North Carolina Amendment 1

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North Carolina Amendment 1
Flag of North Carolina.svg
May 8, 2012

North Carolina Same-Sex Marriage Amendment
Results
Choice
Votes %
For1,317,17861.04%
Against840,80238.96%
Valid votes2,157,98098.87%
Invalid or blank votes24,6951.13%
Total votes2,182,675100.00%
Registered voters/turnout6,296,75934.27%

2012 North Carolina Amendment 1 results map by county.svg
[1] [2]

North Carolina Amendment 1 (often referred to as simply Amendment 1) was a legislatively referred constitutional amendment in North Carolina that (until overruled in federal court) amended the Constitution of North Carolina to prohibit the state from recognizing or performing same-sex marriages or civil unions. The amendment did not prohibit domestic partnership agreements, but defined male–female marriage as "the only domestic legal union" considered valid or recognized in the state. [3] [4] On May 8, 2012, North Carolina voters approved the amendment, 61% to 39%, with a voter turnout of 35%. [5] On May 23, 2012, the amendment took effect. [6]

Contents

State law had already defined marriage as being between a man and a woman prior to its passage. [7] Amendment 1 was the last state constitutional amendment banning same-sex marriage to be passed in the United States via voter referendum, as well as the shortest-lived: it was found unconstitutional in federal court in October 2014 after then-Attorney General Roy Cooper declined to further defend it.

Full text

ARTICLE XIV, Section 6 of the Constitution of North Carolina, as amended, states: [8]

Marriage between one man and one woman is the only domestic legal union that shall be valid or recognized in this State. This section does not prohibit a private party from entering into contracts with another private party; nor does this section prohibit courts from adjudicating the rights of private parties pursuant to such contracts.

Legislative approval

State constitutional prohibitions on same-sex marriage in the United States on 22 May 2012 State constitutional prohibitions on same-sex marriage on 22 May 2012.svg
State constitutional prohibitions on same-sex marriage in the United States on 22 May 2012

Senate Bill 514 was introduced in the 2011 legislative session North Carolina. [9] Sponsored by Republican State Senator Peter Brunstetter, the bill was passed by the North Carolina General Assembly in September 2011. [10]

Final voting on SB 514 was as follows:

Ten House Democrats voted "aye": William Brisson, James W. Crawford, Jr., Elmer Floyd, Ken Goodman, Charles Graham, Dewey L. Hill, Frank McGuirt, William C. Owens, Jr., Garland E. Pierce and Timothy L. Spear. All House Republicans voted "aye" except for those who did not vote: D. Craig Horn, Chuck McGrady and Glen Bradley. All Senate Democrats voted "no" except for those who did not vote: Eric L. Mansfield (who publicly opposed the bill but was absent due to a planned wedding anniversary trip), [11] Michael P. Walters and Stan White. All Senate Republicans voted "aye", except for one who did not vote, Fletcher Hartsell. [12]

Bill information

The long title of Senate Bill 514 is: "An Act to Amend the Constitution to Provide That Marriage Between One Man and One Woman is the Only Domestic Legal Union That Shall Be Valid or Recognized in This State."

The bill proposed to add a new section to article XIV, which covers miscellaneous provisions. The sections of the bill were: [9]

"Marriage between one man and one woman is the only domestic legal union that shall be valid or recognized in this State. This section does not prohibit a private party from entering into contracts with another private party; nor does this section prohibit courts from adjudicating the rights of private parties pursuant to such contracts."

Specifies that the amendment shall be submitted to voters, and defines the ballot text.

Specifies that a simple majority vote is required for approval.

Specify that the amendment will become effective when it is certified by the Secretary of State.

Potential effects

In a study by Maxine Eichner, Barbara Fedders, Holning Lau, and Rachel Blunk of the University of North Carolina School of Law, the authors discussed how the wording in the proposed amendment could have legal implications beyond banning marriage between same-sex couples. [13] A white paper authored by Lynn Buzzard, William A. Woodruff, and Gregory Wallace of Campbell Law School disagreed with many of those claims. [14]

Employee benefits

Some said that all unmarried couples, both same-sex and opposite-sex, and their children that are receiving domestic-partner benefits as public employees would no longer be eligible for those benefits under this amendment. [15] [16] The second sentence in the amendment sought to address this issue by continuing to allow private-party contracts between employees and employers. For example, a private company could agree to extend health benefits to employees and their partners. [17] However, since "domestic legal union" was untested language in the courts, the issue was considered likely to face litigation to determine what the actual meaning would be and how it would be implemented. [18]

