State courts and legislatures each independently expanded same-sex marriage rights.

Evidence

In the decade following the decision, Connecticut, lowa, New Hampshire, New York, and Vermont all recognized same-sex marriages, and New Jersey and Rhode Island recognized same-sex civil unions. In Connecticut and New Jersey, legislative action followed state supreme court rulings recognizing the rights of same-sex couples, while in New Hampshire, New York, and Rhode Island, same-sex couples achieved legislative victories without judicial intervention. — G. Alan Tarr, Judicial Process and Judicial…, 3353

Categorization

• XREF: Links to the course theme of courts as participants in a policy dialogue with legislatures — here both paths produced similar doctrinal outcomes.