recognize non-binary people. When a person's gender is not officially recognized, they may seek associated changes, such as to their legal name, including on their birth certificate. The Supreme Court's decision in Obergefell v. Hodges established that equal protection requires all jurisdictions to recognize same-sex marriages, giving transgender people the right to marry regardless of whether their partners are legally considered to be same-sex or opposite-sex. The Matthew Shepard and James Byrd Jr. Hate Crimes Prevention Act, of 2009, added crimes motivated by a victim's actual or perceived gender, sexual orientation, gender identity, or disability to the federal definition of a hate crime. However, only some states and territories include gender identity in their hate crime laws. Marriage In Obergefell v. Hodges, the Court ruled that people have a right to marry without regard to sex. While this is commonly understood as a ruling allowing same-sex marriage, it also meant that a person's sex, whether assigned at birth or recognized following transitioning, can not be used to determine their eligibility to marry. Prior to this ruling, the right of transgender people to marry was often subject to legal challenge—as was the status of their marriages after transitioning, particularly in cases where an individual's birth sex was interpreted to mean a same-sex marriage had taken place. Cases In 1959, Christine Jorgensen, a trans woman, was denied a marriage license by a clerk in New York City, on the basis that her birth certificate listed her as male; Jorgensen did not pursue the matter in court. Later that year, Charlotte McLeod, another trans woman who underwent sex reassignment surgery, married her husband Ralph H. Heidel in Miami. She did not mention her birth sex, however, or the fact she was still legally male. In 1976, the New Jersey case M.T. v. J.T. held that trans people who had undergone sex reassignment surgery could marry as the legal sex matching their gender identity, the first ruling of its kind. Here the court expressly considered the English Corbett v. Corbett decision, but rejected its reasoning. In Littleton v. Prange, (1999), Christie Lee Littleton, a trans woman who had undergone sex reassignment surgery, argued to the Texas 4th Court of Appeals that her marriage to her genetically male husband (deceased) was legally binding and hence she was entitled to his estate. The court decided that plaintiff's sex is equal to her chromosomes, which were XY