0cd3cea756f995ee199b3cc6d]]


!"#$$ !"#$$ &'()' $#*"+), - !.$/0."'( 1202
345 !262 #/* !"(''"7 !8+"' 944
1#("$/):7 #(',#) 5;34<
"'$2 =94>? 33;@AB44 C/D =94>? 33;@BE<4

Steven C. Berman, OSB No. 951769
Email: sberman@stollberne.com
Nadine A. Gartner, OSB No. 103864
Email: ngartner@stollberne.com
STOLL STOLL BERNE LOKTING & SHLACHTER P.C.
209 S.W. Oak Street, Suite 500
Portland, Oregon 97204
Telephone: (503) 227-1600
Facsimile: (503) 227-6840

Attorneys on behalf of Oregon United for
Marriage and Oregon Says I do





IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
EUGENE DIVISION
DEANNA L. GEIGER and JANINE M.
NELSON, ROBERT DUEHMIG and
WILLIAM GRIESAR,

Plaintiffs,

v.

JOHN KITZHABER, in his official
capacity as Governor of Oregon, ELLEN
ROSENBLUM, in her official capacity as
Attorney General of Oregon, JENNIFER
WOODWARD, in her official capacity as
State Registrar, Center for Health
Statistics, Oregon Health Authority, and
RANDY WALRUFF, in his official
capacity as Multnomah County Assessor,

Defendants.

Case No. 6:13-cv-01834-MC
(Lead Case)


DECLARATION OF STEVEN C.
BERMAN IN SUPPORT OF
OREGON SAYS I DO AND
OREGON UNITED FOR
MARRIAGE’S MOTION FOR
LEAVE TO FILE AMICI CURIAE
MEMORANDUM IN SUPPORT OF
PLAINTIFFS’ MOTIONS FOR
SUMMARY JUDGMENT AND
AMICI CURIAE MEMORANDUM.
Case 6:l3-cv-0l834-MC Document 68 Filed 04/0l/l4 Page l of 3 Page lD#: 683

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Page 1 - DECLARATION OF STEVEN C. BERMAN





PAUL RUMMELL and BENJAMIN
WEST; LISA CHICKADONZ and
CHRISTINE TANNER; BASIC RIGHTS
EDUCATION FUND,

Plaintiffs,

v.

JOHN KITZHABER, in his official
capacity as Governor of Oregon; ELLEN
ROSENBLUM, in her official capacity as
Attorney General of Oregon; JENNIFER
WOODWARD, in her official capacity as
State Registrar, Center for Health
Statistics, Oregon Health Authority, and
RANDY WALRUFF, in his official
capacity as Multnomah County Assessor,

Defendants.


Case No. 6:13-cv-02256-MC


I, Steven C. Berman, declare:
1. I am a lawyer with Stoll Berne, counsel for Oregon Says I Do and Oregon United
for Marriage in this matter. This declaration is based on my personal knowledge, and, if called
to testify to the following facts, I could and would competently do so. I submit this declaration
in support of Oregon Says I Do and Oregon United for Marriage’s Motion for Leave to Appear
as Amici Curiae in Support of Plaintiffs’ Motions for Summary Judgment and Amici Curiae
Memorandum.
2. Attached hereto as Exhibit 1 is a true and correct copy of Oregon Initiative
Petition No. 8 (2014), entitled the Freedom to Marry and Religious Protection Initiative.
3. Attached hereto as Exhibit 2 is a true and correct copy of an article by Mark L.
Hatzenbuehler, Ph.D. and Katherine M. Keyes, Ph.D. entitled “Inclusive Anti-bullying Policies
Case 6:l3-cv-0l834-MC Document 68 Filed 04/0l/l4 Page 2 of 3 Page lD#: 684

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Page 2 - DECLARATION OF STEVEN C. BERMAN



and Reduced Risk of Suicide Attempts in Lesbian and Gay Youth,” published in the Journal of
Adolescent Health, Volume 53 (2013).
4. Attached hereto as Exhibit 3 is a true and correct copy of a publication by the
Oregon Health Authority entitled “Healthy People 2020: Critical Indicators for Adolescents and
Young Adults,” dated June 2012.
5. Attached hereto as Exhibit 4 is a true and correct copy of an article by Glenda M.
Russell entitled “The Dangers of a Same-Sex Marriage Referendum for Community and
Individual Well-Being: A Summary of Research Findings,” published in The Policy Journal of
the Institute for Gay and Lesbian Strategic Studies, Volume 7, Issue 1 (June 2004).
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing
is true and correct.

DATED this 1
st
day of April, 2014.