In addition to restricting benefits to couples in domestic partnerships, the amendment could have also stripped protections for unmarried couples such as domestic violence and stalking protections. [15] [16] If the courts had determined that the language used in the amendment invalidates protections for unmarried couples it could have harmed domestic-violence protections for that population. [19] After passing a similar constitutional amendment in Ohio, several courts ruled that domestic violence protections did not apply to unmarried couples and cases were dismissed or told not to press charges. [19] The courts could have determined that validation of unmarried couples domestic legal union status would violate the amendment. [13] However, the counter argument was that North Carolina's domestic-violence statutes were better defined and included protections for unmarried couples. [20]

North Carolina Statute 50B-1, Domestic Violence, states:

(b) For purposes of this section, the term "personal relationship" means a relationship wherein the parties involved

(1) Are current or former spouses;
(2) Are persons of opposite sex who live together or have lived together;
(3) Are related as parents and children, including others acting in loco parentis to a minor child, or as grandparents and grandchildren. For purposes of this subdivision, an aggrieved party may not obtain an order of protection against a child or grandchild under the age of 16;
(4) Have a child in common;
(5) Are current or former household members;
(6) Are persons of the opposite sex who are in a dating relationship or have been in a dating relationship. For purposes of this subdivision, a dating relationship is one wherein the parties are romantically involved over time and on a continuous basis during the course of the relationship. A casual acquaintance or ordinary fraternization between persons in a business or social context is not a dating relationship. [21]

Adoption and child-visitation protections were also in question. While North Carolina only allows adoption by one unmarried adult, [20] there are cases where children are adopted by two unmarried adults (including same-sex couples) in other states and are now living in North Carolina. Since those relationships would not have been recognized under Amendment One, there were potentially serious consequences. In Potential Legal Impacts of the Proposed Same Sex Marriage Amendment, the authors concluded that in child-custody disputes "judges may interpret [amendment one] as an expression of public policy against all non-marital relationships. This interpretation may have caused judges to view such relationships as having a per se negative impact on a child, and fashion custody orders accordingly. [13] They also said that in custody disputes between a parent and non-parent, the courts could decide that one parent's relationship is impermissible since it would validate a domestic legal union other than heterosexual marriage. [13] As with the other protections in question it seemed that the courts would have to decide what the actual interpretation and implementation will be in this area.

Other areas of protection that were under question included hospital visitation, emergency medicals decisions, and disposition of deceased partner's remains. [15] [16] Although there are legal documents that can help protect medical and financial security (power of attorney, living will, medical power of attorney), these could have been contested in court based on the argument that they recognize a domestic legal union between the two parties. [13] Issues in estate planning could have arisen through increased litigation contesting wills of unmarried individuals, particularly those in same-sex relationships. [13] Again, the courts could have ruled that any recognition of a domestic legal union between unmarried partners would be unconstitutional and therefore rule those wills and trusts invalid. [13]

Economics

In addition to legal implications, there were concerns that the amendment would harm economic development and vitality. Some felt that business's employee recruitment and retention would be hurt if the most talented prospects did not feel that North Carolina was progressive or representative of their beliefs. [22] Many Fortune 500 companies have implemented policies protecting employees against discrimination based on sexual orientation, which would not be affected by such legislation. [22]

Public knowledge

An April 2012 Public Policy Polling found that only 40% of North Carolina voters actually knew that Amendment 1 bans both same-sex marriage and civil unions, and among those voters who do know the effects of Amendment 1, they opposed it with 60% against and 38% in favor. Among the 27% of voters who thought Amendment 1 banned same-sex marriage only, they supported it with 72% in favor and 27% against, and with voters who didn't know what Amendment 1 did, they supported it with 64% in favor and 28% against. Among North Carolina voters who were informed about the effects Amendment 1 banning same-sex marriage and civil unions and then asked how they would vote, only 38% continued to support it, 46% against it, and 16% were unsure. When combined those who do and don't know the effects of Amendment 1 it found that 55% would vote for it, 41% would vote against, and 4% were unsure. It also found that 55% of North Carolina voters support legal recognition of same-sex couples with 27% supporting same-sex marriage, 28% supporting civil unions, 41% oppose any legal recognition of same-sex couples, and 4% were unsure. When asked what the effects of Amendment 1 would be, 40% of voters thought that Amendment 1 banned same-sex marriage and civil unions, 27% thought it banned same-sex marriage only, 26% were unsure, and 7% thought it legalized same-sex marriage. [23]

