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A couple married in Michigan in 1984. The wife, Devon, had children from a prior marriage and was in her early fifties. The couple moved to Pennsylvania and lived together as husband and wife for many years. Nineteen years after the wedding, in 2003, the husband underwent sexual reassignment surgery and began to live life as a woman. What effect, if any, did this surgery have on the validity of their marriage? In a recent ruling, Estate of Burnett, the Michigan Court of Appeals said, none at all. Although Michigan law prohibits both the celebration and recognition of same-sex marriage, the Michigan court reasoned that a post-marital sex change did not transform a valid heterosexual marriage into an invalid homosexual one. Nor, the court ruled, did granting a divorce constitute the implicit recognition of a same-sex marriage.