Supreme Court ruled that the federal constitution required state recognition of same-sex marriages. All state constitutions are trumped by the federal constitution due to the supremacy clause. Conservative mobilization State referendums on constitutional bans of same-sex unions have at times been accused of having been used as a "get-out-the-vote" tactic by some Republicans and social conservatives. When voters see that a particular legislative initiative appears on the ballot, they are thought to feel more motivated to turn out to vote, enhancing ballot numbers for other candidates and issues of their party. The presence of these amendments on state ballots has been credited by some as supposedly providing a boost to Republicans in the 2004 election, and the 2004 Ohio amendment in particular has been cited as aiding President George W. Bush's reelection campaign by motivating evangelical social conservatives in the state to go to the polls. President George W. Bush's close political consultant, Karl Rove, has been an enthusiastic proponent and organizer of legislation banning same-sex unions. After the 2006 elections some activists argued that such referendums were starting to lose their potential to mobilize conservative voters. Kevin Cathcart, director of Lambda Legal pointed to the narrow defeat of Arizona's Proposition 107, which would have rendered civil unions as well as same-sex marriage unconstitutional. Nevertheless, that same election saw seven such amendments pass; these seven included an amendment in Virginia which banned civil unions as well as same-sex marriages. Variants Most U.S. state constitutional amendments banning same-sex unions banned civil unions as well as same-sex marriage. Two marriage amendments differed greatly from all others: Hawaii's and Virginia's. The former gave the Hawaii state legislature the authority to ban same-sex marriages but did not explicitly make such unions unconstitutional. Virginia's amendment not only banned same-sex marriage and civil unions, but arguably rendered any state recognition of private contracts entered into by unmarried couples unconstitutional. Approved amendments Amendments that grant legislative authority to ban same-sex marriage Amendments that ban same-sex marriage Amendments that ban same-sex marriage and civil unions, but not other contracts Amendments that ban same-sex marriage, civil unions, and other contracts Repealed amendments Failed amendments Arizona Proposition 107 – On November 7, 2006, Arizona rejected a constitutional amendment banning same-sex marriage and civil unions by 51.8% of the vote. Two years later Arizona voters approved a more narrow amendment banning only same-sex marriage. Minnesota Amendment 1 – On November 6,