Học viện Ngoại giao Tiểu luận môn Đất nước học Anh Mỹ: Same sex marriage in the United States

MINISTRY OF FOREIGN AFFAIRS
DIPLOMATIC ACADEMY OF VIETNAM
ENGLISH FACULTY

COUNTRY STUDY
Same-sex marriage law in the United
States
Course instructor:
ASSOC. PROF. DR Kieu Thi Thu Huong
Student:
Pham Thi Diu
Class: TA43A
Student ID number: TA43A-002-1620
Hanoi, January, 2018
ACKNOWLEDGEMENT
With my limited time and knowledge, I understood that it was
such a dangerous decision when I make up my mind to write this topic.
When there were several ideas sprang to my mind, I told them to some
my friends. And almost of them said to me that I could never make this
thesis completed and I should better change to another easier theme.


But I believed that “You will never reach your destination if you stop and
throw stones at every dog that barks”, I did, and today, this thesis is in
your hand…
I would like to show my gratitude to ASSOC. PROF. DR Kieu Thi Thu
Huong for teaching me enthusiastically for a quite long time and sharing
her pearls of wisdom as well as experiences in writing study with me.
In spite of my endeavours of learning and finding the references
for my thesis, it is inevitable that the thesis has shortcomings, I am
looking forward to receiving the advices and contributions from you for

my more completed thesis.
Thank you and Sincerely!


ABSTRACT
American citizens have struggled for decades to create same-sex
marriage law which allows gay and lesbian couples across the United
States to be able to equalize their marriage registration. Same-sex
marriage law has gradually been applied throughout the United States
from the Federal Government’s ruling in “Obergefell v. Hodges” and the
Supreme Court about changes in the Defense of Marriage Act (DOMA).
There are many legal issues surrounding this law such as tribal law,
federal law, and parental rights. About this law, there are a great
number of politicians and public expressing their own opinions and
viewpoints, which have some effects on the law in general. Other
impacts accompanied on the Federal Government and same-sex couples
in terms of economy, population and health also are an indispensable
part in this thesis.


TABLE OF CONTENTS
Page


CHAPTER 1: INTRODUCTION
1.1. Rationale for study
The American's legalization of same-sex marriage in all 50 states
was seen as an important step in helping LGBT Americans in the United
States have a happier and more equal life than ever before. This was
also considered as a historic victory for LGBT rights activists. However,

there are many people who has still not known about and understood
much the history of this law, the barriers, the arduous struggles in
decades for this law. In modern society, same sex marriage is normal
and should be accepted, everyone has the right to love, be loved and
have a family. Therefore, understanding the history of this law as well as
the process of struggle and the issues surrounding it will make people's
mind up and this will also be a firmly foundation on the fight for freedom
of marriage of all citizens all over the world.
In addition, I am interested in this topic myself. And going to the
theme in a serious and strict manner is also an opportunity for me to
cultivate my ability to learn about British and American Studies and get
acquainted with the work of doing scientific research even if only on a
small topic.
This itself motivated me to write my study with the theme named
“Same-sex marriage law in the United States”.
1.2. Scope of the study
This essay will give readers comprehensive and specific looks as
well as the important information about history and legal issues about
same-sex marriage law in the United States. This means that it will
include significant events since it was a small movement in the early
years until it got 5/4 of the votes and officially became a legal law
throughout the United States in 2015.

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Besides, the essay also brought to the most objective happening
as well as viewpoints about the arguments between factions and
opinions of politicians around the law before it came to unification. One
part of the thesis is also research and assessment of this law's

influences on several aspects of the United States.
1.3. Organization of the study
This thesis shows the comprehensive outlook on same-sex marriage law
in the US. The organization of this thesis is as follows. Chapter 1 is
Introduction which incudes my Acknowledgement, Abstract and Table of
Contents. Chapter 2 includes four small sections. I first describe the
period of history when same-sex marrige became the law throughout 50
states in the US. Then I provide information about legal issues
surrounding this law. In next part, I extend my performance studies by
analysing how people reacted and express opinions on the law. The last
section in Chapter 2 highlight and focus on how same -sex marriage law
effects on American in general. Chapter 3 is Conclusion which
summarises what I have performed. And the last part in the thesis is
References which cites titles, document and reportages as well as name
of their writers I have used to support for my work.

