Glossip v. Missouri Department of Transportation & Highway Patrol Employees' Retirement System

Summary

The Missouri Supreme Court upheld the denial of survivor benefits to Kelly Glossip, the unmarried same-sex partner of a deceased highway patrol officer. The Court held that the benefits statute classified claimants by marital status rather than sexual orientation, applied rational-basis review, and was reasonably related to legitimate interests including assisting dependents, controlling costs, and administrative efficiency. The Court also held that the statute was not an unconstitutional special law.

Holdings

1. Glossip had standing to challenge section 104.140.3 because he alleged that he was within the class denied benefits and would have been eligible but for the statute's spousal requirement.
2. Glossip lacked standing to challenge section 104.012 because he was not a member of the class of same-sex married persons disadvantaged by that provision.
3. Section 104.140.3 discriminates on the basis of marital status, not sexual orientation, because it denies benefits to unmarried persons regardless of whether the relationship is same-sex or opposite-sex.
4. The survivor-benefits statute is subject to rational-basis review rather than heightened scrutiny.
5. The spousal requirement is constitutional because it is reasonably related to legitimate state interests in assisting persons financially dependent on deceased patrol employees, controlling costs, and promoting administrative efficiency.
6. The survivor-benefits statute is not a special law because its spousal classification is open-ended and reasonably related to legitimate state interests.

Questions Presented

1. Whether Glossip had standing to challenge the survivor-benefits statute and the statutory definition limiting spouse to an opposite-sex marriage.
2. Whether the survivor-benefits statute and section 104.012 violated the Missouri Constitution's equal-protection guarantee by discriminating on the basis of sexual orientation.
3. Whether the challenged statutes were subject to rational-basis, intermediate, or strict scrutiny.
4. Whether the survivor-benefits statute was an unconstitutional special law under article III, section 40 of the Missouri Constitution.

Disposition

affirmed