 Before Obergefell, U.S. law was in patchwork regarding marriages involving at least one transgender person — “trans—marriage,” in Loren Cannon’s term. As a transgender person traveled from state to state, both their legal sex and marital status could change (Cannon 2009, 85). While some raised concerns that the political rationales given for recognizing such marriages (such as the possibility of penile-vaginal intercourse) reaffirmed heteronormative assumptions (Robson 2007), to other theorists, the possibility of trans-marriage itself suggests the instability or incoherence of legal gender categories and gendered restrictions on marriage (Cannon 2009, Almeida 2012).