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In 1972, the United States Supreme Court refused to hear an appeal of Baker v. Nelson. In this case, Mr. Baker had challenged the clerk of the Hennepin County Minnesota district court (Mr. Nelson) for denying his request to marry another man.

In 1993, the Supreme Court of the State of Hawaii ruled that its law limiting marriage to heterosexuals was unconstitutional. In 1998, Hawaiians amended their state constitution to limit marriage to heterosexual couples.

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