inherently ineligible to marry. This ban does not constitute sex discrimination. 1980s Adams v. Howerton, 673 F.2d 1036 (9th Cir. 1982), cert. denied, 458 U.S. 1111. A same-sex marriage does not make one a "spouse" under the Immigration and Nationality Act. De Santo v. Barnsley, 476 A.2d 952 (Pa. Super. Ct. 1984). Same-sex couples cannot divorce because they cannot form a common law marriage. 1990s In re Estate of Cooper, 149 Misc.2d 282 (Sur. Ct. Kings Co. 1990). The state has a compelling interest in fostering the traditional institution of marriage and prohibiting same-sex marriage. Baehr v. Lewin, 852 P.2d 44 (Haw. 1993). A statute limiting marriage to opposite-sex couples violates the Hawaii Constitution's equal protection clause unless the state can show that the statute is both justified by compelling state interests and also narrowly tailored. This ruling prompted the adoption of Hawaii's constitutional amendment allowing the State Legislature to restrict marriage to different-sex couples and the federal Defense of Marriage Act. Dean v. District of Columbia, 653 A.2d 307 (D.C. 1995). DC does not authorise same-sex marriage; denial of a marriage license does not violate the Due Process Clause of the United States Constitution. Storrs v. Holcomb, 645 N.Y.S.2d 286 (App. Div. 1996). New York does not recognize or authorize same-sex marriage. Overturned in part by Martinez v. County of Monroe in 2008. In re Estate of Hall, 707 N.E.2d 201, 206 (Ill. App. Ct. 1998). Illinois does not recognize a same-sex marriage. The petitioner's claim to be in a same-sex marriage was not in a marriage recognized by law. Baker v. Vermont, 170 Vt. 194; 744 A.2d 864 (Vt. 1999). The Common Benefits Clause of the Constitution of Vermont requires that same-sex couples be granted the same legal rights as married persons, though it need not be called marriage. 2000s Frandsen v. County of Brevard, 828 So. 2d 757 (Fla. 2001). The Florida Constitution will not be construed to recognize same-sex marriage; sex classifications not subject to strict scrutiny under the Constitution. Burns v. Burns, 560 S.E.2d 47 (Ga. Ct. App. 2002). Marriage is the union of one man and one woman. In re Estate of Gardiner, 42 P.3d 120 (Kan. 2002). A post-operative male-to-female transsexual is not a woman within the meaning of the statutes and cannot validly marry a man. Rosengarten v. Downes, 806 A.2d 1066 (Conn. Ct. App. 2002). Connecticut will not dissolve a Vermont