The Superior Court of California held that the marriage of Jake Miller, who uses the stage name Buck Angel, was valid. He and his wife Elayne Angel were married in Louisiana after Buck had obtained a California court order recognizing his male sex and had been living as a man for years. His California birth certificate was amended several years after the marriage. In an effort to avoid paying spousal support, Elayne attempted to argue that their marriage was invalid on the grounds that Buck’s birth certificate had not yet been amended to reflect his male sex at the time the Louisiana marriage took place. The California court ruled that Buck was legally male, and that Louisiana law would recognize this as a marriage between a man and a woman.