Many disputes over the validity of marriage occur after a spouse has died and one partner is seeking some sort of benefits or legal action, as is the case for Littleton v. Prange. Christie Lee and Jonathan Littleton married in 1989 in Kentucky and later moved to Texas. After six and a half years of marital bliss, the Texas court system invalidated their marriage given that same-sex marriages are illegal in Texas. Christie Lee Littleton, an MTF transsexual born a biological male, had sex reassignment surgery in 1979, legally changing her birth certificate, and therefore all other documents, to show that she is in fact female. Her husband was aware of this prior to their wedding day. After her husband's death on July 29, 1996, Christie filed a wrongful-death suit, citing malpractice. Lawyers, upon learning of Christie's sex change, then attempted to invalidate Christie's marriage in order to take away any grounds she might have for the suit, as surviving spouse. Contrary to the birth certificate affirming Christie as female, Chief Justice Phil Hardberger was noted as saying, "Male chromosomes do not change with either hormonal treatment or sex reassignment surgery. Biologically a postoperative female transsexual is still male." But do the courts really know Christie's true chromosomes? Chromosomes are rarely, if ever, tested upon birth.

Mubarak Dahir, "Genetics vs. Love: When One Partner is Transgendered, the Courts say DNA Counts More Than a Marriage Certificate," The Advocate, 10 October 2000.