The recognition of same-sex marriages generates debate on both the federal and state levels. Either legislatively or judicially, same-sex marriage is legal in seven states. Other states allow civil unions or domestic partnerships, which may provide similar state-level rights and/or benefits. Many states have statutes or constitutional amendments limiting marriage to one man and one woman. These state-level variations raise questions about the validity of such unions outside the contracted jurisdiction and have bearing on the distribution of federal benefits. The Defense of Marriage Act (DOMA), P.L. 104-199, prohibits federal recognition of same-sex marriages and allows individual states to refuse to recognize such marriages performed in other states. Section 3 of DOMA requires that for purposes of federal benefit programs, marriage is defined as the union of one man and one woman. Lower courts have started addressing DOMA’s constitutionality. On May 31, 2012, the First Circuit became the first federal appellate court to determine DOMA’s constitutionality. The court found that the denial of benefits to same-sex couples residing in a state where they were legally married caused an adverse effect on a historically disadvantaged group.