CHAPTER 2: MAIN CONTENT
2.1. History of same-sex marriage law in the United States
Before the 1970s, same-sex marriage was very seldom mentioned
or recognized as a political issue. In August 1953, officials of the U.S
Post Office put off delivery of that monthly issue of ONE magazine, with
cover story "Homosexual Marriage?" and at the same time, they also
tried to determine if its contents were obscene. In June 1971, at New
York City’s Marriage License Bureau, members of the LGBT Activists

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Alliance requested marriage rights for same-sex couples. In October
1971, the Minnesota Supreme Court ruled that the laws of Minnesota

which prohibit marriages between homosexuals were not violation in
federal constitution. Supreme Court also dismissed Baker v. Nelson - a
Minnesota case filed by a gay couple seeking to marry, "for want of a
substantial federal question."
During the 21st century, there was a considerable number of
people supporting same-sex marriage in the U.S when some countries
elsewhere all over the world were opening marriage for same-sex
couples, and national surveys conducted since 2011 revealed that a
majority of Americans support legalizing it. However, at the same time,
lots of states also passed the law to ban against same-sex marriage, by
legislative way or by referendum. On November 18, 2003, the
Massachusetts Supreme Judicial Court ruled in Goodridge v. Department
of Public Health that denying marriage rights to same-sex couples
violated the Massachusetts Constitution. Massachusetts became the
first United States and the sixth jurisdiction in the world to legalize
same-sex marriage on May 17, 2004. On May 9, 2012, the president
Barack Obama became the first sitting U.S. President to publicly declare
support for the legalization of same-sex marriage. Six months later,
Maine, Maryland and Washington were three first states to legalize
same-sex marriage through popular vote. On June 26, 2013, the U.S.
Supreme Court issued a 5/4 decision in United States v. Windsor, ruling
Section 3 of DOMA (Defense of Marriage Act) unconstitutional "as a
deprivation of the equal liberty ... protected by the Fifth Amendment."
The decision was widely quoted by both sides in same-sex marriage
lawsuits. In the two years following Windsor, while two U.S. district
courts and one state court did not find that same-sex marriage bans
violate the U.S. Constitution, U.S. district courts in 27 states and state
courts in six states and one state court ruling addressing only the
recognition of same-sex marriages from other jurisdictions, did. Finally,

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in November 2014, the flow of federal appeal cases rejecting same-sex
marriage bans was interrupted.

Bans on same-sex marriage or its

recognition was found and considered to be unconstitutional by the
panel ruling reversed six U.S. district court rulings, reinstating State
bans in the four states (Kentucky, Michigan, Ohio and Tennessee).
On January 16, 2015, the U.S. Supreme Court agreed to hear four
cases which were Obergefell v. Hodges (Ohio), Tanco v. Haslam
(Tennessee), DeBoer v. Snyder (Michigan), and Bourke v. Beshear
(Kentucky) on whether states may constitutionally ban same-sex
marriages or reject to recognize same-sex marriages legally took place
in another state. Decided by the court under the heading of Obergefell
on June 26, 2015, a 5/4 majority of justices led by Justice Anthony
Kennedy declared that the Court's rulings must evolve in the light of
better understanding of discrimination and the constitutional protections
to protect minorities, and that same-sex couples have the constitutional
rights to marry and to have their own marriages recognized. According
to the Fourteenth Amendment, starting on June 26, 2015, gay and
lesbian couples across the United States were able to equalize their
marriage registration, protected by law. Marriage and related laws such
as divorce, etc. They are entitled to all rights and obligations as a
heterosexual couple.
2.2. Legal issues around United States same-sex marriage law
Before 2004, same-sex marriage was not performed in any U.S.
jurisdiction. It was subsequently legalized in different jurisdictions

through court rulings, tribal council rulings, legislation and popular vote
in referenda. The Supreme Court's ruling in Obergefell's case gives
lumbering legal challenges, because it specifically orders states to both
issue marriage licenses for same-sex couples and to recognize as valid
marriages performed in other states.