/s/ Steven C. Berman
Steven C. Berman
Case 6:l3-cv-0l834-MC Document 68 Filed 04/0l/l4 Page 3 of 3 Page lD#: 685
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Case 6:l3-cv-0l834-MC Document 68-l Filed 04/0l/l4 Page l of 2 Page lD#: 686
Article XV, section 5(a). Folicy regarding marriage. lt-ie-the
iea
m+n+
n shall-be valid or
ma++age' lt is the
policy
of the State of
Oregon to recognize and
protect the right to marry, while also
preserving and
protecting the right of religious institutions and
clergy to refuse to
perforrn a marriage.
(1) Right to Marry: The state and its political subdivisions
shafl issue marriage licenses to all couples who othenruise
meet the requirements of Oregon law regarding age,
marital status, capacity to consent to marriage, and
degree of kinship.
(2) Religious Protection: The existing right of religious
institutions and clergy to refuse to perform a marriage
shall be protected,
(3) Non-Discrimination: All legally valid marriages shall
be treated equally under the law.
u'o",.i#áJffirrrnn
P
s_
ü/u
T,T
glr
trilt
03/{/3cJu
\
Exhibit 1
Page 1 of 1
Case 6:l3-cv-0l834-MC Document 68-l Filed 04/0l/l4 Page 2 of 2 Page lD#: 687
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Case 6:l3-cv-0l834-MC Document 68-2 Filed 04/0l/l4 Page l of 7 Page lD#: 688
Jourrral of Adolesceut Healtlì 53 (2013) 521
*526
ELSEVIER
.IOUIìNAI, OI'
ADOLESCENT
HEAXTH
www.jahonline.org
Original article
Inclusive Anti-bullying Policies and Reduced Risk of Suicide Attempts
in Lesbian and Gay Youth
Mark L. Hatzenl¡uehler, Ph.D."'*, and l(atherine M. l(eyes, Ph.D.b
aDepartment
ofSociomedical Sciences, Columbio University, New York, New Yotk
b
Deportntent of Epídeníolog, Colutnbío lJniversity, New York, New York
Article history: Received
lune
7,2O72; Accepted Augrsst 23,2012
Ikywords: Anti-bullying policies; Sexual orientation; Suicide attempts
ABSTRACT
Purpose: To evaluate whether anti-bullying policies that are inclusive of sexual orientation are associated
with a reduced prevalence of suicide attempts among lesbian, gay, and bisexual youths.
Methods:Atotal of 31,852 11th-grade public school students (1,413 lesbian, gay, and bisexual individuals;
4.4%) in Oregon completed the Oregon Healthy Teens survey in 2006-2008. The independent variable was
the proportion of school districts in tl-re 34 counties participatirlg in the Oregon Healthy Teens survey that
adopted anti-bullying policies inclusive of sexual orientation. The outcome measure was any self-reported
suicide attempt in the past 12 months. We stratified lesults by sexual orientation.
Results: Lesbian and gay youths living in counties with fèwer school districts with inclusive anti-bullying
policies were 2.25 times (95% confidence interval
[CIl,
1.13-4.49) more likely to have attempted suicide
in the past year compared with those living in counties where more districts had these policies. Inclusive
anti-bullying policies were significantly associated with a reduced lisk for suicide altempts among lesbian
and gay youths, even after controlling for sociodemographic characteristics (sex, race/ethnicity) and expo-
sure to peer victimization (odds ratio, .18', 95% Cl, .03-.92). In contrast, anti-bullying policies that did not
include sexual orientation were not associated witl-r lower suicide attempts among lesbian and gay youths
(odds ratio, .38;95% Cl, .02-7.33).
Conclusions: Inclusive anti-bullying policies may exert protective effects for the mental health of lesbian
and gay youths, including reducir.rg their risk for suicide attempts.
@ 2013 Society for Adolescent Health and Medicine. All rights reserved.
Amidst several widely publicized suicides among adolescents
with a minority sexual orientation in the past year and a half
[1],
there has been a national conversation about what can be done
to reduce and prevent suicides among lesbian, gay, and bisexual
(LGB) youths. Within this context, several individuals have
initiated court cases against school districts whose policies may
TIìe autllors declare no conflicts of interest.
Publication of this artlcle was supported by the Centers for Disease Control and
Prevention. The opinions or views expressed in th¡s paper are those of the
authors and do not necessarily represent the ofñcial position of the Centers for
Disease Control and Preventiorl
*
Address correspondence to: Mark L. Hatzenbuehler, Plì.D, Department of
Sociornedical Scielrces, Maillnatr School oI Pul¡lic Health, Columl]ia University.
722 Wesr 168th Street, Room 549 B, New Yorl<, NY 10032
E-mail address: mlh2101@columbia edu (M.L. Hatzenbuehler).
1054-139X/$
-
see front matter o 2013 Society for Adolescent Health and Medic¡ne. All rights reserved.
http://dx.doi.org/1 0.101 6/j jadohealth.20l 2.08.01 0
have harmed LGB students by their failure to adopt policies that
protect LGB youths
[2],
including inclusive anti-bullying policies
[3].
Although social science data are frequently used in court
cases involving issues related to sexual orientation
[4,5],
there is
currently a paucity of research examining the associations
between anti-bullying policies and mental health outcomes for
LGB students upon which to inform policy recommendations.
The goal of the present study was to address this gap in the
literature.
Evaluating the associations between anti-bullying policies
and LGB youths' mental health has important implications for
etiologic and prevention research. Population-based studies of
adolescents in the United States have consistently shown that
LGB youths'rates of suicide attelnpts are between two and seven
times higher than those of their heterosexual peers
[6].
Although
Exhibit 2
Page 1 of 6
Case 6:l3-cv-0l834-MC Document 68-2 Filed 04/0l/l4 Page 2 of 7 Page lD#: 689
s22
these disparities are well-documented, there is comparably less
research on the processes that cleate risk for, or protectior]
against, suicide atterrpts among LGB youths. Consequently,
establishing associations between anti-bullying policies and
reduced risk of suicide attempls among LGB youths would
provide critical information on social and contextual protective
factors within tl.ris population and aid in public health inter-
vention efforts.
Recent research has shown that social policies negatively
targeting gays and lesbians, including col-tstitutional amend-
ments banning same-sex marriage
[7]
and lhe absence of
employment nondiscrimination acts
[8],
are robust predictors of
psychiatric morbidity amorrg LGB adults. Whereas negative
social policies appear to increase risk for psychopathology in LGB
populations, supportive policies and programs may protect LGB
individuals against the development of mental health problems
[9,101.
For instance, LGB youtlrs who attend sclrools witlr
Gay-Straight Alliances report less suicidaìity than youths who
attend schools without these programs
[1.1 ].
These empirical
findings are consistent with ecosocial
[12]
and ecological
systems
[13]
theories, both of which highlight the importance of
broad social and contextuaì influer-rces, ir-rcluding family, school,
and neighborhood factors, on health and development. Thus,
several lines of evidence suggest tl-rat ir-rclusive arrti-bullying
policies may be associated with reduced prevalence of suicide
attempts among LGB youths
[7-11].
The current study tested this
hypothesis by evaluating whether LGB students living in counties
with a greater proportion of school districts wilh inclusive anti-
bullying policies have a lower risk of suicide attempts.
Methods
Sample and setting
We obtained data from the Oregon Healthy Teens (OHT)
study. Annual OHT surveys are administered to more than one
third of Oregon's eighth- and 11th-grade students atteuding
public schools. Each yea¡ a random sample of districts within
counties and schools within districts is selected. Palticipating
students came from 34 counties (no respondents were sarnpled
in the rer¡aining two counties in Oregon). The questionnaire was
available in both English and Spanish. All participants were
assured tl-rat the survey is anonymous and voluntary, and parents
provided passive consent for tlreir children to participate. For the
current study, we pooled data from the Vears 2006 (when sexual
orientation was first assessed) to 2008 (the [rost recently avail-
able data), to increase the sample size of LGB participants.
Sampling fol the 2007-2008 years was conducted so that each
school would be asked to participate as part of the state sample
once in the 2-year period, minimizing the lil<elihood that the
same schools were sampled in multiple years. ln 2008,75.4% of
the eighth- and 11th-grade students in participating schools
completed the OHT survey.
Measures
Demographic variables includirrg sex and race/ethnicity
were olltained via self-report. SexuaÌ orientation, which is
only assessed in the survey of llth graders, was rneasured
with a single itern asking respondents to indicate "which of
the following best describes you." Foul lesponse optior-rs
were given: ('l) heterosexual (straight); (2) gay or lesbian;
M.L.HotzenbuehlerondK.M Keyes/lournaloJAdolescentHeolth53(2013)521-526
(3) bisexual, and (4) not sure. Of the 33,714 original OHT
respondents, 30,439 (90.3%) self-identified as heterosexual, 301
(.9%) self-identified as gay or lesbian, and 1,112 (3.3%) selÈ
identified as bisexual. We excluded from analyses participants
who indicated that they were "not sure" about their sexual
orientation (n :
653; 1.9%), which is consistent with previous
studies
[14].
An additional 1,209 respondents did not complete
the sexual orientation item, and were also excluded. Conse-
quently, the final sample size was 31,852. The sociodemographic
cl'raracteristics of the LGB sample in the OHT study are provided
in a previous report
[91.
Independent
yariable
We obtained data on school anti-bullying policies at the
district level froln the Oregon Department of Education. We
analyzed school district websites and high school student
handbooks for 197 school districts. lf we were not able to obtain
policy information from this search (31 school districts), we
contacted the individual school district to request this informa-
tion. Of the 197 districts in Oregon, we were not able to obtain
information for 18 districts, which we coded as missing. The
missing data were largely clustered within four counties: Of the
36 counties in Oregon, 60% (21 counties) had no missing district
data,31%(11 counties) had only one ortwo districts with missing
data, and 1.1 % (four counties) had more than half of districts with
missing data. We conducted sensitivity analyses by removing
respondents from the four counties with the most missing data.
The rnagnitude of the results remained unchanged when we
removed these counties from the analyses, so the current report
included all counties in the analyses.
We first coded school district websites and student hand-
books for whether the districts had any anti-bullying policies
(these policies had to specifically mention bullying; harassment
and antidiscrimination policies were not included in this cate-
gory). Next, we coded the policies to indicate whether they
contained an enumerated list of groups specifically covered by
the policy, aud finally, whether the enumerated list included
sexual orientation. Policies had to include tlle phrase "sexual
orientation" (e.g., in a list of protected class statuses) to be
considered to protect LGB youth. Thus, these data made it
possible to differentiate among (1) the absence of anti-bullying
policies; (2) the presence of anti-bullying policies including
specific categories (e.g., gender, race, religion), but not sexual
orientation (which are hereafter referred to as "restrictive anti-
bullying policies"
[This
category includes districts with anti-
bullying policies but no enumeration of specific protected
groups, as well as districts with anti-bullying policies with
enumel'ation of groups, but no mention of sexual orientationl);
and (3) anti-bullying policies that were inclusive of sexual
orientation (which are hereafter referred to as "inclusive anti-
bullying policies").
Because information on location of residence was available
only at the count¡r level, we aggregated the measures of anti-
bullying policies from the district to the county level by
dividing the number of school districts with anti-bullying poli-
cies by the total nuinber of school districts in the county. We
created variables of the proportion of school districts that had
reslrictive and inclusive anti-bullying policies within each of the
Oregon counties. Of the sclrool districts with availal¡le da|.a,7%
had no anti-bullyitrg policies; among districts with anti-bullying
policies, 37% did not include sexual orientation as a protected
Exhibit 2
Page 2 of 6
Case 6:l3-cv-0l834-MC Document 68-2 Filed 04/0l/l4 Page 3 of 7 Page lD#: 690
class status. Of the counties with available data, 15% had no
districts with iuclusive anti-bullying policies; 18% had fewer than
half of their school distlicts with inclusive policies; and only 15%
of tlle couuties had 100% of tl-reir school districts witl-r inclusive
policies.
Outcome varíable
Participants wele asl<ed the numbel' of times they attempted
suicide during tlre past 12 r-nontl-rs. Given tl-re non-normal
distribution, we examined suicide attempts as a dichotomous
outcome. The suicide question used in the OHT was based on
a measure from the Youth Risl< Behavior Surveillance Survey,
