Skow draws out the inherent tensions in Missouri law that, on the one hand, in 1999 included sexual orientation in its Hate Crimes Act, yet in 2004 passed a state constitutional amendment banning same-sex marriage. Besides the seeming general inconsistency concerning the state’s attitude toward GLBT persons, the author theorizes that the two taken together “may provide a basis for an Equal Protection challenge if the same-sex marriage prohibition amendments inspire the animus that hate crime statutes seek to prevent.”