The struggle for same-sex marriage rights in the United States has been long and complicated. Cases challenging various states' refusal to recognize same-sex marriages date back to Baker v. Nelson, a 1971 case upholding the validity of a Minnesota statute defining marriage. 291 Minn. 310 (1971). In 2003, Massachusetts became the first state to legalize same-sex marriage. Goodridge v. Dep't of Public Health, 798 N.E.2d 941 (Mass. 2003). Since then, Connecticut, Iowa, New Hampshire, Vermont, and Washington, D.C., have legalized same-sex marriage. See National Conference of State Legislatures, Same-Sex Marriage, Civil Unions, and Domestic Partnerships (last updated May 2011, last visited June 2, 2011). New York, Rhode Island, and Maryland do not grant same-sex marriage licenses but recognize same-sex marriages performed in other states. Id. Recent polls have indicated the majority of Americans now approve of same-sex marriage. See Nate Silver, Gay Marriage Opponents Now in Minority, New York Times, (Apr. 20, 2011, 11:18 a.m.).
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