The court subsequently invalidated her revision to her birth certificate, as well as her Kentucky marriage license, ruling "We hold, as a matter of law, that Christie Littleton is a male. As a male, Christie cannot be married to another male. Her marriage to Jonathon was invalid, and she cannot bring a cause of action as his surviving spouse." Littleton appealed to the Supreme Court but it denied her writ of certiorari on October 2, 2000. In the 2001 case In re Estate of Gardiner (2001) the Kansas Appellate Court applied a different standard to the marriage of transgender woman J'Noel Gardiner, concluding that:[A] trial court must consider and decide whether an individual was male or female at the time the individual's marriage license was issued and the individual was married, not simply what the individual's chromosomes were or were not at the moment of birth. The court may use chromosome makeup as one factor, but not the exclusive factor, in arriving at a decision. Aside from chromosomes, we adopt the criteria set forth by Professor Greenberg. On remand, the trial court is directed to consider factors in addition to chromosome makeup, including: gonadal sex, internal morphologic sex, external morphologic sex, hormonal sex, phenotypic sex, assigned sex and gender of rearing, and sexual identity.Gardiner ultimately lost her case in the Kansas Supreme Court, which declared her marriage invalid. In 2002 transgender man Michael Kantaras made national news when he won primary custody of his children upon divorce; however, that case was reversed on appeal in 2004 by the Florida Supreme Court, upholding the claim that the marriage was null and void because Michael Kantaras was still a woman and same-sex marriages were illegal in Florida. The couple settled the case with joint custody in 2005. The 2005 case re Jose Mauricio LOVO-Lara, 23 I&N Dec. 746 (BIA 2005) considered marriage under federal law, as it pertains to immigration. The Board of Immigration Appeals (a federal body under the US Department of Justice) ruled that for purposes of an immigration visa: "A marriage between a postoperative transsexual and a person of the opposite sex may be the basis for benefits under ..., where the State in which the marriage occurred recognizes the change in sex of the postoperative transsexual and considers the marriage a valid heterosexual marriage." See also Transgender history Current issues of gender inequality in the United States for