which showed exceÌlent test-r'etest reliabiliry (rc : 76.4)
[15,16].
Covariates
We were interested in exarnining whether anti-bullying
policies were associated with reduced risk ol suicide atlenlpts
after controlling for exposure to peer victimization, a risl< factor
for suicide attempts among sexual mir-rority adolescents
[17,18].
Exposure to peel' victimization was assessed by asking partici-
pants, "Durir-rg the last 30 days, l-rave you been harassed at scl-tool
(or on the way lo or fronr school)?" This item had a "yes" or "no"
lesponse option.
Statistícal analysis
The analytic strategy cor-rsisted of four steps corresponding to
the four study aims. Filst, we calculated differences in suicide
attelnpts and risl< factors belween LGB and heterosexual youtl-t
using basic descriptíve cross-tabulations. Second, we tested
whether tlre effect of inclusive anti-bullying policies or.r suicide
attempts varies by sexual olientatior-r. For this aim, we divided
the inclusive anti-bullyiug policy into tertiles based on the
distribution in the data. Third, we examined wlretlrer iuclusive
anti-bullying policies wele significantly associated with suicide
attempts arnor.rg LGB youth after adjusting for individual-level
risl< factors (sociodemographic characteristics and peer victimi-
zation). For this airn, we entered inclusive anti-bullying policies
as a continuous variable, with larger values indicating a higher
proportion of distlicts with inclusive anti-bullying policies
within the county. For the second and third study airns, we used
Geuel'alized Estin-rating Equations, a method developed for
handling clustered data, il-l which the observations within each
cluster are col'elated with each other
[19].
Given that OHT
respondents weLe nested witl-rìn their county of residence, we
used Generalized Estirnating Equations to account for the
correlatior-rs among observations flom each individual within the
same county. Fourth, we repeated the second and third study
Tal¡le 1
luclus¡ve anti-llullying policies and suicide attempts, by sexual orientation
aims to deterrnine whether the presence of any arrti-bullying
policies (i.e., restrictive policies) l¡uffered LCB youth agait.rst
risk of suicide attempts, ol whether these protective effects
were only observed for policies that specifically include sexual
orientation (i.e., inclusive policies). These analyses therefol-e
tested the specificity of the plotective effects of inclusive anti-
bullying policies on rates of suicide attempts among LGB youth.
Recent research that has disaggregated ìrisexuals florn gay
and lesbian youths has shown that bisexual adolescents are more
lil<ely to attempt suicide than gay and lesbian youths
[20]:
consequently, we separated these groups ir-r all analyses. Giverl
the relatively small number of lesbian and gay participants, we
did not stratify analyses by sex. Statistical sigrlificance was set at
ø
:
.05.
Results
Lesbian, gay, ar-rd bisexual respondents were significantly
rnore likely to l-rave attempted suicide in the past 12 montl-rs tharr
lreterosexuals (X2 :
109.1 ; degrees of freedorr :2: p < .0O1,).
Approximately 21% of lesbian and gayyouths and23% of bisexual
youtlls reported attemptiug suicide at least once in the plevious
-12
months, compared wilh 4.3% ol their heterosexual peers.
Lesbian, gay, and bisexual adolescents were also rnole lil<ely to
report past-3O-day peer victimization (lesbian and gay'. 6O.2%',
bìsexual: 56.7%; hetelosexual: 28.8%), compared with hetero-
sexual youths. These group differences in peer victilnization
were statistically significant:
X2
:175.4: degrees of freedom
-
2;
p < .00.1.
Associations betvveen inclusive onti-bullying policies and suicide
attempts
We divided the inclusive anti-bullying policies into tertiles
ranging from least ir-rclusive (i.e., counties with the smallest
ploportion of school districts with inclusive poìicies) to ulost
inclusive (i.e., counties with the Ìargest proportion of school
districts with inclusive policies). We examined the plevalence of
suicide attempts within each tertile for the thlee different sexual
orientation groups (lesbian/gay, bisexual, aud heterosexual).
Arrong lesbian and gay youths, the risl< of suicide attempts
was lowest in counties that had the greatest proportion ofschooÌ
districts with inclusive policies (Table 1). The proportior.r of
lesbian and gay respondents attempting past-yeal suicide
within the tertiles was as follows: most inclusive (16.67%);
mediur¡ (19.05%); and least inclusive (31.08%), Lesbian and
gay youths living in the least inclusive counties were 2.25 titnes
(95% confidence interval
[Cl],
1.13-4.49) rnore likely to have
attempted suicide in the past year compared with those in the
nrost inclusive counties.
M.L Hotzenbuelllet ond K.M Keyes
l Jounnl
of Adolescent Heoltll 53 (2013) 521
-526
lnclusive anti-bullying policy tert¡le Lesbian and gayyouths (N:301) Bisexual youths (N: 1,112) Heterosexu¿l youths (N
-
30,439)
Attempt¡ng (%) OR (952 Cl) Attempting (%) OR (95% Cl) Attempting (%) OR (95U Cl)
Least Inclusive
Mediun: lnclusive
Most hrclusive
2.25 (1.13-4.49)
1.18 (0 57-2.43)
.1.00
22.1'l
25.65
20.76
4.72
3.77
4.45
1 .08 ( 7s-1.s6)
1.32 (.94-1.84)
1_00
respoÌìdeuts wllo attenlpted suicide in each tertile, witll results stratiñed by sexual or ienlation.
CI: colrfìdeuce interval; OR
=
odds ratio.
Exhibit 2
Page 3 of 6
Case 6:l3-cv-0l834-MC Document 68-2 Filed 04/0l/l4 Page 4 of 7 Page lD#: 69l
s24
In contrast, we did not observe this pattern for the bisexual or
heterosexual youths. Among bisexual youths liviug in the most
inclusive counties, 2O.76% afternpted suicide in the past yea¡
compared with 25.65% in the mediurn ar¡d 22.71% in the least
inclusive counties. Bisexual youths living ir-r tlre least inclusive
counties were not more likely to altempt suicide than those
living iu the most inclusive counties (odds ratio
IOR]
: 1.08; 95%
Cl, .75-1.56). Sirnilarly, the proportion of heterosexual respon-
dents attempting suicide was nearly identical across tertiles:
least inclusive
Ø.72%):
rnedium (3.77%); and most inclusive
(4.45%). Heterosexual youths were no more likely to attempt
suicide in the least inclusive compared with the most inclusive
counties (OR : 1.06: 95% Cl, .93-1.22).
Having docurnented a protective effect of inclusive anti-
bullying policies only arnong Ìesbian and gay youtlrs, we next
tested whether thel-e was an association between inclusive anti-
bullying policies ar-rd suicide attempts over and above peer
victimization experiences (Table 2). In the full sample, peer
victimization was significantly more lil<ely to occur in the least
ínclusive (31.59%) compared witÌr the most inclusive (29.69%)
counties (Wald F
-
4.44i p : .01
).
Even after adjusting fol peer
victilnization aud sociodemogt'aphic characteristics (sex and
race/ethnicity), a higher propoltion of districts with inclusive
anti-bulìying policies was associated with reduced risk for
suicide atternpts aulong lesbian and gav
Vouths
(OR: 0.18; 95%
cr, .03-.92).
Tests of specifcity
We couducted follow-up analyses to detelrnine whetlrer
these eff,ects were specific to inclusive auti-bullying policies.
Results indicated that having any anti-bullying policy (i.e.,
restrictive policies that did not inclnde sexual orientation as
a protected class status) did not protect lesbian and gay youths
from attemptir-rg suicide. The propoltion of gay and lesbian
resporrdents attelnpting suicide did not dilfer between the low-
arrd lriglr-inclusion categories: 21.56% and 2O.OO%, respectively.
Moreover, after colrtrolling for other established risl( factors for
suicide attempts (Table 3), restrictive anti-bullying policies did
ruot buffer lesbian and gay youths against attempting suicide
(OR
-
.38; 9s% Ct, .02-7.33).
Discussion
Suicide is the tlrird leading cause ofdeath arnong youths aged
15-24 years
[21],
and studies have consistently documented
M L Hatzenbuehler ond l(.M Keyes
/ Journol
oJ Adolescent Healtlt 53 (2013) 521-526
sexual orientation-related dìspalities iu suicicle attempts atnong
adolescents
[6,22].
However, the plevalence of suicide attempts
atnong LGB youths does not appear to be invariant across social
context. For instance, a recent study found that the risk of suicide
attempts was 20% higher an-ror-rg LGB youths living in co[lmu-
nities characterized by lower support for gays and lesbians (e.g.,
counties with a lower density of same-sex couples and fewer
schools with protective policies), cornpared with LGB youths
living in more supportive communities
[9].In
addition, data fronl
tlre pooled 2OO1-2009 Youth Risl< Behavior Surveillance Survey
studies showed that, across 13 states and cities that included
a lreasule of sexual identity, rates of past-year suicide attelnpts
among gay and lesbian youtl'rs ranged from a low of 15.1% to
a high of 34.3%, over a rwofold difference
[23].
This geograpl.ric
variation in the prevalence of suicide attempts among lesbian
alld gay adolesceuts suggests that social and contextual factors
likely contrìbute to sexual orientatior-l disparities in suicide
attempts. The current study examined scl-rool policies, and in
particular inclusive anti-bullying policies, as one social/contex-
tual factor that may lower the risk of suicide attempts ar-rrong LGB
adolescents. We highlight four key findings below.
First, as the proportion of school districts that adopted
inclusive anti-bullying policies increased, rates of past-year
suicide attempts among lesbian and gay youths decreased.
Whe¡eas 31% of lesbian and gay adolesceltts atternpted suicide in
counties where school districts were the least likely to adopt
irrclusive anti-bullying policies, only 77% attelnpted suicide in
counties with the greatest proportion of school districts with
inclusive policies. hr rnodels adjusted lol established risl< factors
at the individual level (sex, race/etlrnicity, and peer victirniza-
tion), inclusive anti-bullying policies remained significantly
associated witl-r lower rates of suicide atternpts among lesbian
arrd gay youths.
Second, peer victimization of all youth was also less lil<ely to
occur in counties with inclusive anti-bullying policies. These
results not only suggest one potential mecltanism lir-rl<ing inclu-
sive anti-bullying policies to reduced risl< of suicide attempts iu
lesbian and gay youtìr, but also delnonstrate that policies pro-
tecting sexual rninoril¡r adolescents may confer benefits for
heterosexual youths as well
[9].
Thild, the resuìts documented specificily of the protective
effects of inclusive anti-bullying policies to lesbian and gay
youths. Inclusive anti-bulìying policies did not leduce the risl< of
suicide attempts amollg,bisextral youths. Recent studies that
have disaggregated gay and lesbian from bisexual youths suggest
one possible explarration for these results. This research has
Table 2
Associ¿t¡on between ¡DclLlsive anti-brllyirg policies and suicide attempts, by sexual orientation, in the Oregon Healthy Teens Study (2006-2008)
Lesllian and gay youths
(N:301)
OR
952 Ct 95% Ct Heterosexual youths
(N : 30.439)
OR
95% Cl
OR
Model 1: unadjusted model
lnclusive anti-bullyiug policy
Model 2: adjusted model
lnclusive ¿nti-bullying policy
Sex
Race/ethnic¡ ty
Peer har¿ssment
16 (.04-.64)
(.03-.s2)
(r.0r-3.79)
(1.2'r
-5.38)
(3.1 2- 1 9.1 3)
.89
.83
1.47
1.44
2.98
(0.43-1.83) 81 (.61-1.07)
.18
195
2.55
?72
81
163
1.57
3.r8
ethnicity: non-wìrite : 0i white : 1 Peer harassment (0 : no peer victilnization in past 30 days).
Abl¡reviations as in Table 1
Exhibit 2
Page 4 of 6
Case 6:l3-cv-0l834-MC Document 68-2 Filed 04/0l/l4 Page 5 of 7 Page lD#: 692
Table 3
Associations lletween restrictive anti-bully¡ng policies and suic¡de atterllpts
among lesbian and gay youtlì, in Oregon Healtlìy Teens Study (2006-2008)
Parameters OR 95% Ct
s25
admiuisleling questionuaires in classroorn settillgs. Thus, ir-l
many cases, the OHT survey relied on single-item questions,
including those for suicide atlempts and peer victimization.
Although the reliability of these measures has been well vali-
dated
[15,16],
future studies examining similar resealch ques-
tions would benefit from more detailed assessments of suicide
attempts and associated risl< factors.
Our measure of school policies is also subject to a numl¡er of
limitations. First, because the OHT study does not release infor-
lnation on the individual schools participating in the survey, it
was not possible to obtain data on whether these policies were
enforced in the schools. An important direction for future studies
is to conduct detailed assessrnents of the extent to which school
policies are consistent with daily practices. Second, school poli-
cies on bullying are determined at the district level; however,
data had to be aggregated to the county, because participants'
residence was available only at this level of analysis. This
approach could introduce potential error in the county variable;
however, lhis would likely bias us toward the null, because we
would not expect that misclassification is related to the propor-
tion of students attempting suicide within the county. Conse-
quently, these results are likely a conseruative estimate of the
association between anti-bullying policies ar-rd suicide attempts
among lesbian and youth.
A fir-ral study limitation is that the data are cross-sectional.
Consequently, we are unable to determine whether anti-
bullying policies are causally related to decreases in suicide