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2.2.1. Same-sex marriage under United States federal law
In 2004, according to the Federal Government's Government
Accountability Office, Federal Government gave U.S. citizens more than
1,138 protections and rights in marriage; fields affected include Social
Security

benefits,

veterans'

benefits,

health

insurance,

hospital

visitation, estate taxes, retirement savings, pensions, family leave, and
immigration law. Since July 9, 2015, married same-sex couples in the
United States have equal approach to all the federal benefits like

married opposite-sex couples have.
The Defense of Marriage Act (DOMA) says in Section 2 that no
state needs to recognize the legal validity of a same-sex relationship
even if recognized as marriage by another state while DOMA's Section 3
defined marriage for the purposes of federal law as a union of one man
and one woman. Beginning in 2010, eight federal courts found DOMA
Section 3 unconstitutional in cases involving bankruptcy, public
employee benefits, estate taxes, and immigration. On June 26, 2013 the
U.S. Supreme Court also ruled in Windsor that Section 3 violated the
Fifth Amendment.
As a result of the Windsor decision, married same-sex couples
regardless of domicile have benefits of federal tax, military, federal
employment and immigration. In February 2014, the Justice Department
recognized of same-sex marriages to include bankruptcies, prison visits,
survivor benefits and refusing to testify against a spouse. In the same
way, in June 2014, family medical leave benefits were extended to
married same-sex couples. Formerly, the Veterans Affairs (VA) and the
Social Security Administration (SSA) could provide only limited benefits
to married same-sex couples living in states where same-sex marriage
was not legal. However, after the Supreme Court's ruling in Obergefell v.
Hodges on June 26, 2015, same-sex married couples are also eligible for
full benefits.

Following the Obergefell decision, the Justice Department

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extended all federal marriage benefits to married same-sex couples
nationwide.

Opponents of same-sex marriage have attempted to amend the
United States Constitution to define marriage as a union between one
man and one woman. In 2006, the Federal Marriage Amendment, which
would prohibit states from recognizing same-sex marriages, was
approved by the Senate Judiciary Committee on a party-line vote and
was debated by the full Senate. However, it was finally defeated in both
houses of Congress. On April 2, 2014, the Alabama State House adopted
a resolution calling for a constitutional convention to propose an
amendment to ban same-sex marriage nationwide.
2.2.2. Same-sex marriage under United States tribal law
The Supreme Court decision in Obergefell v. Hodges that legalized
same-sex marriage in the states and most territories did not legalize
same-sex marriage on Indian lands. In the United States, Congress (not
the federal courts) has legal authority over Indian country. Thus, unless
Congress passes a law regarding same-sex marriage for Indian tribes,
federally recognized American Indian tribes have the legal right to form
their own marriage laws. As such, the individual laws of the various
United States federally recognized Native American tribes set the limits
on same-sex marriage under their jurisdictions.
Most, but not all, Native American jurisdictions have no special
regulation for marriages between people of the same sex or gender.
Many Native American belief systems include the two-spirit descriptor
for gender variant individuals and accept two-spirited individuals as
valid members of their tribes. Same-sex marriage is possible in at least
40 Native American tribes, beginning with the Coquille Indian Tribe
(Oregon) in 2009. Marriages performed in these Native American tribes
were first recognized by the Federal Government in 2013 after section 3

