In Pavan v. Smith, the U.S Supreme Court ruled in favor of same-sex couples' rights to have both parents listed on their child's birth certificate. The case involved two married lesbian couples from Arkansas who had conceived through artificial insemination. When they sought to list both mothers on their children’s birth certificates, state officials only allowed the biological mother to be listed, citing a statute that presumed a woman's husband as the father of her child unless paternity was legally rebutted. The women sued and won at trial court but lost at the Arkansas Supreme Court which held that this law did not violate Obergefell v Hodges (2015) ruling because it was an issue of biology or parental rights rather than marriage equality. The U.S Supreme Court reversed this decision in 2017 stating that by denying married same-sex couples access to "the constellation of benefits" linked with birth certificates, Arkansas law treated those couples differently than opposite-sex ones thus violating Obergefell’s commitment to provide same-sex couples “the constellation of benefits that the States have linked to marriage.” This landmark ruling affirmed equal treatment for all marriages under law.

In the case of PAVAN v. SMITH, there was no formal dissenting opinion recorded as the Supreme Court reversed and remanded the decision in a per curiam (by the court) order. The crux of this case revolved around two same-sex couples who had children through artificial insemination but were not allowed to list both parents on their child's birth certificate due to Arkansas law. The state only permitted biological parents' names on birth certificates, which excluded non-biological parents in same-sex marriages despite being legally married under Obergefell v. Hodges ruling that legalized gay marriage nationwide.