case. As binding precedent, Baker prevented lower courts from coming to a contrary conclusion when presented with the precise issue the Court adjudicated in dismissing the case. The "moot" question suggested that perhaps the "precise issue" was not the right of citizens to marry the adult of one's choice. Application of the Baker precedent When dealing with precedents like Baker, lower courts may have to guess at the meaning of these unexplained decisions. The Supreme Court has laid out rules, however, to guide lower courts in narrowly applying these summary dispositions: The facts in the potentially binding case must not bear any legally significant differences to the case under consideration. The binding precedent encompasses only the issues presented to the Court, not the reasoning found in the lower court's decision. Of the issues presented, only those necessarily decided by the Court in dismissing the case control. Subsequent developments by the Court on the relevant doctrines may cast doubt on the continuing validity of a summary judgment. In recent years, most judges faced with claims like those in Baker have concluded that subsequent developments render Baker no longer authoritative. During the 2013 oral argument in Hollingsworth v. Perry, U.S. Supreme Court Associate Justice Ruth Bader Ginsburg summarized her view of Baker: "The Supreme Court hadn't even decided that gender-based classifications get any kind of heightened scrutiny. And the same-sex intimate conduct was considered criminal in many states in 1971, so I don't think we can extract much in Baker v. Nelson." Following the Supreme Court's ruling in June 2013 in United States v. Windsor that found unconstitutional the provision of the Defense of Marriage Act that forbade federal government recognition of same-sex marriages, no U.S. Court of Appeals held that Baker controlled in a case challenging a state ban on same-sex marriage, until November 6, 2014, when the Sixth Circuit Court of Appeals ruled that Baker precluded it from considering several such cases from Kentucky, Michigan, Ohio, and Tennessee. The author of the opinion, Judge Jeffrey Sutton, argued that Windsor in no way contradicted Baker: "Windsor invalidated a federal law that refused to respect state laws permitting gay marriage, while Baker upheld the right of the people of a State to define marriage as they see it." He wrote in DeBoer v. Snyder that: Conversely, Judge Martha Craig Daughtrey dissented from the court's decision that Baker was binding precedent. She wrote: