without the governor's signature. Fourteen states either have not yet formally repealed their laws against sexual activity among consenting adults or have not revised them to accurately reflect their true scope in the aftermath of Lawrence v. Texas. Often, the sodomy law was drafted to also encompass other forms of sexual conduct such as bestiality, and no attempt has subsequently succeeded in separating them. Eleven states' statutes purport to ban all forms of sodomy, some including oral intercourse, regardless of the participants' genders: Florida, Georgia, Louisiana, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, North Carolina, Oklahoma and South Carolina. Three states specifically target their statutes at same-sex relations only: Kansas, Kentucky, and Texas. The age of consent in each jurisdiction varies but in most jurisdictions it is equal to the age of consent for heterosexual sex. The exception to this is Texas, whose statute books still hold an outdated Romeo and Juliet law that makes the age of consent for gay and lesbian teenagers unequal to that for heterosexual ones. Recognition of marriage and adoption for same-sex couples Marriage The movement to obtain civil marriage rights and benefits for same-sex couples in the United States began in the 1970s but remained unsuccessful for over forty years. On May 17, 2004, Massachusetts became the first U.S. state and the sixth jurisdiction in the world to legalize same-sex marriage following the Supreme Judicial Court's decision six months earlier. Before nationwide legalization, same-sex marriage became legal in 36 states; twenty-four states by court order, nine by legislative action, and three by referendum. Some states had legalized same-sex marriage by more than one of the three actions. On June 26, 2015, the Supreme Court ruled in Obergefell v. Hodges that states must license and recognize same-sex marriages. Consequently, same-sex marriage is legal in all 50 states, the District of Columbia, Puerto Rico, Guam, U.S. Virgin Islands, and Northern Mariana Islands. Currently, same-sex marriages are neither licensed nor recognized in American Samoa, due to its unique constitutional status. The legal status of same-sex marriage also varies in Native American tribal nations, as their reservations are considered sovereign entities and were not affected by the Supreme Court's legalization in 2015. Civil unions Prior to nationwide same-sex marriage, fifteen U.S. states had civil unions or domestic partnerships. The first state to allow same-sex unions was Vermont in July 2000. Many of these states retain those laws as a continued