Same-sex marriage in Hawaii

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Lesbian, Gay, Bisexual, Transgender
Rights in Hawaii
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Baehr v. Lewin (1993)
Baehr v. Miike (1996, 1999)
Constitutional Amendment 2 (1998)
House Bill 444 (2009)
Senate Bill 232 (2011)
Hawaii Marriage Equality Act (2013)

Equality Hawaii

LGBT rights in the United States
Same-sex marriage in Hawaii
Reciprocal beneficiary relationships in Hawaii
LGBT history in Hawaii

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Same-sex marriage in Hawaii has been legal since December 2, 2013. The Hawaii State Legislature held a special session beginning on October 28, 2013, and passed the Hawaii Marriage Equality Act legalizing same-sex marriage. Governor Neil Abercrombie signed the legislation on November 13, and same-sex couples began marrying on December 2. Hawaii also allows both same-sex and opposite-sex couples to formalize their relationships legally in the form of civil unions and reciprocal beneficiary relationships. Civil unions provide the same rights, benefits, and obligations of marriage at the state level, while reciprocal beneficiary relationships provide a more limited set of rights.

Hawaii's denial of marriage licenses to same-sex couples was first challenged in state court in 1991, and the plaintiffs initially met with some success. In 1993, a ruling by the Hawaiian Supreme Court made Hawaii the first state in the United States to consider legal challenges to bans on same-sex marriage.[1] However, Hawaii voters later modified the state Constitution in 1998 to allow the Legislature to restrict marriage to mixed-sex couples. By the time the Supreme Court of Hawaii considered the final appeal in the case in 1999, it upheld the state's ban on same-sex marriage.

When Hawaii's civil union law took effect at the start of 2012, same-sex marriages established in other jurisdictions were considered civil unions in Hawaii.

Legal history[edit]

Baehr case (1991–1999)[edit]

Baehr v. Miike (originally Baehr v. Lewin) was a case decided by the Supreme Court of Hawaii, which initially found the state's refusal to grant same-sex couples marriage licenses discriminatory. In 1991, three same-sex couples sued Hawaii Director of Health John C. Lewin in his official capacity, seeking to force the state to issue them marriage licenses. After the case was dismissed by the trial court, the couples appealed to the state Supreme Court. In the plurality opinion delivered by Chief Justice Ronald Moon in 1993, the court ruled that while the right to privacy in the Hawaii Constitution does not include a fundamental right to same-sex marriage, denying marriage to same-sex couples constituted discrimination based on sex in violation of the right to equal protection guaranteed by the state's Constitution. The court remanded the case to the trial court, instructing that "in accordance with the 'strict scrutiny' standard, the burden will rest on Lewin to overcome the presumption that HRS § 572-1 [the state's marriage statute] is unconstitutional by demonstrating that it furthers compelling state interests and is narrowly drawn to avoid unnecessary abridgments of constitutional rights."[2]

In 1996, Judge Kevin S.C. Chang ruled that the state did not meet its evidentiary burden. It did not prove that the state had a compelling interest in denying marriage licenses to same-sex couples and even assuming that it had it had not proven that HRS § 572-1 was narrowly tailored to avoid unnecessary abridgement of constitutional rights. He enjoined the state from refusing to issue marriage licenses to otherwise-qualified same-sex couples.[3] The following day, Chang stayed his ruling, acknowledging the "legally untenable" position couples would be in should the Hawaii Supreme Court reverse him on appeal.[4]

On December 9, 1999, the Hawaii Supreme Court, following the passage of a constitutional amendment empowering the Hawaii State Legislature to limit marriage to mixed-sex couples, ruled that "The passage of the marriage amendment placed HRS § 572-1 on new footing. The marriage amendment validated HRS § 572-1 by taking the statute out of the ambit of the equal protection clause of the Hawaii Constitution, at least insofar as the statute, both on its face and as applied, purported to limit access to the marital status to opposite-sex couples. Accordingly, whether or not in the past it was violative of the equal protection clause in the foregoing respect, HRS § 572-1 no longer is. In light of the marriage amendment, HRS § 572-1 must be given full force and effect." Because the remedy sought by the plaintiffs – access to marriage licenses – was no longer available, this reversed Chang's ruling and remanded the case for entry of judgment in favor of the defendant.[2]

Constitutional Amendment 2 (1998)[edit]