attempts among lesbian and gay youth, or whether such policies
are merely a marl<er of more supportive environments krrowr-r to
protect LGB youth
[91.
Future studies with stronger research
designs are needed to streugtllen causal inferences regarding tl-re
effect of anti-bullying policies on LGB health. For instance, quasi-
experimental designs can be used to compare rates of suicide
attempts among LGB youth before and after inclusive anti-
bullying policies are implemented.
Despite these limitations, lhe current study has severaì
methodological advantages for testing relationships between
anti-bullying policies and suicide attempts. The large,
population-based sample increases generalizability of the results
and minimizes biases that may occur with convenience samples
of LGB youths
[26].
Moreove¡ unlike many previous studies
[27],
the LCB and heterosexual participants in the OHT study were
recruited using identical sarnpling methods (i.e., through
sclrools), which further diminished sampling biases
[28].
An
additional strength was the ability to document associations
between social policies and mental health at geographic scales
below the state level. Most studies that have examined the health
consequences of policies targeting gays and lesbians have been
conducted at the state level
[7,8].
Because the OHT study released
data at the county level, we were al¡le to use measures of
ecological environments that are more proximal to LCB youth.
This study provides a significant contribution to the literature
on social determinants of suicide attempts among sexual
minority youths. ln particular, the results indicate that the social
environments in which lesbian and gay adolescents are
ernbedded can shape their mental health, independent of
individual-level characteristics. Schools are l<ey social contexts ir-r
which important health and developmental processes unfold for
adolescents
[29].
In documenting associations between inclusive
anti-bullying policies in schools and reduced risk of suicide
attelnpts an-rong lesbian and gay youth, this study lends further
empirical support to the argument that social policies exert
M L Hotzenbuehlet otld K.M Keyes
I Journol
of Adolescent Healtll 53 (2013) 521-526
Restrictive antÈbullying policies
Sex
Rece/ethnicity
Peer haràssment
.38
1.99
2.66
8.12
Data represent the Gener¿lized Estilnating Equatiorìs model predicting suicide
attempts in the past 12 months. We entered restrictive anti-bullying policy
policies as a continuous variable, ranging frorn 0 to 1.0. Higlrer values indicate
ã greater proportion ofdistricts with inclusive anti-bullying policies. Sex: male
=
0; female
-
1. Race/ethnicity: non-white
=
0; white
=
I Peer harassment (0 : no
peer victinization in past 30 days).
Abbreviations as in Table 1.
illustrated that risk factors for mental health problerrs among
bisexual youths are somewhat distinct frorn those for individuals
witlr same-sex sexual orientations
[24],
which suggests that
factors benefi[ing gay and lesbiar-r youths do not always gener-
alize to bisexual youths. Given the high rates ofsuicide attempts
among bisexual youths observed in this study and others
[20],
the identification of social and contextual factors that protect
bisexual youths from engaging in suicidal behaviors represeuts
an important avenue for future inquiry. In addition, inclusive
anti-bullying policies weÍe not associated with a decreased risl<
for suicide attempts in the heterosexual sample. It is lilcely that
these policies are mole relevant to subgroups of heterosexual
youths that are targets of bullying, such as tl-re overweight or
obese
[25].
However, we did not code fol other gloups that were
protected in these inclusive policies, which was beyond the
scope ofthis study. This rernains an irnportant topic that can be
examined in subsequent researcl-r with tlris sample.
Fourth, the results documented speciñcity of the effects to
inclusive anti-bullying policies. That is, policies had to include
sexual orientation in the list of protecled class statuses to be
associated with signiñcantly lower rates of suicide attempts
among lesbian and gay youths. There was not sufficient evidence
to indicate that restrictive anti-bullying policies (which did not
enuffrerate sexual orientation) exerted a mental health benefit
for Iesbian and gay students. These results therefore suggest the
importance of specifically including sexual orientation in auti-
bullying policies tllat enumerate protected groups, to signal
supportive and inclusive school environments for lesbian and
gay youths. However, over three quarters of the school districts
had restrictive anti-bullyir-rg policies; thus, rnost students, botl-l
LGB and heterosexual, were in districts with ar least sorne anti-
bullying policies. Tlre limited range for tlris variable rnay have
reduced our ability to detecl significarrt results for the l'estrictive
anti-bullying policies.
This study had several limitations. The OHT suruey assesses
youths attending public schools. Results are tlrerefore not
genelalizable to studeuts attending private or altel'native
schools, or to adolescents who do not attend school. In addition,
a quartel ofschool districts that were randomly selected declined
to participate in the study. The OHT does not provide information
on these school districts. Consequently, we cannot detelmine to
what extent differential llonrespollse by school district r-r-right
affect the study's results.
In addition to issues of sampling, there are ffreasurelrellt
lilnitations. In particular, the number of questions that can be
included irr large-scale surveys such as the OHT is necessarily
limited, especially given the tine constraints involved in
Exhibit 2
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s26
downstream health elfects
[30,31 ].
Consequently, altering nega-
tive social environrnents surrounding LGB youths through policy-
level changes may ultimately lead to reductions in sexual
orientation-related disparities in suicide attempts, an important
public health priority
[32].
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Hatzenbuehler ML The social environnrent and suicide attempts in a pop-
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[1
0] Toomey RB, Ryan C, Diaz RM, Russell ST. High School cey-Stre¡ght Alliances
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Walls NE, Freedenthal S, Wisneski H. Suicidal ideation and attempts among
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I(rieger N. Theories for social epidemiology in tlìe 21st century: An eco-
social perspective. Int
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Bronfenbrenner U. The ecology of human development: experiments by
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Brener N, CollinsJ, Kann L, et al. Reliability ofthe youth risk behavior
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Brener ND, l(ann L, McManus T, et al. Reliabil¡ry of the 1999 youth risk
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/ Journol
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Garofalo R, Wolf RC, Wissow [S, et al. Sexuål orientation and risk of suicide
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Joyner
K. Adolescent sexual orientation and suicide risk:
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Robin L, Brener ND, Donâhue SF, et al. Associations between health risk
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[21]
Centers for Disease Control and Prevention, Nat¡onal Center for Injury
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Marshal MP, Dietz LJ, Friedman MS, et al. Suic¡dality and depression
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I<ahn L, Olsen EO, McManus T, et al Sexual identity, sex ofsexual cont¿cts,
and health-risk beh¿viors among students in grades 9-12: Youth Risk
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201 l;60:1-133.
[24]
Ross LE, Dobinson C, Eady A. Perceived determinants of mental health for
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Publ¡c Health 2010;100:
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[25]
Puhl RM, LâtnerJD. St¡gma, obesily, ând the health ofthe ¡ration's clrildren.
Psychol Bull 2007:133:557-80.
[26]
Meyer IH, Wilson PA Sampling lesbian, gay, and bisexual populations.
J
Counsel Psychol 2009;56:23-31.
[27]
Safren SA, Heimberg RC. Depression, hopelessness, suicidality, and related
factors in sexual minorily and heterosexual adolescents,
J
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999;67:859-66
[28]
Diamond LM. New paradigrns for research on heterosexual and sexual-
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[29]
Eccles
JS,
Roeser RW. School and community influences on human devel-
opment. In: Bolnstein MH, Lamb ME, eds. Developmental science:
an advanced textbook. 6th edition. New York: Psychology Press;
2011:571-643.
[30]
Hatzenbuehler ML. Social factors ¿s determinants of mental health
disparities in LGBT populations: implications for public policy- Soc Issues
Policy Rev 20-10i4:3-l
-62.
[31]
Williams DR, Costã MV, Odunlami AO, Mohammed SA. Moving upstream:
how interventions that address the social determinants of health can
irnprove health and reduce disparities.
J
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[32]
Institute of Medicine o[ the Nat¡onal Academy of Sciences. The health
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Press:2011.
Exhibit 2
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HEALTHY PEOPLE ffiffiWffi
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Suicide rate among adolescents
(12-17 years)
and
young
adults
(18-24 years)
Overview
Suicide is a serious
public health concern. lt has long-lasting effects on individuals, families and
communities, Nationally, suicide is the third leading cause of death among
youth
aged 15-24 years
old,
ln 0regon suicide is the second leading cause of death in
youth
of the same age. The path to suicide is
complex, lt is paved with many factors that can
put youth
at risk for and
protect them against suicide,
However, the goal of suicide prevention is simple: Reduce factors that increase risk and increase factors
that promote resilience, Successful
prevention strategies address individual, relationship, community and
societal levels. Effective prevention actions will promote suicide awareness and encourage social change,
Youth suicide in Oregon
0regon's adolescent suicide rate has decreased
approximately 50
percent
since the early
.1990s,
However, Oregon's suicide rate has generally
been higher than the U,S. rate (see Figure 1),i
Major contributors to 0regon's suicides include
mental health challenges (such as depression), a
crisis within two weeks, interpersonal relationship
problems and trouble at school, Nearly eight of
10 youth who attempted suicide in 201 2 had aI
least one mental health condition, Youth attempted
suicide by using
prescription
or over-the-counter
drugs more than by any other method, Most
attempts were in the
youths'
own home, Data
from the Adolescent Suicide Attempt Data System
show that 66
percent of the youth who attempted
suicide were females.
Suicide rates among
youth
aged
10-24 in 0regon and the U.S.,
1990-2009
-.
-a
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Figure 1
0
Source: CDC WIS0ARS dala set; 0regon Violent Death Reporting Syslem
Exhibit 3
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Case 6:l3-cv-0l834-MC Document 68-3 Filed 04/0l/l4 Page 2 of 5 Page lD#: 696
However, three times more males than females
died by suicide, Over half of
youth
suicides were
from firearms,
Emotional and mental health are strongly connected
to suicidal thoughts and behaviors, ln the 2009
Oregon Healthy Teens Survey, 7'1 percent
of
students with serious suicidal thoughts also
reported poor
emotional or mental health, Students
who felt depressed for two weeks in a row in the
past year were six times more likely to have suicidal
thoughts and behaviors than those who did not feel
depressed (40.10/o vs. 6,7%), Substance abuse,
exposure to violence and harassment at school also
contribute to these thoughts and behaviors, Youth
who identify as lesbian, gay 0r bisexual considered
and attempted suicde at a higher rate than youth
who identify as heterosexual (see figure 2),
Percent of llth graders,
by
sexual orientation, who attempted
suicide in the
past year,
2008
Number of attempts
$$ Once I Two or more times
25%
20%
75%
70%
5%
o%
-"..'J
t!
".'." ".J
l"
Sef-reportedsexualorientation
Sourcer 0regon Healthy Teens Survey, 2008
Suicide
prevention
in Oregon
-
a
public
health approach
A public
health approach to preventing
suicidal thoughts and behaviors includes a broad range of
interventions, programs
and
policies.
This approach cuts across health, media, criminal
justice,
advocacy,
education and other sectors, The public health approach monitors trends, conducts research on risks and
protections,
develops and tests interventions, and builds capacity for tactics that reduce suicide behavior,
Creating nurturing environments to
prevent
suicide
When children's and youths'
exposure to violence, parental
conflict, bullying, victimization and other
toxic conditions decrease and nurturing conditions (such as strong relationships with adults and peers
and safe and supportive school environments) increase, many behavioral and psychological problems,
