Langan v. St. Vincent's Hospital
Encyclopedia
In 2000, New York residents John Langan and Neil Conrad Spicehandler traveled to Vermont where they affirmed their commitment under Vermont's Civil Union
laws. They were planning to adopt a child, and had purchased a house in Massapequa. Just hours after the closing of their house, Spicehandler was struck by an automobile in Manhattan. Spicehandler subsequently died following treatment at Saint Vincent's Catholic Medical Center
. Survivor Langan brought a malpractice suit against the Hospital, arguing standing as a "spouse" for purposes of New York's wrongful death statute.
(the state's trial court) held that Langan had standing as a "spouse" for the purposes of New York's wrongful death statute. New York courts, under principles of full faith and credit and comity
recognize valid contracts established under the laws of her sister states so long as they do not offend a New York state policy. This is especially true of marriages celebrated in other states. Spouses in out-of-state marriages would thus be extended the privileges and immunities the marriage laws of New York extend to marriages officiated in-state. Even common law marriages, which are not recognized for in-state New York cohabiting partners, are recognized for purposes of New York spousal benefits so long as the common law marriage was validly entered into in another state.
The court ruled that partners in a civil union, a relationship status wholly legal in Vermont, are therefore indistinguishable from spouses in marriage to the extent of the rights conferred to a "spouse" under New York's wrongful death statute.
(intermediate appellate level court) overturned the lower court ruling. The appellate court concluded that the state legislature did not contemplate protecting same-sex couples when it enacted the wrongful death statute and that Langan had failed to demonstrate that there was no legitimate purpose for the statute’s exclusion of same-sex couples. Langan v. St. Vincent’s Hospital, 802 N.Y.S.2d 476 (N.Y. App. Div. 2005).
, the state's highest court, affirmed in 2006 the intermediate court's decision to deny Langan standing as surviving "spouse", thus blocking Langan from bringing suit against St. Vincent's Hospital. Langan v. St. Vincent's Hospital, 25 A.D.3d 90, 802 N.Y.S.2d 476 (N.Y. App. Div. 2005), review denied, 850 N.E.2d 672 (N.Y. 2006).
Civil union
A civil union, also referred to as a civil partnership, is a legally recognized form of partnership similar to marriage. Beginning with Denmark in 1989, civil unions under one name or another have been established by law in many developed countries in order to provide same-sex couples rights,...
laws. They were planning to adopt a child, and had purchased a house in Massapequa. Just hours after the closing of their house, Spicehandler was struck by an automobile in Manhattan. Spicehandler subsequently died following treatment at Saint Vincent's Catholic Medical Center
Saint Vincent's Catholic Medical Center
Saint Vincent Catholic Medical Centers ' was a healthcare system, anchored by its flagship hospital, St. Vincent's Hospital Manhattan, locally referred to as "St. Vincent's". St. Vincent's was founded in 1849 and closed in 2010...
. Survivor Langan brought a malpractice suit against the Hospital, arguing standing as a "spouse" for purposes of New York's wrongful death statute.
Lower court ruling
In 2003, the New York Supreme CourtNew York Supreme Court
The Supreme Court of the State of New York is the trial-level court of general jurisdiction in thestate court system of New York, United States. There is a supreme court in each of New York State's 62 counties, although some smaller counties share judges with neighboring counties...
(the state's trial court) held that Langan had standing as a "spouse" for the purposes of New York's wrongful death statute. New York courts, under principles of full faith and credit and comity
Comity
In law, comity specifically refers to legal reciprocity—the principle that one jurisdiction will extend certain courtesies to other nations , particularly by recognizing the validity and effect of their executive, legislative, and judicial acts...
recognize valid contracts established under the laws of her sister states so long as they do not offend a New York state policy. This is especially true of marriages celebrated in other states. Spouses in out-of-state marriages would thus be extended the privileges and immunities the marriage laws of New York extend to marriages officiated in-state. Even common law marriages, which are not recognized for in-state New York cohabiting partners, are recognized for purposes of New York spousal benefits so long as the common law marriage was validly entered into in another state.
The court ruled that partners in a civil union, a relationship status wholly legal in Vermont, are therefore indistinguishable from spouses in marriage to the extent of the rights conferred to a "spouse" under New York's wrongful death statute.
Intermediate court ruling
On Oct. 11, 2005, the New York Supreme Court, Appellate DivisionNew York Supreme Court, Appellate Division
The Supreme Court of the State of New York, Appellate Division is the intermediate appellate court in New York State. The Appellate Division is composed of four departments .*The First Department covers the Bronx The Supreme Court of the State of New York, Appellate Division is the intermediate...
(intermediate appellate level court) overturned the lower court ruling. The appellate court concluded that the state legislature did not contemplate protecting same-sex couples when it enacted the wrongful death statute and that Langan had failed to demonstrate that there was no legitimate purpose for the statute’s exclusion of same-sex couples. Langan v. St. Vincent’s Hospital, 802 N.Y.S.2d 476 (N.Y. App. Div. 2005).
Highest court ruling
The New York Court of AppealsNew York Court of Appeals
The New York Court of Appeals is the highest court in the U.S. state of New York. The Court of Appeals consists of seven judges: the Chief Judge and six associate judges who are appointed by the Governor to 14-year terms...
, the state's highest court, affirmed in 2006 the intermediate court's decision to deny Langan standing as surviving "spouse", thus blocking Langan from bringing suit against St. Vincent's Hospital. Langan v. St. Vincent's Hospital, 25 A.D.3d 90, 802 N.Y.S.2d 476 (N.Y. App. Div. 2005), review denied, 850 N.E.2d 672 (N.Y. 2006).