Because of the limitation of Commonwealth power, until 1 March 2009 the Family Court could adjudicate on a property dispute if it arose out of only a matrimonial relationship. In 2009 the states agreed to refer power to the Commonwealth to include breakup of de facto relationships (including same sex relationships) which was accepted. The changes, passed by the Labor Rudd Government, came into effect on 1 March 2009. Prior to this de facto and same-sex couples did not have the same property rights as married couples under the Act, and so had to rely on their state's de facto relationship legislation. Such claims were often much harder to prove than under the Act, and did not include all the same considerations as under the Act, and could result in a more uneven or diminished distribution of property than would otherwise be possible.