1. dismissing action brought by biological father on behalf of son given that the mother, by virtue of a state court order;Elk Grove Unified Sch. Dist. v. Newdow, 542 U.S,2004
2. Traditionally, marriage defined the scope of state-recognized parenting;See Douglas Nejaime;Marriage Equality and the New Parenthood, 129 HARV. L. REV. 1185,2016