The Dutch Parliament is expected to legalize partnerships for same-sex couples by next year and could legalize same-sex marriage within five to 10 years. In Hawaii, lawmakers struggle over how to acknowledge rights for same-sex couples while preserving marriage for a man and a woman.
Holland legalized same-sex marriage in record time, and hundreds of couples exchanged vows, gaining equal rights.
But the country's neighbors don't recognize such unions, leading to potentially traumatic situations.
Consider the following:
A gay spouse lies in a coma in a foreign hospital. Doctors won't recognize his legal spouse for visitation, consultation or medical decisions.
A child's biological mother dies while living in a foreign country. Her lesbian spouse has no rights to the child or spouse's property.
Gay spouses get stopped in a country that prohibits gay sex. Officials jail them, assuming they are having sex as a married couple and breaking the law.
The Dutch Parliament has formed a commission to look at issues such as these as it contemplates legalizing same-sex marriage, which could make Holland the first nation in the world to do so.
Parliament's lower house voted 80-61 last year to create the commission, which will focus on consequences for children and on same-sex couples who travel outside the Netherlands.
The vote reflects support for same-sex marriage but is only one step for a country undecided over whether to allow homosexuals to adopt.
"If the trend continues in Parliament, it will get passed," said Kees Waaldijk, a commission member and Universiteit Utrecht associate law professor specializing in gay and lesbian law. "But the trend may change."
Officials will wait for the commission report, due later this year, and elections in May 1998 before they introduce a same-sex bill.
Bills take three to four years to get through Parliament, putting passage at 2001 at the earliest.
While same-sex marriage faces years of debate, bills for registered partnerships and co-custody will likely pass this year and take effect next January, Waaldijk said.
Partnerships would offer the same rights as marriage except for the right to adopt children. Co-custody would allow nonbiological partners to have authority over a child's maintenance, giving them a say in areas such as education.
Parliament's vote to create the same-sex commission reflects a ruling coalition more liberal than the previous one. Today's coalition, formed in 1994, includes the Social Democrat, Left-wing Liberal and Right-wing Liberal parties.
Christian Democrats, leading opponents of allowing same-sex couples to marry and adopt, fell out of the ruling coalition after the last election. Additionally, only about 5 percent of Parliament's seats belong to conservative Christian parties, which are vocal but carry little weight, Waaldijk said.
The success of a same-sex marriage bill will likely turn on whether adoption remains part of it and how lawmakers repond to public pressure.
"In Holland, there's tolerance for homosexuality up to a point," said Astrid Mittijssen, commission member and lawyer with the Clara Wichmann Instituut for women and the law. "That point is adoption."
Eighty-two Dutch lawmakers previously approved a resolution for same-sex adoption, giving it stronger support than the 80 votes for same-sex marriage. But social opposition from the public is greater against same-sex adoption than marriage, Waaldijk said.
Some supporters may be willing to compromise, achieving full rights in a two-step process. But advocates will likely insist that a bill retain adoption rights.
"Let's ask for the best," said Henk Krol, father and gay newspaper editor. "Not second-class rights but first-class rights. It's not just for the couples, but for the 20,000 children being raised by gays or lesbians."
Mieke Vanderburg, a Social Democrat member and party spokeswoman for family rights, will push for same-sex marriage with adoption.
"There is no reason to make it worse for children when they grow up with two people of the same sex," she said.
Focusing on marriage alone, polls show that about 64 percent of city residents and about 45 percent of country residents favor same-sex marriages, Vanderburg said.
Opponents, who include religious and conservative groups, cite procreation and tradition.
"All over the world marriage is for a man and a woman in a union in which children can be born," said Cees Bremmer, a Christian Democrat and a party spokesman for family law.
Cardinal Adrianus Simonis, a vocal religious leader, dismisses the charge of discrimination in the church definition of marriage, said Janwillen Wits, press officer for the Archdiocese in Utrecht.
"Marriage is marriage with a man and a women and with the theoretical possibility to have children," he said.
Bremmer supports registered partnerships as an alternative to marriage; Simonis favors a contract to protect inheritance rights. Bremmer opposes adoption, but would allow limited co-custody; Simonis has no opinion on adoption.
As in Denmark, many gays and lesbians in the Netherlands oppose marriage as a relationship model. Some prefer individualized contracts, eliminating financial, social or romantic incentives for marriage.
"The government shouldn't be involved with love," said Annelize Van der Stoel, a Liberal Party member. She said officials need to know the status of a couple only for the purposes of taxation, subsidies and inheritance.
Hein Verkerk, a longtime gay activist, said gays supported individual contracts until about five years ago. But partnerships and marriage became "politically correct" as a strategy to end discrimination.
He remains cynical about the approach: "It's an imitation of a system that refused to recognize gays and lesbians until recently."
Waaldijk said he supports same-sex marriage, parental rights for nonbiological partners and redefining "family" as any household in which children are raised.
"Whatever the law offers should be available to same-sex couples," he said. "They should have the freedom to choose."
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Archive of previous same-sex stories