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of the Defense of Marriage Act (DOMA) was declared unconstitutional in
United States v. Windsor. As of the time of the Obergefell ruling, 24
tribal jurisdictions legally recognize same-sex marriage. Some tribes
have passed legislation specifically addressing same-sex relationships
and some specify that state law and jurisdiction govern tribal marriages.
As of November 2017, same-sex marriage is legally recognized in 40
tribal jurisdictions.
2.2.3. Parental rights
Before Obergefell, six states have tried to deny same-sex couples
full adoption rights to varying degrees. In Arkansas, Florida, Indiana, and
Wisconsin, same-sex couples have been met with rejection when trying
to get both parents' names listed on the birth certificate. Alabama's
highest court attempted to void an adoption decree obtained by a samesex couple in Georgia, but on March 7, 2016, the United States Supreme
Court unanimously reversed the Supreme Court of Alabama. The court
ruled that the Alabama Supreme Court was incorrect when it refused to
recognize the adoption decree from Georgia, ruling that the Full Faith
and Credit Clause had been violated. The court's decision had the effect
of the adoption decree from Georgia being recognized in Alabama, and
V.L.'s parental rights being restored. The case was remanded to the
Supreme Court of Alabama for further proceedings. The ruling was
described as having the effect of making same-sex adoption essentially
legal in all 50 states. On June 26, 2017, the U.S. Supreme Court granted
the petition for a writ of certiorari sought by the plaintiff parents and
reversed the Arkansas Supreme Court. The Court held by a 6-3 vote that
Arkansas' law only allowing for opposite-sex couples to be named on
their children's birth certificates was an unconstitutional breach of their
ruling in Obergefell v. Hodges. The Supreme Court also ordered all
states to treat same-sex couples equally to opposite-sex couples in the

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issuance of birth certificates. These court rulings have made adoption
by same-sex couples legal in all 50 states.
2.3. Opinions of Politicians and Media
2.3.1. Opinions of Politicians
Obama supported legalizing same-sex marriage when he first ran
for the Illinois Senate in 1996, was undecided about legalizing same-sex
marriage when he ran for re-election to the Illinois Senate in 1998, and
supported civil unions but not same-sex marriage when he ran for the
U.S. Senate in 2004 and for U.S. President in 2008. Obama voted
against the Federal Marriage Amendment which would have defined
marriage as the union of one man and one woman, but stated in a 2008
interview that he personally believed that marriage is "between a man
and a woman" and that he is "not in favor of gay marriage." He
supported civil unions that would establish legal standing equal to that
of marriage for same-sex couples, but believed that decisions about the
definition of marriage should be left to the states. In December 2008,
Obama called for the repeal of the federal Defense of Marriage Act
(DOMA). On May 15, 2008, in a statement in response to the ruling of
the California Supreme Court, Obama announced his opposition to
Proposition 8, an initiative measure proposed for the 2008 California
General Election ballot that would amend the California Constitution to
define marriage as the union of a man and a woman. In a letter read to
the Alice B. Toklas LGBT Democratic Club on June 29, 2008, Obama
reiterated his opposition to the proposed amendment, stating that he
supports extending "fully equal rights and benefits to same-sex couples
under both state and federal law." On May 9, 2012, Obama told an
interviewer that he supported same-sex marriage. He was the first

sitting U.S. President to do so. In October 2014, President Obama told
an interviewer: "Ultimately, I think the Equal Protection Clause does
guarantee same-sex marriage in all fifty states".

