With the United States Supreme Court overturning Texas antisodomy statutes and the consecration of openly gay Rev. Canon V. Gene Robinson as a bishop in the Episcopal Church in New Hampshire, the year 2003 turned out to be a signal one for the struggle for gay and lesbian equality. But the decision, which may have the most profound impact on society was the assertion by the Massachusetts Supreme Judicial Court to the cosntitutional right of same-gender couples to civil marriage.

Marriage as an institution is not exempt from critique. The gay and lesbian theorists of the early Liberation movement of the 1970s, building on the work of the women's movement, projected that same-gender relationships provided an opportunity to dislodge the outdated patriarchal relationships that were inherent in male-female pairings.





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