Following a 1993 decision by the Hawaii State Supreme Court that found the state's refusal to grant same-sex couples marriage licenses discriminatory, voters in 1998 approved a constitutional amendment granting the Hawaii State Legislature the power to reserve marriage to opposite-sex couples, which made it impossible to challenge the state's ban on same-sex marriage.[5] The state had enacted a statute defining marriage as an institution for "one man and one woman" in 1994, following the first state court decision that questioned the state's denial of marriage licenses to same-sex couples.[6] Both the statute and the constitutional amendment were passed around the same time as the federal Defense of Marriage Act (DOMA; Hawaiian: Kānāwai Kūpale Male o ka makahiki 1996) was enacted into law by the United States Congress.[7]

Civil unions (2009–2011)[edit]

Civil unions (Hawaiian: uniona kīwila, [unijonə tiːˈvilə])[8] were introduced in Hawaii on January 1, 2012, following the passage of legislation in early 2011. These unions provide all of the rights, benefits and responsibilities of marriage at the state level. However, the rights provided for by marriage at the federal level are not granted to couples in civil unions.

Bills creating civil unions were considered several times, but failed to receive approval in legislative committees before 2009.[5] In 2010, Hawaii House Bill 444 (HB 444), which would have created civil unions for same-sex and opposite-sex couples, passed the Hawaii House of Representatives and the Hawaii Senate.[9] Governor Linda Lingle vetoed it in July 2010.[10]

Following Lingle's veto, the American Civil Liberties Union and Lambda Legal filed Young v. Lingle on behalf of six same-sex couples. The suit, while acknowledging that the state has the constitutional authority to limit marriage to opposite-sex couples, asserted that the state Constitution still mandates that same-sex couples be accorded equal treatment.[11] The suit was withdrawn on March 31, 2011.[12][13]

A bill substantively similar to HB 444, Senate Bill 232, was passed on January 26, 2011 by the Senate Judiciary and Labor Committee in a 3–2 vote,[14] and was passed by the full Senate 19–6 on January 28;[15] a modification to the bill was then made in the House of Representatives before passage on February 11 by a vote of 31–19.[16][17] The Senate passed the revised bill on February 16, and Governor Neil Abercrombie signed it into law on February 23. Civil unions began on January 1, 2012.[18]

417 couples obtained a civil union in the first six months after the law went into effect.[19] Low participation may have been the result of technical issues that surrounded the conversion of a reciprocal beneficiary relationship to a civil union. A bill correcting the transitional issues was signed into law on July 6, 2012.[20][21] At the end of 2012, over 700 couples had established civil unions.[22] Since Hawaii enacted same-sex marriage in November 2013, civil unions remain an option for both opposite-sex and same-sex couples to access, making Hawaii one of only four states (Colorado, Illinois and New Jersey being the other three; several other states also recognize domestic partnerships providing many of the benefits of marriage) to allow for this practice.[23]

Jackson case (2012–2014)[edit]

Jackson v. Abercrombie
CourtUnited States District Court for the District of Hawaii
DecidedAugust 8, 2012
Citation(s)884 F. Supp. 2d 1065
Case history
Subsequent action(s)Appealed sub. nom. Jackson v. Fuddy, No. 12-16995, 12-16998 (9th Cir.)
Defendants' motion for summary judgment granted, plaintiff same-sex couples' motion for summary judgement denied; Hawaii's same-sex marriage ban upheld.
Court membership
Judge(s) sittingAlan C. Kay U.S.D.J.

On December 7, 2011, a same-sex couple filed suit in U.S. district court to obtain marriage licenses in Hawaii, which at that time denied licenses to such couples. The state's denial was based on its marriage laws: Article 1 § 23 of the Hawaii Constitution, which leaves any decision on same-sex marriage to the Hawaii State Legislature, along with (since repealed) Hawaii Statute § 572-1, which defined marriage only "between a man and a woman." The initial suit was styled Jackson v. Abercrombie, after first-named-plaintiff Natasha Jackson and first-named-defendant Hawaii Governor Neil Abercrombie. On January 27, 2012, an amended complaint added plaintiff Gary Bradley, one partner in a same-sex civil union, who wanted to marry but thought it futile to apply. The plaintiffs argued that the marriage laws violated the Due Process Clause and Equal Protection Clause of the U.S. Constitution. Governor Abercrombie agreed with the plaintiffs that the ban violated both clauses of the U.S. Constitution, but the state's Director of Health, Loretta Fuddy, was allowed to defend the ban.[24]

Order in Jackson v. Abercrombie[edit]

