On Thursday, March 23, 2016, Professor Shaakirrah R. Sanders presented her recent work-in-progress, The Gay Divorcee, at University of Toledo College of Law. The Gay Divorcee ponders the Court's failure to discuss divorce in Obergefell v. Hodges. In The Gay Divorcee, Professor Sanders argues that divorce fatally undermined the state's procreative justification for same-sex marriage and recognition bans. Professor Sanders concluded that the U.S. marriage equality movement could have been less successful or improbable if spouses who were also the biological parents of children did not have the ability to divorce. The Gay Divorcee is scheduled for submission for publication in the summer of 2017.