choice for same-sex couples, and opposite-sex couples in certain states. Adoption Same-sex couples are allowed to adopt in states and territories following the ruling in Obergefell v. Hodges legalizing same-sex marriage. Prior to Obergefell, various states by legislative and judicial action had allowed joint adoption by same-sex couples. Citizenship Naturalized U.S. citizens whose biological children are born abroad may be unable to obtain U.S. citizenship for their children even if their spouse is also a U.S. citizen. This may disproportionately affect same-sex couples, given that typically only one spouse is biologically related to the child. In October 2020, with representation by Lambda Legal, Immigration Equality and law firm Morgan Lewis & Bockius; the United States Department of State withdrew its appeal of the verdict in Kiviti v. Pompeo, and declined to appeal Mize-Gregg v. Pompeo. The State Department’s refusal to recognize children born overseas to married same-sex, American citizen couples as U.S. citizens was ruled to be unlawful by Federal district court judges in both cases. Former restrictions Defense of Marriage Act The United States Congress enacted the Defense of Marriage Act (DOMA) in 1996, which forbade the federal government from recognizing same-sex marriages and relieved states of the requirement that they recognize same-sex unions performed in other jurisdictions. On June 26, 2013, Section 3 of DOMA ("Definition of marriage") was ruled unconstitutional by the U.S. Supreme Court in United States v. Windsor. The law became effectively unenforceable after the U.S. Supreme Court decision Obergefell v. Hodges (2015) and was fully repealed by the Respect for Marriage Act in 2022.. Former state bans on same-sex marriage After the passage of the DOMA in 1996, many state legislators enacted state statutes, nicknamed mini-DOMA's, that ban same-sex marriage. Beginning in 1972 with Maryland, all states but New Mexico passed a statute banning same-sex marriage prior to nationwide legalization in Obergefell v. Hodges in June 2015. After Massachusetts legalized same-sex marriage in 2004, fourteen states amended their constitution to ban recognition of same-sex marriages and many banning civil unions as well. Twenty-eight states passed state constitutional amendments that banned same-sex marriage: Alabama, Alaska, Arizona, California, Colorado, Florida, Georgia, Idaho, Kansas, Kentucky, Louisiana, Michigan, Mississippi, Missouri, Montana, Nebraska, Nevada, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, South Carolina, South Dakota, Tennessee, Texas, Utah, Virginia, and Wisconsin. Hawaii voters approved a narrower constitutional amendment empowering the legislature to outlaw same-sex marriage, which they had already