In an order issued on August 8, 2012, U.S. District Court Judge Alan Kay rejected the plaintiffs' claims and granted defendants' motion for summary judgment, upholding Hawaii's ban on same-sex marriage. Judge Kay's ruling became the first court decision to cite the "New Family Structure" research of Mark Regnerus, research discredited by the American Sociological Association as well as thoroughly rejected by the U.S. District Court for the Northern District of California during the Hollingsworth v. Perry trial.[25][26][27]

Appeal as Jackson v. Fuddy[edit]

The plaintiffs in Jackson appealed Judge Kay's ruling to the Ninth Circuit Court of Appeals, now restyled as Jackson v. Fuddy.[28] The appeal was initially scheduled to be heard on a parallel track with a similar Nevada case before the same court, Sevcik v. Sandoval until both cases were placed on hold, pending Supreme Court decisions in two other same-sex marriage cases, Perry and Windsor. Those cases were resolved on June 26, 2013, and on November 13, Hawaii enacted the Hawaii Marriage Equality Act, ending its ban on same-sex marriage.

Despite that legislation, the plaintiffs did not withdraw their suit as moot, but pressed their appeal seeking to have the lower court's order overturned. The Ninth Circuit heard oral argument on September 8, 2014, along with Sevcik and another related case, Latta v. Otter, before Judges Stephen Reinhardt, Ronald M. Gould, and Marsha Berzon.[29]

The Ninth Circuit announced on October 10, 2014 that it had dismissed the case as moot because of Hawaii's legalization of same-sex marriage and voided the district court's decision.[30]

Same-sex marriage legislation (2013)[edit]

In January 2013, a bill to legalize same-sex marriage in Hawaii was brought before the State Legislature, but the bill died without legislative action. By September, after both the U.S. Supreme Court decisions in United States v. Windsor and Hollingsworth v. Perry, as well as months of negotiations within the Senate and House Democratic caucuses and with leaders of both chambers of the Legislature, Abercrombie called forth a special session for October 28, with the promise of signing the bill, and the chamber leaderships were confident in having the necessary majority for passage.[31]

The state Senate passed the marriage bill on October 30 by a vote of 20–4,[32] and the House followed by a 30–19 vote on November 8,[33][34] though not before an extensive 'citizens filibuster' attempt to block the bill's progress.[35] The bill returned to the Senate for approval of House amendments which expanded religious exemptions and the Senate provided final legislative approval on November 12, voting 19–4 for passage.[36] Governor Neil Abercrombie signed the bill on November 13,[37] and same-sex couples began marrying on December 2, 2013.[38] In the first two weeks after the law went into effect, 526 same-sex couples had applied for marriage licenses.[39]

The law makes provisions to recognize same-sex marriages performed in other states and countries:[40]

Marriages between two individuals regardless of gender and legal where contracted shall be held legal in the courts of this State. [HRS § 572-3]

Legal challenges[edit]

Hawaii Circuit Court Judge Karl Sakamoto heard a legal challenge to the marriage bill filed by Representative Bob McDermott, who contended that the 1998 constitutional amendment prohibited the Legislature from allowing same-sex marriage. The lawsuit sought to prevent any government official from issuing a marriage license until the question of constitutionality was decided.[41][42] On November 14, Judge Sakamoto ruled that the constitutional amendment in question did not force the Legislature to define marriage as between one man and one woman,[42] and that it only gave the Hawaii State Legislature the power to reserve marriage for opposite-sex couples if it chose to do so, and that "after all the legal complexity of the court's analysis, the court will conclude that same-sex marriage in Hawaii is legal."[43] The court granted the state's motion to dismiss the lawsuit, McDermott v. Abercrombie, on January 29, 2014.[44]

An appeal of the dismissal of the McDermott case was heard in the Hawaii Supreme Court, with oral arguments occurring on December 18, 2014.[45][46][47] On May 27, 2015, following the retitling of the case to McDermott v. Ige, the court ruled that the appellants did not have standing to challenge the constitutionality of the Hawaii Marriage Equality Act, vacated the lower court's order and remanded the case back to the circuit court "with instructions to dismiss the case for lack of jurisdiction."[48][49]

Another challenge, Amsterdam v. Abercrombie, was filed by a Hawaii resident on November 25, 2013. On February 19, 2014, Hawaii District Court Judge Susan Oki Mollway found that the plaintiff lacked standing and dismissed the challenge. In August 2016, the Ninth Circuit Court of Appeals upheld the case's dismissal.[50]

