On Tuesday, May 24, 2016, Professor Sanders presented The Gay Divorcee at the International Society of Family Law North American Regional Conference at Grand Teton National Park in Jackson, Wyoming. In The Gay Divorcee, Professor Sanders examines the U.S. Supreme Court's decision in Obergefell v. Hodges, which legalized same-sex marriage nationwide. Professor Sanders ponders the Obergefell Court's failure to discuss the subject of divorce and argues that divorce fatally undermined the state's procreative justification for same-sex marriage and recognition bans. Professor Sanders concludes that the U.S. marriage equality movement could have been less successful or improbable if biological procreative spouses did not have the ability to divorce. Professor Sanders anticipates publishing a law review article of the same title in the 2016-17 academic year.