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Immediately after winning the 2016 election, President Donald
Trump said he was "fine" to same-sex marriage and believed it would be
resolved by law: " "It's law. It was settled in the Supreme Court. I mean,
it's done." This contrasts with his previous statement in June 2015, after
Obergefell v. Hodges, in which he said he's personally for "traditional
marriage" and that he believed gay marriage should be left for the
states. However, in the same statement, Trump acknowledged that
overturning the Obergefell is unrealistic. Some federal appointments
also declared they would maintain same-sex marriage and enforce the
Supreme Court ruling. Despite he once waving a rainbow flag at
supporters during the 2017 election campaign, his administration has
since been criticized for winding-back LGBTIQ protections, blocking
transgender service in the military and appointing conservatives with
anti-LGBTIQ records – including Attorney General Jeff Sessions and
Education Secretary Betsy DeVos.
Former Presidents Bill Clinton, Jimmy Carter and Barack Obama,
former vice presidents Dick Cheney, Al Gore, Walter Mondale and Joe
Biden have voiced their support for their legal recognition, as well as
former First Lady Laura Bush, Hillary Clinton, Michelle Obama and Nancy
Reagan. Former US President George W. Bush and his wife, former First
Lady Barbara Bush, have served as witnesses to a same-sex marriage
but have not publicly stated that they support gay marriage in general.
The George W. Bush proposed the same marriage, but did not publicly

state his views on the matter (such as the president, he was opposed).
Fifteen US Senators have announced their support in the spring of 2013.
By April 2013, the Senate majority has expressed support for same-sex
marriage. Senator Mark Kirk of Illinois in April, Alaska's Lisa Murkowski in
June and Susan Collins of Maine the following year. Senator Rob Portman
of Ohio became the first Republican senator to endorse a gay marriage
in March 2013.

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During the 2008 presidential election campaign, Republican vicepresidential candidate Sarah Palin stated: "I have voted along with the
vast majority of Alaskans who had the opportunity to vote to amend our
Constitution defining marriage as between one man and one woman. I
wish on a federal level that that's where we would go because I don't
support gay marriage."
When a U.S. district court invalidated the California referendum
that ended same-sex marriages there in 2008, former Speaker of the
House Newt Gingrich said it showed "an outrageous disrespect for our
Constitution and for the majority of people of the United States who
believe marriage is the union of husband and wife". By the end of 2012,
Gingrich was prepared to accept civil—but not religious—same-sex
marriages and encouraged the Republican Party to accept the fact of
same-sex marriage was certain to become legal in more and more
states.
2.3.2. Public Opinions
A CNN poll on February 19, 2015 found that 63% of Americans
believe gays and lesbians have a constitutional right to marry, up from
49% in August 2010. In the wake of the Obergefell decision, CNN polling
found that 59% of Americans felt the decision was correct.

A Washington Post/ABC News poll from February–March 2014
found a record high of 59% of Americans approve of same-sex marriage,
with only 34% opposed and 7% with no opinion. In May 2013, a Gallup
poll showed that 53% of Americans would vote for a law legalizing
same-sex marriage in all 50 states. Three previous readings over the
course of a year consistently showed support at 50% or above. Gallup
noted: "Just three years ago, support for gay marriage was 44%. The
current 53% level of support is essentially double the 27% in Gallup's
initial measurement on gay marriage, in 1996."Some commentators,

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however, have noted instances where polling data has understated
voter opposition to referendums banning same-sex marriage. One 2010
study concluded that "polls on gay marriage ballot initiatives generally
under-estimate the opposition to gay marriage by about seven
percentage points".
As of 2013, public support for same-sex marriage in the United
States has solidified above 50%. Public support for same-sex marriage
has grown at an increasing pace since the 1990s. In 1996, just 25% of
Americans supported legalization of same-sex marriage. Polls have
shown that support is identical among whites and Hispanics, while
support for same-sex marriage trails among blacks. Polling trends in
2010 and 2011 showed support for same-sex marriage gaining a
majority, although the difference is within the error limit of the analysis.
On May 20, 2011, Gallup reported majority support for same-sex
marriage for the first time in the country. In June 2011, two prominent
polling organizations released an analysis of the changing trend in
public opinion about same-sex marriage in the United States, concluding

