criminalization of a polygamous lifestyle originated as anti-Mormon laws, although they are rarely enforced. Having multiple non-marital partners, even if married to one, is legal in most U.S. jurisdictions; at most it constitutes grounds for divorce if the spouse is non-consenting, or feels that the interest in a further partner has destabilized the marriage. In some jurisdictions, like North Carolina, a spouse can sue a third party for causing "loss of affection" in or "criminal conversation" (adultery) with their spouse, while more than twenty states in the US have laws against adultery, although they are infrequently enforced after the Supreme Court's ruling in Lawrence v. Texas (which did not explicitly hold such laws to be unconstitutional but whose reasoning clearly implies that conclusion). Polyamory, however, is on a continuum of family-bonds that includes group marriage and it does not refer to bigamy as long as no claim to being married in formal legal terms is made. The Social History of the American Family: An Encyclopedia (2014, edited by Marilyn J. Coleman and Lawrence H. Ganong) stated that under existing U.S. federal law, a polyamorous relationship is legal in all 50 states while polygamy is not. On November 23, 2011, the Supreme Court of British Columbia ruled that the anti-polygamy law of Canada does not affect unformalized polyamorous households; this is why Polyamory Day is celebrated every year on November 23. Even so, those in polyamorous relationships often face legal challenges when it comes to custody, morality clauses, adultery and bigamy laws, housing, and where they live. In 2012, legal scholar Deborah Anapol called for the revision of existing U.S. laws against bigamy to permit married persons to enter into additional marriages, provided that they have first given legal notice to their existing marital partner or partners, with a "dyadic networks" model. In 2015, another legal scholar, Ronald C. Den Otter, wrote in the Emory Law Journal (in the article "Three May Not Be a Crowd: The Case for a Constitutional Right to Plural Marriage") that in the United States the constitutional rights of due process and equal protection fully support marriage rights for polyamorous families. During a PinkNews question-and-answer session in May 2015, Redfern Jon Barrett questioned Natalie Bennett, leader of the Green Party of England and Wales, about her party's stance toward polyamorous marriage rights. Bennett responded by saying that her party is "open" to discussion on the idea