have ever cohabited, compared with about half of women with some college (52%) or a college degree (47%)," note the Pew study's authors, Richard Fry and D'Vera Cohn. Before the mid-20th century, laws against cohabitation, fornication, adultery and other such behaviors were common in the US (especially in Southern and Northeastern states), but these laws have been gradually abolished or struck down by courts as unconstitutional. As of April 2016, cohabitation of unmarried couples remains illegal in three states (Mississippi, Michigan, and North Carolina), while as of 2020 fornication remains illegal in two states (Idaho and Mississippi). These laws are almost never enforced and are now believed to be unconstitutional since the legal decision Lawrence v. Texas in 2003. However, these laws may have indirect effects. For example, one consequence may be that one may not claim their partner as a dependent (for a tax exemption), whereas in the other states it may be possible to do so after meeting four criteria: residency, income, support and status. In 2006, in North Carolina, Pender County Superior Court judge Benjamin G. Alford ruled that North Carolina's cohabitation law is unconstitutional. However, the Supreme Court of North Carolina has never had the opportunity to rule on it, so the law's statewide constitutionality remains unclear. On 13 December 2013, US Federal Judge Clark Waddoups ruled in Brown v. Buhman that the portions of Utah's anti-polygamy laws which prohibit multiple cohabitation were unconstitutional, but also allowed Utah to maintain its ban on multiple marriage licenses. This decision was overturned by the United States Court of Appeals for the Tenth Circuit, thus effectively recriminalizing polygamy as a felony. In 2020, Utah voted to downgrade polygamy from a felony to an infraction, but it remains a felony if force, threats or other abuses are involved. Unlawful cohabitation, where prosecutors did not need to prove that a marriage ceremony had taken place (only that a couple had lived together), had been a major tool used to prosecute polygamy in Utah since the 1882 Edmunds Act. Latin America Cohabitation in Latin America is becoming more common. Indeed, although this is a largely Roman Catholic region, it has the highest rates of non-marital childbearing in the world (55–74% of all children in this region are born to unmarried parents). In Mexico, 18.7% of all couples were cohabiting . Among young people, the figures are much higher. As of 2000, in