that "public support for the freedom to marry has increased, at an
accelerating rate, with most polls showing that a majority of Americans
now support full marriage rights for all Americans." Gallup's annual
Values and Beliefs poll, conducted in May 2017, found that 64% of U.S.
adults say same-sex marriages should be recognized by the law as valid,
the highest percentage of support recorded to date by the polling firm.
By 2017, according to a PRRI poll, same-sex marriage enjoyed
popular support in all but 6 U.S. states. Of these 6 states, 3 had an
outright majority against same-sex marriage (Arkansas, Mississippi and
West Virginia), while the 3 others had a plurality against same-sex
marriage but not a majority (Alabama, Louisiana and South Carolina).
The state of North Dakota was evenly split, while the 43 remaining
states all supported same-sex marriage, going from 74% support in

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Massachusetts to a plurality of 49% in Kentucky, North Carolina,
Tennessee and Wyoming.
2.4. Effects of same-sex marriage law
2.4.1. Economic impacts on the Federal Government
The 2004 Congressional Budget Office study, working from an
assumption "that about 0.6 percent of adults would enter into same-sex
marriages if they had the opportunity" (an assumption in which they
admitted "significant uncertainty") estimated that legalizing same-sex
marriage throughout the United States "would improve the budget's
bottom line to a small extent: by less than $1 billion in each of the next
10 years". This result reflects an increase in net government revenues
(increased income taxes due to marriage penalties more than offsetting
decreased tax revenues arising from postponed estate taxes). Marriage

recognition would increase the government expenses for Social Security
and Federal Employee Health Benefits but that increase would be more
than made up for by decreased expenses for Medicaid, Medicare, and
Supplemental Security Income.
2.4.2. Economic impacts on same-sex marriage couples
According to a 1997 General Accounting Office study, at least
1,049 U.S. federal laws and regulations include references to marital
status. A 2004 study by the Congressional Budget Office found 1,138
statutory provisions "in which marital status is a factor in determining or
receiving 'benefits, rights, and privileges.'" Many of these laws govern
property rights, benefits, and taxation. Same-sex couples whose
marriages are not recognized by the federal government are ineligible
for spousal and survivor Social Security benefits and are ineligible for
the benefits due the spouse of a federal government employee. One
study found that the difference in Social Security income for same-sex
couples compared to opposite-sex married couples was per year.

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Compared to similarly situated opposite-sex married couples,
same-sex couples faced the following financial and legal disadvantages.
They may have difficulties in legal costs associated with obtaining
domestic partner documents to gain legal abilities granted automatically
by legal marriage, including power of attorney, health care decisionmaking, and inheritance. Same-sex couples were not also eligible to file
jointly as a married couple and thus could not take the advantages of
lower tax rates when the individual income of the partners differs
significantly. Moreover, they have to pay higher health costs associated
with lack of insurance and preventative care: 20% of same-sex couples
had a member who was uninsured compared to 10% of married

opposite-sex couples. Also, a same-sex partner has to incur an estate
tax if he or she inherit an unlimited amount from a deceased spouse.
Others difficulties accompanied such as they are not able to protect
jointly owned home from loss due to costs of potential medical
catastrophe or not able to be a U.S. citizen to sponsor a same-sex
spouse for citizenship.
Some 7,400 companies were offering spousal benefits to samesex couples as of 2008. In states that recognized same-sex marriages,
same-sex couples could continue to receive those same benefits only if
they married. Only 18% of private employers offered domestic partner
health care benefits.
In addition, same-sex couples have to face the same financial
constraints of legal marriage as opposite-sex married couples, including
the marriage penalty in taxation. While social service providers usually
do not count one partner's assets toward the income means test for
welfare and disability assistance for the other partner, a legally married
couple's joint assets are normally used in calculating whether a married
individual qualifies for assistance.

