On September 28, 2011, in "Lui v. Holder", U.S. District Court Judge Stephen V. Wilson rejected a challenge to DOMA, citing "Adams v. Howerton" (1982). The plaintiffs in that case had unsuccessfully challenged the denial of immediate relative status to the same-sex spouse of an American citizen. Early in 2012, two bi-national same-sex couples were granted "deferred action" status, suspending deportation proceedings against the non-U.S. citizen for a year. A similar Texas couple had a deportation case dismissed in March 2012, leaving the non-citizen spouse unable to work legally in the United States but no longer subject to the threat of deportation.