''Littleton v. Prange'', 9 S.W.3d 223 (1999), is a 1999 lawsuit that voided a marriage where one of the individuals was a

transgender woman A trans woman or a transgender woman is a woman who was assigned male at birth. Trans women have a female gender identity, may experience gender dysphoria, and may transition; this process commonly includes hormone replacement therapy and som ...

, Christie Lee Littleton. The Fourth Court of Appeals of Texas ruled that, for purposes of Texas law, Littleton is male, and that her marriage to a man was therefore invalid. Texas law did not recognize

same-sex marriage Same-sex marriage, also known as gay marriage, is the marriage of two people of the same Legal sex and gender, sex or gender. marriage between same-sex couples is legally performed and recognized in 33 countries, with the most recent being ...

at the time of the ruling.''Littleton v. Prange'', No. 99-1214 (Tex. May 18, 2000)

Background

Christie Lee Cavazos was

assigned male ''Assigned Male'' is a webcomic illustrated and written by Sophie Labelle. It draws upon her experiences as a trans girl and woman. The comic, and series of zines, address issues of gender norms and privilege. It began in October 2014 and is on ...

at birth, in

San Antonio, Texas ("Cradle of Freedom") , image_map = , mapsize = 220px , map_caption = Interactive map of San Antonio , subdivision_type = Country , subdivision_name = United States , subdivision_type1= State , subdivision_name1 = Texas , subdivision_t ...

in 1952. She dropped out of school at age 15 and began living as a woman. In 1977, Cavazos began taking female hormones and legally changed her first name. In 1980, she underwent surgical reassignment and had the requisite state-issued identification changed to female.Celia Kitzinger & Sue Wilkinson (2006). Genders, sexualities and equal marriage rights. ''Lesbian and Gay Psychology Review'' In 1989 Cavazos married Jonathan Mark Littleton in Kentucky, later moving to San Antonio.

Case

After Jonathan Littleton's death, Christie Littleton brought a

medical malpractice Medical malpractice is a legal cause of action that occurs when a medical or health care professional, through a negligent act or omission, deviates from standards in their profession, thereby causing injury or death to a patient. The negligen ...

suit against her husband's doctor, Mark Prange.Dahir, Mubarak (October 10, 2000)
Genetics vs. love
''

The Advocate An advocate is a professional in the field of law. The Advocate, The Advocates or Advocate may also refer to: Magazines * ''The Advocate'' (LGBT magazine), an LGBT magazine based in the United States *''The Harvard Advocate'', a literary magazin ...

'' The defense attorney argued that the marriage was invalid because Christie was a biological male. On appeal, Chief Justice

Phil Hardberger Phillip Duane Hardberger (born July 27, 1934) is an American politician and lawyer who served as mayor of San Antonio, taking office in June, 2005. A Democrat, he was elected on a non-partisan ballot. Life and career Family and early years Hardb ...

relied on the fact that "Texas statutes do not allow same-sex marriages" and that "male chromosomes do not change with either hormonal treatment or sex reassignment surgery" in handing down his judgment that "Christie Littleton is a male. As a male, Christie cannot be married to another male. Her marriage to Jonathan was invalid, and she cannot bring a cause of action as his surviving spouse." The decision made it legal for a

cis Cis or cis- may refer to: Places * Cis, Trentino, in Italy * In Poland: ** Cis, Świętokrzyskie Voivodeship, south-central ** Cis, Warmian-Masurian Voivodeship, north Math, science and biology * cis (mathematics) (cis(''θ'')), a trigonome ...

woman to marry a trans woman who had undergone sex reassignment surgery and transitioned to female as long as the two partners were assigned opposite sexes at birth.Pesquera, Adolfo (September 7, 2000). Lesbian couple get license to wed Transsexual ruling clears the way. ''

San Antonio Express-News The ''San Antonio Express-News'' is a daily newspaper in San Antonio, Texas. It is owned by the Hearst Corporation and has offices in San Antonio and Austin, Texas. The ''Express-News'' is the third largest newspaper in the state of Texas, with ...

In fiction

''Littleton v. Prange'' is cited in the fictional 2010 ''

Drop Dead Diva ''Drop Dead Diva'' is an American legal comedy-drama/fantasy television series that aired on Lifetime from July 12, 2009, to June 22, 2014. The series was created by Josh Berman and produced by Sony Pictures Television. It stars Brooke Elliott ...

'' episode "Queen of Mean". In the episode, lawyers for a post-operative trans woman cite the case to prove that her marriage to a cis woman, entered into before she transitioned, was valid, allowing her to inherit her deceased wife's estate.

References

External links

Opinion by Chief Justice Phil HardbergerConcurring Opinion by Justice Karen AngeliniDissenting Opinion by Justice Alma López
at the Texas Fourth Court of Appeals website
Court opinion
at Google Scholar
Story of Christie Lee Littleton
personal website {{LGBT in Texas LGBT in Texas 1999 in United States case law United States transgender rights case law Transgender women-related topics United States same-sex union case law Texas state case law 1999 in Texas Transgender marriage 1999 in LGBT history Marriage in Texas

Background

Case

In fiction

See also

References

External links