The Northern District of Florida’s decision in Brenner, et al. v. Scott, etc., 999 F.Supp. 2d 1278 (2014) about the constitutionality of limiting marriage only to between a man and a woman has been much in the news. The Court makes on page 1290 references that United States Supreme Court “summary dispositions” bind lower federal courts – unless “doctrinal developments in the Supreme Court undermine the decision.” Summary disposition is explained in Alex Hemmer's 2013 article, "Courts as Managers: American Tradition Partnership v.
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