In 1972, the Supreme Court summarily dismissed a challenge to a Minnesota law defining marriage as the union between a man and a woman, rejecting the notion that the Constitution's equal protection clause guaranteed the right of same-sex couples to marry. Citing that standing precedent, the U.S. Court of Appeals for the First Circuit found that it could not proclaim such a right in 2012. Instead, the court issued Thursday a more limited but nevertheless important ruling in the long fight for same-sex marriage equality.