The consequences of these changes for the adults and children involved are heavily debated. In a 2009 Massachusetts spousal benefits case, developmental psychologist Michael Lamb testified that parental sexual orientation does not negatively affect childhood development. "Since the end of the 1980s... it has been well established that children and adolescents can adjust just as well in nontraditional settings as in traditional settings," he argued. However, columnist Maggie Gallagher argues that heteronormative social structures are beneficial to society because they are optimal for the raising of children. Australian-Canadian ethicist Margaret Somerville argues that "giving same-sex couples the right to found a family unlinks parenthood from biology". Recent criticisms of this argument have been made by Timothy Laurie, who argues that both intersex conditions and infertility rates have always complicated links between biology, marriage and child-rearing.