Election spending

The campaigns were fueled by more than $1,000,000 in spending by the pro-amendment coalition Vote For Marriage NC and $2,000,000 in spending by the anti-amendment group Coalition to Protect North Carolina Families. [24] [25] Big donors, making more than $10,000 contributions, were the main source of funds. The Human Rights Campaign, a pro-gay rights group, gave more than $256,000 to the Coalition to Protect NC Families while the National Organization for Marriage (NOM) contributed more than $427,000 to Vote For Marriage NC. [26]

Pre-decision opinion polls

Date of opinion pollConducted by Sample size In favorAgainstUndecidedMarginMargin of ErrorSource
May 5 – 6, 2012 Public Policy Polling 1,026 likely primary voters55%39%6%16% pro±3.1% [27]
April 27 – 29, 2012982 registered voters55%41%4%14% pro [28]
April 20 – 22, 20121,139 registered voters54%40%6%±2.9% [29]
March 26 – 29, 2012 Elon University Poll 534 adults31.9%61.2%6.9%29.3% con4.24% [30]
March 23 – 25, 2012Public Policy Polling1,191 likely primary voters58%38%8%20% pro±2.8% [31]
February 27 – 28, 2012 National Research, Inc. 600 registered voters64%30%6%34% pro±4% [32]
February 26 – March 1, 2012Elon University Poll534 adults37.8%54.2%7.9%16.4% con3.98% [33]
January 5 – 8, 2012Public Policy Polling780 registered voters56%34%10%22% pro±3.5% [34]
December 1 – 4, 2011865 registered voters58%32%26% pro±3.3% [35]
October 27 – 31, 2011615 registered voters59%35%6%24% pro±4% [36]
September 30 – October 3, 2011671 likely primary voters61%34%5%27% pro±4.26% [37]
September 1 – 4, 2011520 voters30%55%15%15% con±4.3% [38]
Same-sex marriage only constitutional ban polling
Date of opinion pollConducted by Sample size In favorAgainstUndecidedMarginMargin of ErrorSource
October 31 – November 2, 2011Elon University Poll529 adults36.5%57%6.5%20.5% con±4.26% [39]
September 25 – 29, 2011594 adults39.1%55.7%5.1%16.6% con±4.02% [40]
August 15 – 16, 2011National Research, Inc.400 unaffiliated general election voters49%43%7%6% pro±4.9% [41]
February 20 – 24, 2011Elon University Poll467 adults37.9%55.8%5.9%17.9% con±4.6% [42]
August 16 – 18, 2010National Research, Inc.400 unaffiliated likely general election voters50%43%7%7% pro±4.9% [43]
October 15 – 19, 2009Elon University Poll620 adults43.3%50.4%6.2%7% con±7.1% [44]

Results

Amendment 1 [45]
ChoiceVotes %
Check-71-128-204-brightblue.svg Yes1,317,17861.04
No840,80238.96
Total votes2,157,980100.00
Registered voters/turnout6,296,75934.66

On May 8, 2012, at 9:00 pm ET the polls closed. At 9:11 pm ET, with 30 percent of the precincts reporting, 43 percent of the vote against and 57 percent of voters approve of the Amendment 1. At 9:15 pm ET, the Associated Press projected, with 35 percent of the vote counted and 58 percent of those casting ballots voted in favor of the amendment, that Amendment 1 had passed. [46] [47]

Of the 100 counties of North Carolina, only Buncombe (home to Asheville), Orange (home to Chapel Hill), Durham (home to the city of Durham), Wake (home to Raleigh), Mecklenburg (home to Charlotte), Chatham, Watauga (home to Boone and Appalachian State University), and Dare voted against Amendment 1. Of the eight counties that voted against Amendment 1, six of them would vote for Barack Obama in the 2012 election, while Watauga County and Dare County voted for Mitt Romney.