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2.4.3. Health impacts on same-sex marriage couples
For meatal health, based in part on research that has been
conducted on the adverse effects of stigmatization of gays and lesbians,
numerous prominent social science organizations have issued position
statements supporting same-sex marriage and opposing discrimination
on the basis of sexual orientation; these organizations include the
American Psychoanalytic Association and the American Psychological
Association.
Several psychological studies have shown that an increase in

exposure to negative conversations and media messages about samesex marriage creates a harmful environment for the LGBT population
that may affect their health and well-being.
One study surveyed more than 1,500 lesbian, gay and bisexual
adults across the nation and found that respondents from the 25 states
that have outlawed same-sex marriage had the highest reports of
"minority stress" - the chronic social stress that results from minoritygroup stigmatization as well as general psychological distress. According
to the study, the negative campaigning that comes with a ban is directly
responsible for the increased stress. Past research has shown that
minority stress is linked to health risks such as risky sexual behavior and
substance abuse.
Two other studies examined personal reports from LGBT adults
and their families living in Memphis, Tennessee, immediately after a
successful 2006 ballot campaign banned same-sex marriage. Most
respondents reported feeling alienated from their communities. The
studies also found that families experienced a kind of secondary
minority stress, says Jennifer Arm, a counseling graduate student at the
University of Memphis.

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At the Perry v. Schwarzenegger trial, expert witness Ilan Meyer
testified that the mental health outcomes for gays and lesbians would
improve if laws such as Proposition 8 did not exist because "when
people are exposed to more stress...they are more likely to get sick..."
and that particular situation is consistent with laws that say to gay
people "you are not welcome here, your relationships are not valued."
Such laws have "significant power", he said.
For physical health, in 2009, a pair of economists at Emory
University tied the passage of state bans on same-sex marriage in the

US to an increase in the rates of HIV infection. The study linked the
passage of same-sex marriage ban in a state to an increase in the
annual HIV rate within that state of roughly 4 cases per 100,000
population.
A study by the Columbia Mailman School of Public Health found
that gay men in Massachusetts visited health clinics significantly less
often following the legalization of same-sex marriage in that state.

CHAPTER 3: CONCLUSION
Overcoming many difficulties in legal issues as well as public
opinion fights, ultimately, the law allowing same-sex marriage was
popular in all states of the United States. Same-sex marriage law in the
United States is a great breakthrough for human rights. This is not only
a happiness for US citizens but for the LGBT community around the
world. This was a reward for their enduring efforts, a stepping stone for
anti-discrimination at both the federal and state levels in the United
States, where dozens of people may be fired or refused because of
same-sex orientation. It was also the opening shot of struggle for
freedom of association in countries around the world. Although the
effects of this legislation on the United States, on same-sex couples are

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not small at this time, it is promised that in the future this law will be
more and more complementary to bring more benefits to LGBT people in
the United States.
REFERENCES
[1] Liptak, Adam. "Same-Sex Marriage Is a Right, Supreme Court
Rules, 5-4". The New York Times. Retrieved December 28, 2017.

[2] "CNN poll: 63 percent of Americans say same-sex couples have
a right to marry". LGBTQ Nation. Retrieved December 29, 2017.
[3] "Deboer v. Snyder: Findings of Fact and Conclusions of Law"
(PDF). United States District Court for the Eastern District of Michigan
Southern Division. March 15, 2014. Retrieved December 31, 2017.
[4] "Obama and Miss California aligned on same-sex marriage?".
The Christian Science Monitor. May 12, 2009. Retrieved December 31,
2017.
[5] Wing, Nick. Hillary Clinton Announces Support For Gay
Marriage. The Huffington Post. March 18, 2013. Retrieved January 01,
2018.
[6] The Rapid Increase in Support for Marriage Changes Political
Equation: Emerging Majority Supports the Freedom to Marry. Joel
Benenson, Benenson Strategy Group, and Jan van Lohuizen, Voter
Consumer Research. July 27, 2011. Retrieved January 02, 2018.

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