Economic impact of same-sex marriage[edit]

A June 2010 study conducted by UCLA indicated that same-sex couples would spend between $4.2 and $9.5 million on their wedding celebrations, if allowed to marry in Hawaii. Out-of-state guests would spend an additional $17.8 to $40.3 million, which would in turn create 193 to 333 new jobs in Hawaii primarily in the events and travel industries. The figures in the study were estimated based on a four-year period.[51]

A July 2013 study conducted by the University of Hawaii estimated an additional $217 million in visitor spending over the following three years if Hawaii legalized same-sex marriage.[52]

Analysis in 2015 estimated that the annual economic impact of same-sex marriage in Hawaii was approximately $26.6 million.[53]

Marriage statistics[edit]

By June 30, 2015, exactly 4,028 same-sex couples had married in the state of Hawaii since legalization on December 2, 2013, making up 10.5% of the state's 38,254 marriages contracted in that time.[54]

According to the Hawaii Department of Health, the number of same-sex marriages performed in the state is as follows:[55]

County 2013 (December only) 2014 2015 2016 2017 2018 Total
Hawaii 85 328 212 158 124 120 1,027
Honolulu 293 1,218 787 666 598 522 4,084
Kauai 53 367 176 182 123 150 1,051
Maui* 102 797 486 369 302 290 2,346
Total 533 2,710 1,661 1,375 1,147 1,082 8,508

Note: * Includes Kalawao County

Public opinion[edit]

Public opinion for same-sex marriage in Hawaii
Poll source Date(s)
Margin of
% support % opposition % no opinion % does not matter
Public Religion Research Institute April 5-December 23, 2017 298 ? 68% 20% 12% -
Public Religion Research Institute May 18, 2016-January 10, 2017 438 ? 68% 25% 7% -
Public Religion Research Institute April 29, 2015-January 7, 2016 239 ? 61% 29% 10% -
New York Times/CBS News/YouGov September 20-October 1, 2014 1,319 likely voters ± 3.6% 59% 26% 15% -
Public Religion Research Institute April 2, 2014-January 4, 2015 195 ? 64% 31% 3% -
Civil Beat October 9–10, 2013 819 registered voters ± 3.4% 44% 44% 4% 7%
QMark Research July 26–30, 2013 442 ? 54% 31% - -
Anzalone Liszt Grove Research January 14–18, 2013 500 residents ? 55% 37% - -
Civil Beat 2012 ? registered voters ± 2.9% 37% 51% 12% -
? likely voters 40% 49% 11% -
? non-voters 27% 57% 16% -
Public Policy Polling October 13–16, 2011 568 voters ± 4.1% 49% 40% 11% -
Civil Beat 2008 ? voters ± 2.9% 43% 44% 13% -

See also[edit]


