The author creates a four part typology of state defense of marriage amendments: court-stripping amendments that reserves the question strictly to the legislature; marriage definition amendments that install a one-man-one-woman definition of marriage into the constitution; amendments that ban same-sex marriage and comparable statuses; and amendments banning recognition and the legal incidents thereof. Butland then ascertains the differential impact of the equal protection analysis of Romer v.Evans, 517 U.S. 620 (1996), for each of the four amendment types, concluding that types 3 and 4 violate the Romer standards, while types 1 and 2 do not.