marriage is legal in every state, pursuant to the U.S. Supreme Court ruling in Obergefell v. Hodges. Hate crimes based on sexual orientation or gender identity are also punishable by federal law under the Matthew Shepard and James Byrd, Jr. Hate Crimes Prevention Act of 2009. Adoption policies in regards to gay and lesbian parents also vary greatly from state to state. Some allow adoption by same-sex couples, while others ban all "unmarried couples" from adoption. Family rights after 1980 With the withering and downfall of sodomy laws on a state-by-state basis after 1960, LGBT rights activists began to develop increasingly detailed demands and campaigns for legal equality at all levels of government, a process which has been incremental in each jurisdiction. In 1984, Berkeley, California became the first jurisdiction to recognize same-sex unions of any type (then in the form of domestic partnership health benefits for city employees). In 1999, California passed its domestic partnership law, becoming the first state to recognize same-sex unions; Vermont became the first state to legalize civil unions (often seen as a reduced version of full marriage rights). However, following the Stonewall riots, the social conservative movement in the United States became increasingly defined by its opposition against rights for LGBT people. The most pre-eminent laws advocated at the federal level by social conservative politicians in the 1990s include Don't ask, don't tell, a continued restriction upon the service of LGBT persons in the United States Armed Forces, and the Defense of Marriage Act (DOMA), which defines marriage as a heterosexual-exclusive institution and bars the federal government from recognizing same-sex unions enacted by municipal, state or foreign governments. These were followed by the passage in the 2000s of state-level statutory and constitutional prohibitions of legal recognition of same-sex marriages or unions of any type. However, a number of other states have legalized same-sex marriages or other unions, beginning with Massachusetts in 2004. That state was followed by Connecticut (2008), Iowa (2009), District of Columbia (2009), Vermont (2009), New Hampshire (2010) and New York (2011). The most controversial moment in the history of the movement for same-sex marriage rights took place in California during the period from May 2008, when the State Supreme Court abrogated Proposition 22, which barred the state from legalizing same-sex marriage, as unconstitutional, to November 2008, when Proposition 8, a proposition against the court ruling brought by social conservatives, passed with