The U.S. Supreme Court's landmark 2013 decision in United States v. Windsor striking down Section 3 of the federal Defense of Marriage Act (DOMA), which had barred the federal government from recognizing otherwise valid same-sex marriages, has created legal complexities at the state and federal levels. For example, the Social Security Administration and the Internal Revenue Service have enacted differing rules on recognition of same-sex marriages that will lead to inconsistent treatment of Pennslyvanians who have entered into such marriages. Windsor has likewise spawned on-going litigation in both state and federal courts, challenging Pennsylvania's state DOMA. There is a direct challenge on federal constitutional grounds pending in teh U.S. District Court for the Middle District of Pennsylvania ( Whitewood). There is an appeal to the Pennsylvania Supreme Court concerning the legality of the Montgomery County Clerk of Court's issuance of marriage licenses to same-sex couples (Hanes). A group of recipients of those licenses who had marriage ceremonies in Pennsylvania have sued in the Pennsylvania Commonwealth Court seeking a declaratory judgment that their marriages are valid and challenging Pennsylvania's DOMA on both state and federal constitutional grounds (Ballen). Finally, there is the unsettled question of the availability of divorce in Pennsylvania for Pennsylvania residents who entered into same-sex marriages in same-sex marriage states (Kern).