Timing of the ballot

The vote on Amendment 1 was held during the lower-turnout North Carolina primary election rather than during a general election when voter turnout is typically higher. Furthermore, whereas the Republican primary was an active contest, the Democratic primary was effectively uncontested and thus had an even further reduced turnout of the Democratic electorate relative to what might have occurred in a hotly contested primary. [48]

Response by President Barack Obama

The day after Amendment 1 passed its public vote, US President Barack Obama expressed disappointment in the outcome [49] and announced his support for same-sex marriage. [50] [51] [52]

On July 28, 2014, the U.S. Court of Appeals for the 4th Circuit affirmed a lower court ruling in Virginia in favor of the freedom to marry, declaring that banning same-sex couples from marriage is unconstitutional under the U.S. Constitution. The decision affirmed the February 13 ruling from U.S. District Court Judge Arenda Wright Allen in Bostic v. Schaefer, in which same-sex couples sought the freedom to marry and respect for their marriages legally performed in other states. On October 6, the United States Supreme Court denied review of this case, meaning that same-sex couples would have the freedom to marry in Virginia.

Since the 4th Circuit also covers Maryland, West Virginia, North and South Carolina, the decision by the Supreme Court to refuse review meant the 4th Circuit decision stood as case law in the other states. With the exception of Maryland, where same-sex marriage was already legal, court cases were promptly filed to strike down various state laws and amendments. [53]

Shortly after 5 p.m. on October 10, 2014, U.S. District Court Judge Max O. Cogburn, Jr. in Asheville issued a ruling in the case of General Synod of the United Church of Christ, et al. v. Drew Reisinger, Register of Deeds of Buncombe County, declaring the amendment unconstitutional, and also declaring unconstitutional "and any other source of state law that operates to deny same-sex couples the right to marry in the State of North Carolina or prohibits recognition of same-sex marriages lawfully solemnized in other States, Territories, or a District of the United States, or threatens clergy or other officiants who solemnize the union of same-sex couples with civil or criminal penalties". [54] [55]

Chris Sgro, executive director of Equality NC, an LGBT rights advocacy organization in North Carolina, said "Today's ruling allowing loving, same-sex couples to marry across North Carolina is a historic moment for our state", and said that "With it, we celebrate with so many North Carolinians who have worked tirelessly over decades to change hearts, minds, and unequal laws in the state we call home. Love won and the barriers to it are done." [56]

Shortly after Cogburn's ruling, the Registers of Deeds in several North Carolina counties reopened (or had previously extended hours in anticipation of the ruling) to issue marriage certificates to same-sex couples that had been waiting for several days.

See also

Related Research Articles

The Federal Marriage Amendment (FMA), also referred to by proponents as the Marriage Protection Amendment, was a proposed amendment to the United States Constitution that would legally define marriage as a union of one man and one woman. The FMA would also prevent judicial extension of marriage rights to same-sex couples.

A domestic partnership is an intimate relationship between people, usually couples, who live together and share a common domestic life but who are not married. People in domestic partnerships receive legal benefits that guarantee right of survivorship, hospital visitation, and other rights.

<span class="mw-page-title-main">2004 Oregon Ballot Measure 36</span> Referendum banning same-sex marriage

Ballot Measure 36 was a 2004 initiative in the U.S. state of Oregon. It amended the Oregon Constitution to define marriage as a union of one man and one woman. The initiative passed with 1,028,546 votes in favor, and 787,556 votes against in the November 2, 2004 general election. It is one of a number of U.S. state constitutional amendments banning same-sex marriage. However, unlike other similar ballot measures passed on or near the same election date, the amendment did not explicitly ban civil unions between same-sex couples.

<span class="mw-page-title-main">Utah Constitutional Amendment 3</span> 2004 referendum

Utah Constitutional Amendment 3 was an amendment to the Utah state constitution that sought to define marriage as a union exclusively between a man and woman. It passed in the November 2, 2004, election, as did similar amendments in ten other states.

<span class="mw-page-title-main">U.S. state constitutional amendments banning same-sex unions</span>

Prior to the Supreme Court's decision in Obergefell v. Hodges (2015), U.S. state constitutional amendments banning same-sex unions of several different types passed, banning legal recognition of same-sex unions in U.S. state constitutions, referred to by proponents as "defense of marriage amendments" or "marriage protection amendments." These state amendments are different from the proposed Federal Marriage Amendment, which would ban same-sex marriage in every U.S. state, and Section 2 of the Defense of Marriage Act, more commonly known as DOMA, which allowed the states not to recognize same-sex marriages from other states. The amendments define marriage as a union between one man and one woman and prevent civil unions or same-sex marriages from being legalized, though some of the amendments bar only the latter. The Obergefell decision in June 2015 invalidated these state constitutional amendments insofar as they prevented same-sex couples from marrying, even though the actual text of these amendments remain written into the state constitutions.