including suicide, decrease.ii Everyone can help create nurturing environments that support healthy
youth
development,
Policymakers
Policymakers can help develop state and local systems of care that include partnerships
among
families, schools, health care
providers
and local programs,
Youth who have more access to physical
and mental health services through school-based health centers can help ensure youth have access
to qualified providers,
Figure 2
Exhibit 3
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Policymakers can also invest in evaluating and
implementing evidence-based
prevention
and mental
health promotion
approaches in communities and
school systems. They could also require health
professionals to receive and mental health graduate
programs to
provide training in suicide intervention.
Policies that reduce access to firearms would reduce
the number of
youth suicides.
Schools and communities
Schools are critical for suicide
prevention,
lncreasing
school connectedness can build resilience among
youth,
Resilience
protects youth from a number of
health risks, including suicide, and supports
greater
academic achievement,iii
Schools can work to increase school connection
in several ways, One is to ensure a healthy and
safe school environment that promotes positive
behavior and engagement. Schools can ensure they
have strong
policies to prevent and report bullying,
aggression and harassment, School staff also need
suicide awareness and intervention skills, Adequate
and frequent staff training in these areas is vital to
support strong
policies, ln Oregon, most counties
offer suicide intervention skills training through
QPR and Applied Suicide lntervention Skills Training
(ASIST), These trainings help recognize signs of
suicidal thinking and behaviors, and teach what to do
and how to get help,
Schools can also help provide
students with the
academic, emotional and social skills to actively
engage in school, Examples of evidence-based
programs include Positive Behavioral lnterventions
and Supports (PBIS), the Good Behavior Game, and
Reconnecting Youth.
Health care
providers
Health care
professionals in clinics, hospitals and
emergency departments can screen all youth for
depression and suicidal thinking, This will help
identify at-risk
youth,
and help them find the right
resources, They can counsel patients at risk to
remove access to firearms, Emergency departments
that follow up with youth who have attempted suicide
help reduce further attempts,
Exhibit 3
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Resources
1. 0regon Youth Suicide Prevention Program: Find resources to prevent
suicide and to help support
survivors, families and friends: http://public.health.oregon.gov/PreventionWellness/SafeLiving/
Su icidePrevention/Pages/i ndex.aspx.
2. Suicide Prevention Resource Center
provides national data, resources and best-practice
registries for suicide
prevention.
Go to www.sprc.org.
3. The U.S. Department of Education has established the Technical Assistance Genter on Positive
Behavioral lnterventions and Supports (PBIS) to provide
school capacity-building information
and technical assistance disciplinary practices.
See www.pbis.org.
4. RESPONSE is a comprehensive, high school-based suicide
prevention program
designed to
increase awareness, heighten sensitivity to depression and suicidal ideation, change attitudes, and
offer response
procedures
to refer a student at risk for suicide. Go to www.columbiacare.org/Page.
asp?NavlD=99.
5. Northwest Area lndian Health Board's THRIVE, Tribal Health: Reaching out lnVolves Everyone,
provides regional support for suicide prevention and is developing four national AI/AN media
campaigns from 2011 to 2013. Go to www.npaihb.org/epicenter/project/thrive/.
i Suicide, Suicide Attempts, and ldeation among Adolescents in Oregon, (2012),Oregon Health Authority
ii Biglan, 4,, Flay, 8,R,, Embry, D,D,, & Sandler, l,N. (2012), The critical role of nurturing environments for
promoting
human well-being. American Psychologist, 67, (4) 257-271.
iii Centers for Disease Control and Prevention. (2009), School Connectedness: Strategies for lncreasing
Protective Factors Among Youth, Atlanta, GA: U,S, Department of Health and Human Services,
This document can be
provided
upon request in alternate formats for rndividuals
with disabilities or in a language other than English for
people
with linrited English
skills, To request this form in another format or language, contact the Adolescent
Health Program aT 971-673-0249 or 971-673- 0372 for TTY,
oHA e631 (o6tz0j2)
ì rrtl itt'
h
PUBLIC HEALTH DIVISION
Adolescent Health Program
Exhibit 3
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Case 6:l3-cv-0l834-MC Document 68-4 Filed 04/0l/l4 Page l of 5 Page lD#: 700
The Dangers of a
Same-Sex Marriage Referendum for
Community and Individual Well-Being:
A Summary of Research Findings
By Glenda M. Russell
F
o
>
=o
o
=
\q
r ìÈ
v !.
ìù?
SÀe"
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àÈå
çäs
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ÈÈì
f,
cross the country, some legislators
Aun¿ citizens in á number of states
have called for a voter referendum on
the question of same-sex marriage.
According to those favoring a referen-
dum, voters should be able to change
state laws or to amend a state constitu-
tion to explicitly deny gay and lesbian
people the right to marry a same-sex
partner. While a referendum might
seem like a democratic way to decide a
highly controversial issuê, experience
with past referenda on gay issues in
other states shows a clear and disturb-
ing down side to the process of voting
on a group's civil rights.
Both formal research and
joumalistic
reports from these states (including
California, Colorado, Florida, Hawaii,
Oregon, Idaho, Maine, and Nebraska)
offer a cautionary note to the idea of a
referendum on this issue. Rather than
uniting community members in demo-
cratic debate and mutual respect, refer-
enda often leave communities even
more divided. Voting on civil rights
issues does not create a corrmon
understanding, but tends to erode a
sense of community and damage the
mentai and physical health of vulnera-
ble community members.
Elections that call into questíons the
rights of lesbian, gay, bisexual, and
transgender (LGBT) people creøte
sharp divisions in communities,
People who have managed to disagree
but live ín peaceful coexistence
become enemies in a public battle.
In places where LGBT rights have
become the focus of political debate,
once-friendly neighborhood networks
were disruptedl and fear and hostility
became more commonplace in commu-
nities.2 LGBT people have not been the
exclusive targets of antagonism, In
some cases, opponents to LGBT rights
have also been harassed. Heterosexual
allies of the LGBT rights movement
have been targeted as well. One
Massachusetts state representative has
said that he "had never experienced
Research Findings
lGoldberg,C.(200,September3).Vermontresidentssplitovercivilunionslaw.NewYorkfimes,p.l4.
z
Sneyd, R. (2000, September 7), Candidates feeling backlash Keene (NH) Senlinel, p.1,
L
IGLSS
P0. Box 2603
Amherst, IVA 01004
Phone:413.577.0145
Fax: 413-545-2921
Acling Execulive Direclor Glenda M. Russell
Reseatch Ditector lVl. V Lee Badgett
Layout Jesús Cudemus
I www.igkr.org
O Copyrisht 2004 IGLSS
Exhibit 4
Page 1 of 4
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anything like the 'fear and anger' gays and lesbians are
often subjected to" until he voted in support of same-
sex marriage.3 A Vermont state representative, a
Republican who voted in favor of civil unions, report-
ed both social and business losses as a result. She
expressed particular surprise at the "delogatory
remarks" made about her to her 13 year-old grandson.a
Hostile and extreme rhetoric becomes common in
the political arena.
A number of communication researchers have ana-
lyzed the incendiary rhetoric that features strongly in
these referenda.s This rhetoric relies on "simplified
moral constructs"6 and on undocumented and faulty
arguments.T The net
effect of such rhetoric is
the dissemination of mis-
information that revives
old prejudices and rein-
forces divisions within
communities.s
"The
net effect ... is the dissemination
of misinformation that revives old
p rej udic e s and reinforc e s divisions
within communities."
Stereotypes and untruths about both sides become
staples of the
formal
and informal campaigns and of
ev ery day c onv ers ation.
Debates about emotionally laden issues contribute
to a polarization of these issues. The most extreme
statements, including patently false ones, are taken as
truth. Each side is portrayed in monolithic and
extreme tems, rendeling a picture of dangerous and
threatening homosexuals battling "Bible-Nazis."e
Stereotypes about other minority groups are revived
as well.l0 The humanity of participants in this polar-
ized debate is often lost. Members of the community
are portrayed as dangerous and threatening.ll A tone
of moral condemnation characferizes rhetorical
exchanges.12 LGBT peo-
ple, in particular, are ren-
dered aS 1!g "91!g¡"-
objectified, disenlran-
chised, and ultimately
treated as non-persons.l3
3
Gisick, M. (2004, lVay 3) Celebratory
atmosphere at gay pride rally. Daily
Hanpshire Gazette, p. A3,
I
Sneyd (2000). lbid.
s
Bransford, S. (1994) Gay polilics vs,
Colorado and Anerica: The inside story
ol Anendmenl 2 Cascade, C0: Cardis
Press,
Bull, C., & Gallagher, J. (1996). Pelecl
enemies: The religious righl, lhe gay
m1vemenL and lhe polilics ol lhe 1990s
New York: Crown
Douglass, D. (1997). Taking the initiative:
Anti-homosexual propaganda of the
0regon Citizens' Alliance. ln S. L. Wilt &
S. lVcCorkle (Eds.\, Anli-gay righls:
,4ssessing voler inilialives (pp. 17-32).
Westport, CI Praeger
Fischli, R (1979). Anita Bryants stand
against
"militant
homosexualily":
Religious lundamentalism and the demo-
cratic process Central States Speech
Journal, 30, 262-271,
Herman, D (1993). Beyond the rights
debate. Social and Legal Studies, 2, 25-
43,
Herman, D. (1997). The antigay agenda:
Orthodox visions and the Christian Right
Chicago: University of Chicago Press
Levin, D. (1997). The Constitution as
rhelorical symbol in weslern anli-gay ini-
liatives: The case of ldaho. ln S L. Will &
S. McCorkle (Eds.), Anti-gay rights:
Assessing voter initiatives (pp. 33-49).
Westporl, CT: Praeger.
lVcCorkle, S, & lVost, M. G. (1997). Fear
and loathing on lhe editorial page: An
analysis of ldahos anti-gay initiative ln
S. L. Will & S, McCorkle (Eds
),
Anti-gay
rights: Assessing voter initiatives (pp.
63-76). Westport, CT: Praeger.
lVori", M. J. (1995), "The
Gay Agenda":
Marketing hate speech lo mainstream
media. ln R, K, Whillock & D, Slayden
(Eds
),
Hate speech, (pp 55-79).
Thousand Oaks, CA: Sage
Sarbin, I R (1996) Ihe deconstructi0n
ol stereotypes: Homosexuals and military
policy In G. M, Herek, J B. Jobe, & R l\tl
Carey (Eds
),
Out in force: Sexual orienta-
tion and the military (pp 177-196).
Chicago: University of Chicago Press.
Smith, R. R., & Windes, R, R. (1997), The
progay and antigay issue culture:
lnterpretation, influence and dissent
Ouarterly Journal ol Speech, 83, 28-48
Smith, R R, & Windes, R R (2000),
Progay/Anligay: The rhetorical war over
sexuality. Thousand Oaks, CA: Sage,
Stein, A. (2001) The stranger nexl door:
The story of a small community's battle
over sex, faith, and civil rights Boston:
Beacon
Whlllock, B K (1 995) The use of hate as
a stratagem for achieving political and
social goals, ln R, K. Whillock & D.
Slayden (Eds.), Hate speech (pp. 28-54).
Thousand 0aks, CA: Sage.
Wieshoff, C. (2002). Naming, blaming,
and claiming in public dispules: ïhe
1998 Maine relerendum on civil rights
proteclion for gay men and lesbians.
Journal of Homosexuality, 44, 61-82,
6
Conrad, C. (1983). The rhetoric ol the
moral majority: An analysis of romantic
form. 0uarterly Journal of Speech, 69,
15S-170.
7
Herek, G. M. (1998) Bad science in the
service of stigma: A critique of the
Cameron group's survey studies, ln G. M.
Herek (Ed.), Stigma and sexual orienta-
tion: Understanding preludice against
lesbians, gay men, and bisexuals (pp.
223-255), Thousand 0aks, CA: Sage,
lVcKorkle & lVost (1997). lbid.
s
Bullis, C & Bach, B, W. (1996).
Feminism and the disenfranchised:
Listening beyond the
"other." ln E B Ray
(Ed.), Communication and disenfran-
chisement: Social health issues and
implications (pp. 3-28). l\4ahwah, NJ:
Lawrence Erlbaum.
s
Douglass(1977), lbid
Smith & Windes. (1997) lbid
Smilh & Windes (2000). lbid.
ro
deRaismes, J (1993) Homosexual
rights: Constructive responses to
Colorado's Amendment 2. Working Paper
93-27. Confllict Research Center
Consortium, University of Colorado,
Boulder. Retrieved lVay 5, 2004, from
http://www.crinf o.org/link-lrame.cf m?lin
kto=http%34%2F%2F
Douglass (1997). lbid.
[/cCorkle & Most (1997) lbid
Russell, G. [/. (2000). Voled out: The
psychological c0nsequences of anti-gay
politics. New York: New York University
Press.
tt
Davies, C. (1982). Sexual taboos and
social boundaries. American Journal ol
Sociology, 87, 1 032-1 063.
Douglass, D. (1997) lbid
Eastland, L. S. (1996b) The reconstruc-
tion of identity: Strategies of the 0regon's
Cilizens' Alliance ln E B Ray (Ed
),
Communication and disenlranchisement:
Social health issues and implications
(pp,59-75). Mahwah, NJ: Lawrence
Erlbaum.
Herman, D (1997) lbid
McCorkle & Most (1997). lbid
Moritz (1995) lbid.
Smith, R. R. (1997). lbid.
12
Smith, R. R (1997) lbid

