On Friday, November 4, 2016, Associate Professor Shaakirrah R. Sanders presented The Gay Divorcee at the Eighth Annual Loyola University Constitutional Law Colloquium. In The Gay Divorcee, Professor Sanders discusses U.S. Supreme Court's failure to to recognize the importance of divorce in general, and no-fault divorce in particular, to the issue of marriage equality in Obergefell v. Hodges. Professor Sanders discusses how majority opinion's definition of marriage a “lifelong union,” which ignores developments that allow for the termination of a marriage before the death of either spouse. Professor Sanders points out how such developments were a distinct feature of U.S. family law at the time of the founding. Professor Sanders also points out how theories of marriage and divorce at the U.S. founding were based on western European models that originally conceived of procreation as the purpose for marriage, but later evolved to include mutual assistance for the spouse. Professor Sanders argues that the procreation versus mutual assistance debate was directly reflected and prominently featured in Obergefell, but at no point was that debate tied to its origin: divorce. Professor Sanders theorizes that divorce recognition jurisprudence provides a cautionary tale that could have proved useful to the Obergefell Court and ponders the wisdom of ignoring these lessons. The eighth annual Loyola colloquium brought together constitutional law scholars at all stages of their professional development to discuss current projects, doctrinal developments in constitutional law, and future goals. The colloquium provides a forum for the vetting of ideas and invaluable opportunities for informed critiques.