be seen in the same negative light as earlier constitutional language against African Americans. They also feared that the measure could be used as a legal basis for denying benefits to same-sex couples which are automatically granted to heterosexual married couples. According to Daniel June in JD Journal, Judge Harry Pregerson effectively undermined the ban by declaring it unconstitutional, when he ruled in favor of Allison Clark that she should receive the same work benefits with her homosexual partner as heterosexual couples would receive. On May 19, 2014, United States District Judge Michael McShane ruled that Oregon's constitutional ban on same-sex marriage was unconstitutional. Since then, same-sex marriage has been legally recognized in Oregon. Satirical arguments Marvin Dennis Moore, a Portland church organist, wrote satirical arguments on several Oregon ballot measures, including Measure 36. Moore's arguments, ostensibly in favor of the measure, were printed in the official voters' pamphlet. For example, reacting to some supporters' claims that the purpose of marriage is for procreation, he argues that "couples who fail to conceive within two years ought to have their marriage licenses revoked." Measure 36 supporters criticized the placement of Moore's arguments in the "Arguments in Favor" section of the pamphlet, but the Oregon Secretary of State's Office countered they had no choice under the law but to print his arguments as specified. See also Same-sex marriage in Oregon List of Oregon ballot measures Same-sex marriage in the United States Same-sex marriage legislation in the United States Same-sex marriage in the United States by state Same-sex marriage in the United States public opinion Same-sex marriage status in the United States by state List of benefits of marriage in the United States Defense of Marriage Act Marriage Protection Act Federal Marriage Amendment Domestic partnerships in the United States Freedom to Marry Coalition History of civil marriage in the U.S. Lon Mabon Karen Minnis References External links Oregon Voter's Guide page for Measure 36--includes ballot title, text of the measure, and arguments for and against (including satirical arguments) Oregon Department of Justice page devoted to same-sex marriage 2004 in LGBT history Amendments to the Constitution of Oregon Initiatives in the United States 2004 Oregon ballot measures U.S. state constitutional amendments banning same-sex unions Same-sex marriage ballot measures in the United States