Also in 2013, Chief Justice Rabner authored a unanimous decision denying the state's application for a stay of a trial court order permitting same-sex couples to marry. "Garden State Equality v. Dow" The ruling was the first by a State Supreme Court in the wake of the United States Supreme Court's decision in "United States v. Windsor". Windsor struck down part of the federal Defense of Marriage Act (DOMA) and held that DOMA violated the federal constitution by denying lawfully married same-sex couples the benefits given to married couples of the opposite sex. In the wake of that decision, a number of federal agencies extended federal benefits to married same-sex couples but not to partners in civil unions. Under New Jersey state law, same-sex couples could enter into civil unions but could not marry. As a result, the New Jersey Supreme Court concluded that the state constitution's guarantee of equal protection for same-sex couples was not being met; that the harm to same-sex couples was real, not speculative; and that the public interest did not favor a stay. Three days after the ruling, same-sex couples began to marry, and the state withdrew its appeal of the trial court order, effectively ending the litigation.