civil union. Standhardt v. Superior Court ex rel. County of Maricopa, 77 P.3d 451 (Ariz. Ct. App. 2003). The Constitution of Arizona does not provide the right to same-sex marriage. Goodridge v. Dept. of Public Health, 798 N.E.2d 941 (Mass. 2003). The denial of marriage licenses to same-sex couples violated provisions of the Massachusetts State Constitution guaranteeing individual liberty and equality, and it was not rationally related to a legitimate state interest. Morrison v. Sadler, 821 N.E.2d 15 (Ind. Super. Ct. 2005). Indiana's Defense of Marriage Act is valid. Langan v. St. Vincent's Hospital, 802 N.Y.S.2d 476 (App. Div. 2005). For the purposes of New York's wrongful death statute, the survivor partner from a Vermont civil union lacks standing as a "spouse". Citizens for Equal Protection v. Bruning, 455 F.3d 859 (8th Cir. 2006). Nebraska's Initiative Measure 416 does not violate the Fourteenth Amendment's Equal Protection Clause, was not a bill of attainder, and does not violate the First Amendment. Lewis v. Harris, 908 A.2d 196 (N.J. 2006). Prohibiting same-sex marriage does not violate the New Jersey Constitution, but the state must extend all the rights and responsibilities of marriage to same-sex couples. The New Jersey Legislature had 180 days to amend the marriage laws or create a "parallel structure". Andersen v. King County, 138 P.3d 963 (Wash. 2006). Washington's Defense of Marriage Act does not violate the State Constitution. Hernandez v. Robles, 855 N.E.2d 1 (N.Y. 2006). The New York Constitution does not require that marriage rights be extended to same-sex couples. Conaway v. Deane, 932 A.2d 571 (Md. 2007). Upholds a Maryland law defining marriage as the union of a man and a woman. Martinez v. County of Monroe, 850 N.Y.S.2d 740 (App. Div. 2008). Because New York recognizes the marriages of opposite-sex couples from other jurisdictions, it must do the same for same-sex couples. In re Marriage Cases, 183 P.3d 384 (Cal. 2008). Limiting marriage to opposite-sex couples is invalid under the equal protection clause of the California Constitution. Full marriage rights, not merely domestic partnership, must be offered to same-sex couples. Kerrigan v. Commissioner of Public Health, 957 A.2d 407 (Conn. 2008). The availability of civil unions but not marriage to same-sex partners is a violation of the equality and liberty provisions of the Connecticut Constitution. Strauss v. Horton, 207 P.3d 48 (Cal. 2009). Proposition 8 was validly adopted, and marriages contracted before its adoption remain