Joan was not informed of this mortgage because Head and Master provisions of Louisiana law allowed him to do so without her consent or knowledge.

[1] She then filed a lawsuit arguing that Louisiana's laws giving sole control of marital property to the husband were unconstitutional.

On appeal, the Fifth Circuit overturned the district court, finding the law unconstitutionally violated the Equal Protection Clause, but limited the application of their ruling to future decisions.

[3] Applying intermediate scrutiny as they had in Craig v. Boren, the court held that Louisiana's law lacked an "exceedingly persuasive justification" for its sex-based classification, and therefore was in violation of the Equal Protection Clause of the Fourteenth Amendment.

[2][5] In 2015, during oral arguments in the same-sex marriage case Obergefell v. Hodges U.S. Supreme Court Justice Ruth Bader Ginsburg used the example of the Supreme Court's striking down of Louisiana's Head and Master rule in Kirchberg v. Feenstra to illustrate how "traditional" concepts of marriage had been revised over time.