  1. ^ Schmalz, Jeffrey (May 7, 1993). "In Hawaii, Step Toward Legalized Gay Marriage". The New York Times.
  2. ^ a b Baehr v. Lewin, 74 Haw. 530, 852 P.2d 44 (1993), reconsideration and clarification granted in part, 74 Haw. 645, 852 P.2d 74 (1993).
  3. ^ Baehr v. Miike, Circuit Court for the First Circuit, Hawaii No. 91-1394
  4. ^ Oshiro, Sandra (December 6, 1996). "Hawaiian judge puts same-sex marriage ruling on hold". The Nation. Reuter. p. A12. Retrieved August 18, 2010. CS1 maint: discouraged parameter (link)
  5. ^ a b Niesse, Mark (February 22, 2009). "Hawaii is latest civil unions battleground". Associated Press. Archived from the original on March 1, 2009. Retrieved March 1, 2009. CS1 maint: discouraged parameter (link)
  6. ^ Gross, Jane (April 25, 1994). "After a Ruling, Hawaii Weighs Gay Marriages". New York Times. Retrieved August 27, 2013. CS1 maint: discouraged parameter (link)
  7. ^ "He male kuʻuna kā?". (in Hawaiian). June 29, 2013.
  8. ^ Solis, Kekeha (March 5, 2011). "Ua 'ike 'ia paha kākou hoa kanaka?". Star Advertiser.
  9. ^ "Hawaii Legislature OKs historic civil unions bill; governor now must decide". The Honolulu Advertiser. April 29, 2010. Archived from the original on May 3, 2010. Retrieved April 30, 2010. CS1 maint: discouraged parameter (link)
  10. ^ Sample, Herbert A. (July 7, 2010). "Hawaii governor vetoes same-sex civil unions bill". MSNBC. Retrieved August 27, 2013. CS1 maint: discouraged parameter (link)
  11. ^ "Gay couples sue Hawaii". July 29, 2010. Retrieved July 29, 2010. CS1 maint: discouraged parameter (link)
  12. ^ ACLU of Hawaii (March 31, 2011). "Lambda Legal and ACLU Conclude Lawsuit Seeking Civil Unions". Retrieved November 13, 2013. CS1 maint: discouraged parameter (link)
  13. ^ Lambda Legal. "Young v. Lingle". Retrieved November 13, 2013. CS1 maint: discouraged parameter (link)
  14. ^ "Civil unions bill advances out of Senate committee". Honolulu Star Adviser. January 24, 2011.
  15. ^ Reyes, B.J. (January 29, 2011). "Civil unions bill moves on". Honolulu Star-Advertiser. Retrieved November 13, 2013. CS1 maint: discouraged parameter (link)
  16. ^ Associated Press (February 11, 2011). "Hawaii House passes same-sex civil unions bill". KHON 2.
  17. ^ BJ Reyes (February 11, 2011). "House approves civil unions bill in 31–19 vote". Honolulu Star-Advertiser.
  18. ^ Levs, Josh (January 2, 2012). "Two more states allow same-sex civil unions". CNN. Retrieved August 27, 2013. CS1 maint: discouraged parameter (link)
  19. ^ Akana, Paula (July 5, 2012). Civil union marriage not valid. KITV (Television production). Hearst Television. Retrieved November 13, 2013. CS1 maint: discouraged parameter (link)
  20. ^ Hawaii State Legislature (July 6, 2012). "Governor's Message No. 1370" (PDF). Retrieved November 13, 2013. CS1 maint: discouraged parameter (link)
  21. ^ Hawaii State Legislature (2012). "HB2569 (2012) Archived Status Page". Retrieved November 13, 2013. CS1 maint: discouraged parameter (link)
  22. ^ Stewart, Colin M. (December 16, 2012). "Hawaii sees hundreds of civil unions". Hawaii Tribune-Herald. Stephens Media. Retrieved November 4, 2013. CS1 maint: discouraged parameter (link)
  23. ^ Culhane, John (November 8, 2013). "Gay Marriage Is Booming. Where Does That Leave Civil Unions?". Retrieved November 13, 2013. CS1 maint: discouraged parameter (link)
  24. ^ Jackson v. Abercrombie, 884 F.Supp.2d 1065 (August 8, 2012). "Order Granting Motion for Summary Judgment". Google Scholar.
  25. ^ Blair, Chad (August 8, 2012). "Hawaii Judge Upholds Same-Sex Marriage Ban". Honolulu Civil Beat. Retrieved August 9, 2012. CS1 maint: discouraged parameter (link)
  26. ^ Bartlett, Tom (July 26, 2012). "Controversial Gay-Parenting Study Is Severely Flawed, Journal's Audit Finds". Chronicle of Higher Education. Retrieved August 12, 2012. CS1 maint: discouraged parameter (link)
  27. ^ Marrigan, Haurwitz, Tara, Ralph K.M (July 27, 2012). "UT researcher's study on children of gay parents should not have been published, audit says". Retrieved August 13, 2012. CS1 maint: discouraged parameter (link)
  28. ^ The appeal was docketed as No. 12-16995 for plaintiff Jackson and No. 12-16998 for plaintiff Bradley.
  29. ^ Geidner, Chris (September 8, 2014). "Appeals Court Appears Ready To Strike Down Idaho, Nevada Same-Sex Marriage Bans". BuzzFeed News. Retrieved September 18, 2014. CS1 maint: discouraged parameter (link)
