1961 to preserve racial segregation by making it optional for county clerks to issue marriage licenses. The Alabama Legislature passed a bill replacing marriage licenses with marriage certificates in May 2019. These final eight counties resumed allowing couples to marry on August 29, 2019. Several Kentucky counties initially refused to marry same-sex couples. In response, Kentucky reformed its marriage license forms and removed the name of the county clerk from the licenses. As of June 2016, Chris Hartmann, director of the Kentucky-based Fairness Campaign, said that to his knowledge "there are no counties where marriage licenses are being denied" in his state. Parental rights Post-Obergefell, six states have, on occasion, attempted to deny same-sex couples full adoption rights to varying degrees. In Arkansas, Florida, Indiana, and Wisconsin, same-sex couples have been met with rejection when trying to get both parents' names listed on the birth certificate. In V.L. v. E.L., Alabama's highest court attempted to void an adoption decree obtained by a same-sex couple in Georgia, but the U.S. Supreme Court reversed, restoring joint custody to the adoptive mother on March 7, 2016. Mississippi had once banned same-sex couples from adopting, but the law requiring this was ruled unconstitutional by the United States District Court for the Southern District of Mississippi on March 31, 2016. With that ruling, adoption by same-sex couples became legal in all fifty states. On June 26, 2017, the Supreme Court ruled by a 6–3 vote in the case of Pavan v. Smith that under their decision in Obergefell, same-sex couples must be treated equally to opposite-sex couples in the issuance of birth certificates. In December 2016, the Supreme Court of Arkansas upheld a state law only allowing opposite-sex couples to be automatically listed as parents on their children's birth certificates, while prohibiting same-sex couples from being allowed the same on an equal basis. The Supreme Court summarily reversed the Arkansas Supreme Court, finding that the disparity in treatment violated their decision in Obergefell. Tribal law The Supreme Court decision legalizing same-sex marriage in the states and territories did not legalize same-sex marriage in Native American tribal nations. In the United States, Congress (not the federal courts) has legal authority over Native reservations. Thus, unless Congress passes a law regarding same-sex marriage on such reservations, federally recognized Native American tribes have the legal right to form their own marriage laws. As of the time of the