If the Supreme Court somehow avoids a ruling on whether there is a constitutional right to same-sex marriage in the Utah case, another recent ruling out of Ohio provides an alternative route to de facto nationwide recognition of marriage equality. In that case, James Obergefell and John Arthur, a gay couple from Ohio flew to Maryland and were legally married on the tarmac at Baltimore Washington International Airport because Arthur had Lou Gehrig's disease. When Arthur died in October, Mr. Obergefell asked that he be listed as a spouse on the death certificate. Federal Judge Timothy S. Black ruled that since Ohio has always recognized other states' marriages as valid (as all states do), it could not refuse to do so in the case of a same-sex couple. If that logic prevails, state-level debates about gay marriage become very different. It's not a question of whether Ohio (or Indiana, or Texas, or wherever) has gay marriage but whether that state's gay couples hold destination weddings in one of the 18 states where such nuptials are allowed.