  30. ^ "Memo: District court decision vacated, remanded with instruction to dismiss the case as moot". Retrieved October 10, 2014. CS1 maint: discouraged parameter (link)
  31. ^ "Gov. Abercrombie Calls Special Session on Marriage Equity". Governor of Hawaii. September 9, 2013.
  32. ^ Osher, Wendy (October 30, 2013). "Breaking: Same-Sex Marriage Bill Passes Senate in 20-4 Vote". Retrieved October 30, 2013. CS1 maint: discouraged parameter (link)
  33. ^ "House votes to pass Marriage Equality Bill". Hawaii 24/7. November 6, 2013. Retrieved November 7, 2013. CS1 maint: discouraged parameter (link)
  34. ^ "State House advances same-sex marriage bill after long session". Honolulu Star-Advertiser. November 7, 2013. Retrieved November 7, 2013. CS1 maint: discouraged parameter (link)
  35. ^ Lazo, Alejandro (November 9, 2013). "In Hawaii, 'Citizens' Filibuster' Targets Gay-Marriage Bill". Wall Street Journal. Retrieved November 13, 2013. CS1 maint: discouraged parameter (link)
  36. ^ Ohlheiser, Abby (November 12, 2013). "Hawaii Legislature Sends Same-Sex Marriage Bill to the Governor's Desk". The Atlantic Wire. Retrieved November 13, 2013. CS1 maint: discouraged parameter (link)
  37. ^ "Abercrombie signs same-sex marriage bill into law". Honolulu Star-Advertiser. November 13, 2013. Retrieved November 13, 2013. CS1 maint: discouraged parameter (link)
  38. ^ "First same-sex couples marry in Hawaii". December 2, 2013. Retrieved December 7, 2013. CS1 maint: discouraged parameter (link)
  39. ^ Kobayashi, Ken (December 24, 2013). "Lawyers ask rejection of suit against same-sex marriage law". Honolulu Star-Advertiser. Retrieved December 24, 2013. CS1 maint: discouraged parameter (link) (subscription required)
  40. ^ 2013 Hawaii Revised Statutes TITLE 31. FAMILY 572. Marriage
  41. ^ Muskal, Michael (November 8, 2013). "Hawaii judge says he is open to hearing case on same-sex marriage". Los Angeles Times. Retrieved November 15, 2013. CS1 maint: discouraged parameter (link)
  42. ^ a b Garcia, Oskar (November 14, 2013). "Hawaii judge rejects lawmaker's bid to overturn states' new gay marriage law". LGBTQ Nation. Associated Press. Retrieved November 15, 2013. CS1 maint: discouraged parameter (link)
  43. ^ Karlamangla, Soumya (November 14, 2013). "Hawaii judge refuses to block law permitting same-sex marriage". Los Angeles Times. Retrieved November 15, 2013. CS1 maint: discouraged parameter (link)
  44. ^ DePledge, Derrick (January 30, 2014). "Challenge to marriage equality law rejected". Honolulu Star-Advertiser. Retrieved January 30, 2014. CS1 maint: discouraged parameter (link) (subscription required)
  45. ^ Zimmerman, Malia (November 12, 2014). "Hawaii Supreme Court to hear same sex marriage case". Hawaii Free Press. Retrieved November 12, 2014. CS1 maint: discouraged parameter (link)
  46. ^ Kelleher, Jennifer Sinco (December 18, 2014). "Hawaii Supreme Court hears gay marriage arguments". Honolulu Star-Advertiser. Associated Press. Retrieved December 24, 2014. CS1 maint: discouraged parameter (link)
  47. ^ DePledge, Derrick (December 19, 2014). "Justices question challenge to same-sex marriage law". Honolulu Star-Advertiser. Retrieved December 24, 2014. CS1 maint: discouraged parameter (link) (subscription required)
  48. ^ "McDermott v. Ige" (PDF). Supreme Court of Hawaii. May 27, 2015.
  49. ^ "Hawaii Supreme Court dismisses challenge to marriage equality law". LGBTQNation. May 27, 2015.
  50. ^ 9th Circuit Upholds Dismissal of Challenge to Marriage Equality Act Maui Now
  51. ^ Goldberg, Naomi G.; Sears, Brad; Badgett, M.V. Lee (June 2010). "Potential Impact of HB444 on the State of Hawaiʻi". Los Angeles: The Williams Institute. Retrieved January 5, 2014. CS1 maint: discouraged parameter (link)
  52. ^ Lincoln, Mileka (July 25, 2013). "UH: $217M in tourism if gay marriage in Hawaii". Hawaii News Now. Raycom Media. Retrieved November 7, 2013. CS1 maint: discouraged parameter (link)
  53. ^ Todd Simmons (December 30, 2015). "Finally, Positioning Hawaii As A Gay Wedding Destination". Honolulu Civil Beat.
  54. ^ Todd Simmons (December 30, 2015). "Finally, Positioning Hawaii As A Gay Wedding Destination". Honolulu Civil Beat.

External links[edit]