Littleton v. Prange is a 1999 lawsuit that voided the marriage between a man and a transexual woman. The precedent may result in some Texas marriages being voided where one of the partners is transsexual.[1]
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Christie Lee Littleton was assigned male at birth, in San Antonio, Texas in 1952. She dropped out of school at age 15 and began living as a woman. In 1977 she began taking female hormones and legally changed her name to Christie Lee Cavazos. In 1980, she completed her surgical reassignment and had her state-issued identification changed to female.[2] In the 1990s she met and married Jonathan Mark Littleton in Kentucky, later moving to San Antonio, where she worked at a salon and he worked as a window washer.
After her husband's death, Christie Lee Littleton brought a medical malpractice suit against her husband's doctor, Mark Prange.[3] The defense attorney argued that the marriage was invalid because Christie Lee Littleton was a biological male. On appeal, Chief Justice Phil Hardberger relied on the fact that "Texas statutes do not allow same-sex marriages" and that "male chromosomes do not change with either hormonal treatment or sex reassignment surgery" in handing down his judgment that "Christie Littleton is a male. As a male, Christie cannot be married to another male. Her marriage to Jonathon was invalid, and she cannot bring a cause of action as his surviving spouse."[4]
The decision made it legal for a woman to marry a man who had undergone sex reassignment surgery and transitioned to female.[5][6]
Littleton v. Prange is cited in the 2010 Drop Dead Diva episode "Queen of Mean". In the episode, lawyers for a post-operative transwoman cite the case to prove that her marriage to a biological woman, entered into before she transitioned, was valid, allowing her to inherit her deceased wife's estate.