Same-sex marriage has been legally recognized in Oregon since May 19, 2014, when Judge Michael J. McShane of the U.S. District Court for the District Court of Oregon ruled in Geiger v. Kitzhaber that Oregon's 2004 state constitutional amendment banning same-sex marriages discriminated on the basis of sexual orientation in violation of the Equal Protection Clause of the U.S. Constitution. A campaign that was then under way to win voter approval of a constitutional amendment legalizing same-sex marriage was suspended following the decision. In July 2015, Governor Kate Brown signed legislation codifying same-sex marriage in various Oregon statutes. The law change went into effect on January 1, 2016.

Same-sex marriage has been legally recognized in the US state of Washington since December 6, 2012. On February 13, 2012, Governor Christine Gregoire signed legislation that established full marriage rights for same-sex couples in the state of Washington. Opponents mounted a challenge that required voters to approve the statute at a referendum, which they did on November 6. The law took effect on December 6, and the first marriages were performed on December 9. Within a couple of days, more than 600 marriage licenses were issued to same-sex couples in King County alone. Washington was the seventh U.S. state, and the eighth U.S. jurisdiction overall to legally provide same-sex marriages.

<span class="mw-page-title-main">2005 Texas Proposition 2</span>

Proposition 2 was a referendum for a state constitutional amendment placed on the ballot by the Texas legislature and approved by the voters at the November 8, 2005 general election. The measure added a new provision to the Texas Constitution, Article 1, Section 32, which provides that "Marriage in this state shall consist only of the union of one man and one woman", and "This state or a political subdivision of this state may not create or recognize any legal status identical or similar to marriage." Texas thus became the nineteenth US state to adopt constitutional amendment banning same-sex marriage. It was the most populous state to adopt a constitutional ban on same-sex marriage until California passed its ban in November 2008. The amendment was later invalidated after the Supreme Court legalized Same-Sex marriage nationwide following the decision in Obergefell v. Hodges in June 2015, though the amendment is still currently in the Texas Constitution.

<span class="mw-page-title-main">Nebraska Initiative 416</span> Referendum banning same-sex marriage

Nebraska Initiative 416 was a 2000 ballot initiative that amended the Nebraska Constitution to make it unconstitutional for the state to recognize or perform same-sex marriage, same-sex civil unions or domestic partnerships. The referendum was approved on November 7, 2000, by 70% of the voters. The initiative has since been struck down in federal court and same-sex marriage is now legally recognized in the state of Nebraska.

<span class="mw-page-title-main">Same-sex marriage in Hawaii</span>

Same-sex marriage has been legal in Hawaii since December 2, 2013. The Hawaii State Legislature held a special session beginning on October 28, 2013, and passed the Hawaii Marriage Equality Act legalizing same-sex marriage. Governor Neil Abercrombie signed the legislation on November 13, and same-sex couples began marrying on December 2. Hawaii also allows both same-sex and opposite-sex couples to formalize their relationships legally in the form of civil unions and reciprocal beneficiary relationships. Civil unions provide the same rights, benefits, and obligations of marriage at the state level, while reciprocal beneficiary relationships provide a more limited set of rights.

Same-sex marriage has been legally recognized in Wisconsin since October 6, 2014, upon the resolution of a lawsuit challenging the state's ban on same-sex marriage. On October 6, the U.S. Supreme Court refused to hear an appeal of an appellate court ruling in Wolf v. Walker that had found Wisconsin's ban on same-sex marriage unconstitutional. The appellate court issued its order prohibiting enforcement of the state's ban on same-sex marriage the next day and Wisconsin counties began issuing marriage licenses to same-sex couples immediately. Wisconsin had previously recognized domestic partnerships, which afforded limited legal rights to same-sex couples, from August 2009 until they were discontinued in April 2018.

<span class="mw-page-title-main">2008 Florida Amendment 2</span>

Florida Amendment 2 is an amendment made to the Constitution of Florida in 2008. It added Article I, Section 27 to the constitution, which defines marriage as a union only between one man and one woman, and thus bans the creation of similar unions, such as civil unions or same-sex marriage.

