Ohio Recognizes Out-of-State Same-Sex Marriage

 “This is not a complicated case,” was the first sentence in the decision by the U.S. District Court for the Southern District of Ohio in Obergefell, et al. v. Kasich, et al., Case No. 1:13-cv-501 (S.D. Ohio July 22, 2013).  Granting the plaintiffs’ motion for a temporary restraining order (TRO) against a death certificate that didn’t record as “married” two men who were legally wed in Maryland, Ohio’s first post-United States v