Twenty of the existing state constitutional amendments also prohibit the creation of marriage-equivalent same-sex civil
unions, regardless of what it is called. At least forty-one states have passed their own “defense of marriage” policies by
statute, constitutional amendment, or both. Such defense-of-marriage policies effectively prohibit courts in those states from
recognizing same-sex marriages performed in other jurisdictions, and also express strong public policy in the states barring
same-sex marriage recognition. Nearly two-thirds of American *497 states (thirty-three states) clearly reject and prohibit
either marriage or any marriage-like legal status or marital benefits for same-sex couples. 21 Currently, forty-one American
states (82%) recognize only dual-gender marriage--defining marriage as a union between a man and a woman only.