Same-sex marriage has been fully recognized in the U.S. state of Minnesota since August 1, 2013. Same-sex marriages have been recognized if performed in other jurisdictions since July 1, 2013, and the state began issuing marriage licenses to same-sex couples on August 1, 2013. After 51.9% of state voters rejected a constitutional amendment to ban same-sex marriage in November 2012, the Minnesota Legislature passed a same-sex marriage bill in May 2013, which Governor Mark Dayton signed on May 14, 2013. Minnesota was the second state in the Midwest, after Iowa, to legalize marriage between same-sex couples, and the first in the region to do so by enacting legislation rather than by court order. Minnesota was the first state to reject a constitutional amendment banning same-sex marriage, though Arizona rejected one in 2006 that banned all legal recognition and later approved one banning only marriage.

Same-sex marriage has been legal in Utah since October 6, 2014. On December 20, 2013, the state began issuing marriage licenses to same-sex couples as a result of the U.S. District Court for the District of Utah's ruling in the case of Kitchen v. Herbert, which found that barring same-sex couples from marrying violates the U.S. Constitution. The issuance of those licenses was halted during the period of January 6, 2014 until October 6, 2014, following the resolution of a lawsuit challenging the state's ban on same-sex marriage. On that day, following the U.S. Supreme Court's refusal to hear an appeal in a case that found Utah's ban on same-sex marriage unconstitutional, the Tenth Circuit Court of Appeals ordered the state to recognize same-sex marriage.

Same-sex marriage has been legally recognized in Nevada since October 9, 2014, when a federal district court judge issued an injunction against Nevada's enforcement of its same-sex marriage ban, acting on order from the Ninth Circuit Court of Appeals. A unanimous three-judge panel of the Ninth Circuit had ruled two days earlier that the state's ban on same-sex marriage was unconstitutional. Same-sex marriage was previously banned by an amendment to the Constitution of Nevada adopted in 2002. The statutory and constitutional bans were repealed in 2017 and 2020, respectively.

Same-sex marriage has been legally recognized in North Carolina since October 10, 2014, when a U.S. District Court judge ruled in General Synod of the United Church of Christ v. Cooper that the state's denial of marriage rights to same-sex couples was unconstitutional. Governor Pat McCrory and Attorney General Roy Cooper had acknowledged that a recent ruling in the Fourth Circuit Court of Appeals and the U.S. Supreme Court's decision not to hear an appeal in that case established the unconstitutionality of North Carolina's ban on same-sex marriage. State legislators sought without success to intervene in lawsuits to defend the state's ban on same-sex marriage.

Same-sex marriage has been legal in South Carolina since a federal court order took effect on November 20, 2014. Another court ruling on November 18 had ordered the state to recognize same-sex marriages from other jurisdictions. Following the 2014 ruling of the Fourth Circuit Court of Appeals in Bostic v. Schaefer, which found Virginia's ban on same-sex marriage unconstitutional and set precedent on every state in the circuit, one judge accepted marriage license applications from same-sex couples until the South Carolina Supreme Court, in response to a request by the Attorney General, ordered him to stop. A federal district court ruled South Carolina's ban on same-sex marriage unconstitutional on November 12, with implementation of that decision stayed until noon on November 20. The first same-sex wedding ceremony was held on November 19.

Same-sex marriage has been legal in Ohio since the U.S. Supreme Court's ruling in Obergefell v. Hodges, a landmark decision in which the court struck down the state's statutory and constitutional bans on same-sex marriage on June 26, 2015. The case was named after plaintiff Jim Obergefell, who sued the state of Ohio after officials refused to recognize his marriage on the death certificate of his husband. Same-sex marriages were performed in Ohio beginning shortly after the Supreme Court released its ruling, as local officials implemented the order.

<span class="mw-page-title-main">LGBT rights in North Carolina</span>

Lesbian, gay, bisexual, and transgender (LGBT) people in the U.S. state of North Carolina may face legal challenges not experienced by non-LGBT residents, or LGBT residents of other states with more liberal laws.

This article contains a timeline of significant events regarding same-sex marriage in the United States. On June 26, 2015, the landmark US Supreme Court decision in Obergefell v. Hodges effectively ended restrictions on same-sex marriage in the United States.

References

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  2. Voter Turnout
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