Brits have got it right

[asterroc]

Elton John got married this week. And the UK did things pretty well as far as I can tell with their civil unions.

Civil union ceremonies are seen as a watershed in the struggle for gay rights in the UK.

The partnerships are not a "marriage" in the religious sense, but give gay and lesbian couples the same legal benefits and responsibilities as heterosexuals who wed in a register office.
CNN

There are still some distinctions between their civil unions and marriage, such as not having the same title.

It gives gay couples the same property and inheritance rights as married heterosexuals and entitles them to the same pension, immigration and tax benefits. But unlike in Belgium, Spain and Canada it is not a marriage.

The procedure is an exclusively civil one in Britain, with the partners merely signing documents, whereas a marriage becomes binding when partners exchange spoken words in a civil or religious ceremony.
CNN


Now, heterosexual marriages from any country are recognized in all other countries. What about homosexual marriages and unions? My guess is that other countries (and US states?) will recognize them as their equivalents under their own laws. I wonder, if someone was married polygamously in another country and then came to the US, how our laws would handle it. Would we prosecute them for polygamy? Would we presume only the first, or one of the person's choice counts? Could the person get divorced from the other spouses?

Comments

[sammka.livejournal.com]

Nope. America, at least, has a habit of not recognizing unions that are contrary to our policies. This is why, for instance, gay marriages in Massachussetts are not recognized in Georgia, despite the general "full faith and credit" that states generally grant to marriages from other states. I'm guessing that a 13-year-old/20-year-old marriage from Kentucky would not be upheld in more liberal states. I remember seeing one news article in which a gay couple married in England, one of whom was American and one of whom was British, and they said they were sad that even now they couldn't move back to America because the marriage wouldn't be recognized and the Englishman wouldn't legally be allowed to take up residence there.

Polygamous marriages from other countries are not recognized. Otherwise there would be a lot of immigration scams in which tons of people people marry one American citizen to get them green cards or citizenship (in fact this is one of the few objections I have to polygamy- too much potential to abuse it as a device for getting benefits).