Bullis, C., & Bach, B W (1996) lbid
l6tf f
^a.
N c L E S Jl,ilt 1001
Exhibit 4
Page 2 of 4
Case 6:l3-cv-0l834-MC Document 68-4 Filed 04/0l/l4 Page 3 of 5 Page lD#: 702
Some of the most damaging impact occurs within
families
in whiclt members are divided in their opin-
ions and can no longer live comfortably with those
dffirences.
Family members become estranged as they realize
that they intend to vote differently on these issues.14
When a particular group is the subject of political
debate, group members often exhibit a variety of
negative outcomes including anxiety, depressiott,
alienation,
fear,
ønd anger.
In the case of the debate over same-sex mariage,
these consequences will be most strongly experienced
by lesbian, gay, bisexual, and transgender people; by
children in LGBT fami-
lies; and by LGBT peo-
ple's extended family
"As
the referendum polariZes people,
members and friends.ls LGBT citizens become.fearful and
As the referendum polar-
their chitdren often encounter
izes people' LGBT citi-
ridicule at school."
zens become fearful and their childlen often
encounter ridìcule at school.l6
All of these consequences leave individuals und
communities damaged. Considersble time is
required
for
individuals and cornmunities to return
to healthy
functioning.
Recent research indicates that some people in
Colorado report continuing alienation and isolation
more than 10 years after a 1992 referendum on gay
issues in that state.lT
Referenda on the rights of any group run the risk of
allowing a tyranny of the majority.
Both theories of public
policy and empirical
studies have suggested
that civil rights are very
vulnerable to public
votes. Despite the fact
that voters approve only
one third of all citizen-
initiated referenda on ballots, voters have endorsecl
more than three-quarters of anti-civil rights initiatives
appearing on the ballot over the past three decades.rs
Voting on such matters implies that it is acceptable for
majorities to have the final say about legal matters that
have significant impact on the day-to-day lives of
political minorities. These elections both take advan-
tage of and increase existing prejudices that divide
community members from one another. As James
Madison warned, "If a majority be united by a com-
mon interest, the rights of the minority will be inse-
.,l o
cure. ''
Research Mlethods on Anti-gay
Referendø
Researchers from a variety of disciplines have
investigated anti-gay referenda, with most of the
research occurring since 1980 and especially
during the 1990s. Studies have focused on formal
electoral campaigns as well as on public debates
regarding gay rights at municipal and state levels
and in corporate and educational settings.
Communication scholars have most frequently
looked at the rhetoric and related processes
associated with these campaigns and elections.
Psychologists, sociologists, political scientists,
and legal scholars have examined the conse-
quences of anti-gay referenda both on individuals
and on the communities in which these elections
and debates have occurred. Scholars from all
fields have employed both qualitative and quanti-
tative techniques in their work. ln addition, an
extensive library of
journalistic
accounts illustrat-
ing some of the research findings is now avail-
able.
ra
Russell, G M, & Richards, J, A, (2003)
Stressor and tesilience lactors lor les-
bians, gay men, and bisexuals con-
honling antigay polilics. Anerican
Journal ol Connunily Psychology,3l ,
31 3-328.
1s
Eastland, L S. (1996a). Defending iden-
tity: C0urage and compromise in radical
right contexts ln E B, Ray (Ed.), Case
studres in communicati0n and disen-
lranchisement: Applications to social
heallh issues (pp 3-1a) l/ahwah, NJ:
Lawrence Erlbaum
Eastland, L, S. (1996b) lbid
Keen, 1., & Goldberg, S. B (1998).
Strangers to the law: Gay people on trial
Ann Arbor: Univenity of lVichigan Press
(especially pp. 26-27),
Russell (2000). lbid,
Stapanek, M. (1 992, December 23)
Gay-bashing on rise in Colorado San
Francisco Examiner, p 49,
1o
Russell (2000). lbid
r7
Russell, G lV , & Bohan, J. S, A 10-year
retr0spective ol Colorado's AmendmenI
2 lVlanuscript in progress
rs
Gamble, B S. (1997). Putting civil rights
to a popular vote, American Journal of
Political Science, 41, 245-269.
1e
0uoted in Gamble (1997). lbid
IGI'' Ä N G L E S IlJl{I IOO4
Exhibit 4
Page 3 of 4
Case 6:l3-cv-0l834-MC Document 68-4 Filed 04/0l/l4 Page 4 of 5 Page lD#: 703
Implications
for
the Debate about Same-Sex
Marríage
Potential voters, political organizations, and policy-
makers should seriously consider the findings of
research on the fallout from referenda on gay issues.
Elections of the sort being proposed can have very
negative and long-term consequences for a state and
its citizens. Oul system of checks and balances, which
promotes democratic input at many points, is
designed to protect the most treasured and basic rights
of individuals. While the referendum process might
provide useful guidelines on many issnes, on civil
rights matters a referendum is much more likely to
result in a process that will further damage-not
heal-a divided public.
Glenda M. Russell is Senior Research Associate
and Acting Executive Director at the Institute for Gay
and Lesbian Strategic Studies in Amherst, MA.
About the Author
About IGLSS
The lnstitute for Gay and Lesbian Strategic Studies
(IGLSS) is an independent think tank that bridges the gap
between the world of research and the world of policy debate
and public opinion. IGLSS asks and answers tough questions
that affect the lesbian, gay, bisexual, and transgender
communities, using reliable methodologies and the best
available data. We conduct both long-term research and rapid-
response analyses of pressing topics in four areas: Youth &
Education, Work & Family, Strategies, and the Data Project.
Our accessible publications, workshops, and briefings bring
those answers to the people who need them: policymakers,
advocates, employers, the media, and the general public.
IGLSS encourages the use of its information by other
organizations and individuals. However, IGLSS materials may
not be resold, reprinted, or distributed for compensation of any
kind without prior permission. This statement does not constitute
that permission.
For any questions or to request permission to reprint this
publication, please contact Lee Badgett at badgett@iglss.org.
Angles is the policy journal
of the lnstitute for Gay and Lesbian
Strategic Studies (IGLSS). Past titles include:
.
Going Beyond Gay-Straight Alliances to Make Schools Safe for
Lesbian, Gay, Bisexual, and Transgender Students
.
Vulnerability in the Workplace: Evidence of Anti-Gay
Discrimination
.
The Pseudo-Science Of Sexual Orientation Conversion
ïherapy
.
Calculating Costs with Credibility: Health Care Benefits for
Domestic Partners
For more information or to download a PDF version of these and
other publications, please visit us online at www.iglss.org.
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4
Exhibit 4
Page 4 of 4
Case 6:l3-cv-0l834-MC Document 68-4 Filed 04/0l/l4 Page 5 of 5 Page lD#: 704
1
Danielle M. Luethe
From: info@ord.uscourts.gov
Sent: Tuesday, April 01, 2014 9:41 AM
To: nobody@ord.uscourts.gov
Subject: Activity in Case 6:13-cv-01834-MC Geiger et al v. Kitzhaber et al Declaration
This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to
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***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
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U.S. District Court
District of Oregon
Notice of Electronic Filing

