ABSTRACT
One of the most dramatic statements of change came in June 2015, when the Supreme Court announced in Obergefell v. Hodges that both the due process and equal protection clauses of the Fourteenth Amendment protect the right of same-sex couples to marry and to have those marriages recognized in other states. It was a momentous change in civil rights law. As is true of other areas of civil rights law and policy, it is very much a work in progress. The change is dramatic for many reasons, but particularly because of just how extreme discrimination against people because of sexual orientation has been, and how recently the change has taken place. It was not long ago that the US Supreme Court rejected the idea that discrimination on the basis of sexual orientation or identity triggered any constitutional or statutory protection. Procreation occurs through sexual relations between a man and a woman.
