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"These beliefs are tied not only to theology but also to religious and family practices, deeply and sincerely held personal beliefs, and entire ways of life," the state said. "They are not less integral to the dignity and identities of millions of Utah citizens than plaintiffs’ sexual orientation is to them."
Upending that understanding of marriage would create the potential for "religion-related strife," it said, impacting rights of religious organizations or members to carry out faith-based or business activities.
Governments face a "perennial challenge" to formally link mothers and fathers to maximize the welfare of children, it said.
"Marriage between the man and woman who create a child provides that essential link," the state said, and encourages those parents to set aside their own personal desires for the benefit of their children.
"The district court’s ruling rests on a very different understanding of the principal public purpose and meaning of marriage — one centered on accommodating adult relationship choices," the state said.
But Utah has "steadfastly" reserved social recognition of marriage for man-woman marriage "so as to guide as many procreative couples as possible into the optimal, conjugal childrearing model."
"While other jurisdictions may choose to elevate adult-centric relationships, Utah has chosen a different course," the state said.
Utah’s marriage laws signal "all would-be parents that the state wants them to do their best to ensure that any children they conceive are raised by their biological mother and father within a stable marital union."
And that model is working, the state said, as reflected by Utah having the lowest percentage of unwed births in the nation, the highest percentage of children being raised by both parents and low child-poverty rates.
"Such real-world benefits to children are exactly what Utah’s marriage policies are intended to produce, and what the district court’s decision both ignores and imperils," the state said.
Redefining marriage to include same-sex couples would "tend to encourage more parents to raise their existing biological children without the other biological parent." The state lists six other possible negative outcomes of such a move, including more out-of-wedlock births; increased divorce rates; increased nonmarital sexual activity; more children being raised by same-sex parents; making it difficult to bar other "innovations" such as group marriage; and decreased interest in marriage.
Utah also has a high birthrate, slightly above the replacement rate. In comparison, fertility and birthrates are "markedly lower" in nations and states that have embraced same-sex marriage, it said.
Utah "has good reason to fear that a judge-imposed redefinition — and the changes to the public meaning of marriage such a redefinition would entail — would over time weaken its marriage tradition enough to reduce its fertility rate, perhaps even below the replacement rate," the state said.
The laws governing marriage do not interfere with the ability of same-sex couples to enter committed, loving relationships or to raise children together, the state argues.
Instead, they "encourage a familial structure that has served society for thousands of years as the ideal setting for raising children. Nothing in the federal Constitution prevents Utah’s citizens from making that choice."
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