The following transaction was entered by Berman, Steven on 4/1/2014 at 9:41 AM PDT and filed on 4/1/2014
Case Name: Geiger et al v. Kitzhaber et al
Case Number: 6:13-cv-01834-MC
Filer: Oregon Says I Do
Oregon United for Marriage
Document Number: 68
Docket Text:
Declaration of Steven C. Berman in Support of Oregon Says I Do and Oregon United for
Marriage's Motion for Leave to File Amici Curiae Memorandum in Support of Plaintiffs'
Motions for Summary Judgment and Amici Curiae Memorandum. Filed by Oregon Says I Do,
Oregon United for Marriage. (Related document(s): Motion for Leave, (56 in 6:13-cv-02256-MC,
66 in 6:13-cv-01834-MC).) (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4)
Exhibit 4)Associated Cases: 6:13-cv-01834-MC, 6:13-cv-02256-MC (Berman, Steven)
Case Name: Rummell et al v. Kitzhaber et al
Case Number: 6:13-cv-02256-MC
Filer: Oregon Says I Do
Oregon United for Marriage
Document Number: 58
Docket Text:
Declaration of Steven C. Berman in Support of Oregon Says I Do and Oregon United for
Marriage's Motion for Leave to File Amici Curiae Memorandum in Support of Plaintiffs'
Motions for Summary Judgment and Amici Curiae Memorandum. Filed by Oregon Says I Do,
Oregon United for Marriage. (Related document(s): Motion for Leave, (56 in 6:13-cv-02256-MC,
2
66 in 6:13-cv-01834-MC).) (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4)
Exhibit 4)Associated Cases: 6:13-cv-01834-MC, 6:13-cv-02256-MC (Berman, Steven)

