the revision retained the abrogation of common-law crimes, eliminated the solicitation provision of the disorderly conduct law, abolished the crime against nature law and set varying ages of consent for different sexual activities. In 1978, the constitution was amended to provide the right to privacy for the first time. Despite the State v. Mueller (1983) ruling which interpreted this amendment conservatively and ruled out any consideration for sexual privacy, the State legislature acted in 1986 to lower the age of consent to 14 years of age, the lowest in the nation at the time. 1990–1994 On December 10, 1990, three same-sex couples applied for marriage licenses at the Hawaii Department of Health. When denied licenses, the couples sue to have the prohibition on licenses for same-sex couples declared unconstitutional and discriminatory, resulting in Baehr v. Miike (originally Baehr v. Lewin). After the case was dismissed by the trial court, the couples appealed to the State Supreme Court. In the plurality opinion delivered by Judge Steven H. Levinson in 1993, the court ruled that while the right to privacy in the Hawaii state constitution does not include a fundamental right to same-sex marriage, denying marriage to same-sex couples constituted discrimination based on sex in violation of the constitutional right to equal protection. The court remanded the case to the trial court, instructing that "in accordance with the 'strict scrutiny' standard, the burden will rest on Lewin to overcome the presumption that HRS § 572-1 [the state's marriage statute] is unconstitutional by demonstrating that it furthers compelling state interests and is narrowly drawn to avoid unnecessary abridgments of constitutional rights." 1995–1999 In 1996, in Baehr v. Miike, Judge Kevin K.S. Chang ruled that the State did not meet its evidentiary burden. It did not prove that the State had a compelling interest in denying marriage licenses to same-sex couples and even assuming that it had it did not prove that HRS § 572-1 was narrowly tailored to avoid unnecessary abridgement of constitutional rights. He enjoined the State from refusing to issue marriage licenses to otherwise-qualified same-sex couples. The following day Chang stayed his ruling, acknowledging the "legally untenable" position couples would be in should the Hawaii Supreme Court reverse him on appeal. In 1997, reciprocal beneficiary relationships were enacted into law by the State Legislature, marking the first state recognition of same-sex couples. It was intended to be an alternative to the