6:13-cv-01834-MC Notice has been electronically mailed to:

Anna M. Joyce anna.joyce@doj.state.or.us

Jennifer J. Middleton jjls@justicelawyers.com, jmiddleton@justicelawyers.com,
pjenkins@justicelawyers.com

Katharine Von Ter Stegge katevts@multco.us, amy.goodale@multco.us

Kevin Diaz kdiaz@aclu-or.org

Kristina J. Holm KJHolm@perkinscoie.com, DAnderson@perkinscoie.com, docketpor@perkinscoie.com

Lake James H. Perriguey lake@law-works.com

Lea Ann Easton leaston@dorsayindianlaw.com, jj@dorsayindianlaw.com, kellyd@dorsayindianlaw.com

Mary Williams mary_h_williams@msn.com

Misha A.D. Isaak MIsaak@perkinscoie.com, docketpor@perkinscoie.com, maguero@perkinscoie.com,
sroberts@perkinscoie.com

Nadine A. Gartner ngartner@stollberne.com, tkim@stollberne.com

Sheila H. Potter sheila.potter@doj.state.or.us, mary.c.hamilton@doj.state.or.us,
samantha.moon@doj.state.or.us, shiori.iinuma@doj.state.or.us

Steven C. Berman sberman@stollberne.com, jsloan@stollberne.com

Thomas R. Johnson TRJohnson@perkinscoie.com, ADargis@perkinscoie.com, ajaclark@perkinscoie.com,
docketpor@perkinscoie.com, skroberts@perkinscoie.com

6:13-cv-01834-MC Notice will not be electronically mailed to:

6:13-cv-02256-MC Notice has been electronically mailed to:

Amanda C. Goad agoad@aclu.org, aspiegel@aclu.org

Anna M. Joyce anna.joyce@doj.state.or.us

Jennifer J. Middleton jmiddleton@justicelawyers.com, jjls@justicelawyers.com,
pjenkins@justicelawyers.com

Katharine Von Ter Stegge katevts@multco.us, amy.goodale@multco.us

Kevin Diaz kdiaz@aclu-or.org

3
Kristina J. Holm KJHolm@perkinscoie.com, DAnderson@perkinscoie.com, docketpor@perkinscoie.com

Lake James H. Perriguey lake@law-works.com

Mary Williams mary_h_williams@msn.com

Misha A.D. Isaak MIsaak@perkinscoie.com, docketpor@perkinscoie.com, maguero@perkinscoie.com,
sroberts@perkinscoie.com

Nadine A. Gartner ngartner@stollberne.com, tkim@stollberne.com

Rose A. Saxe rsaxe@aclu.org

Sheila H. Potter sheila.potter@doj.state.or.us, mary.c.hamilton@doj.state.or.us,
samantha.moon@doj.state.or.us, shiori.iinuma@doj.state.or.us

Steven C. Berman sberman@stollberne.com, jsloan@stollberne.com

Thomas R. Johnson TRJohnson@perkinscoie.com, ADargis@perkinscoie.com, ajaclark@perkinscoie.com,
docketpor@perkinscoie.com, skroberts@perkinscoie.com

6:13-cv-02256-MC Notice will not be electronically mailed to:
The following document(s) are associated with this transaction:
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