Chapter

Contrasts between the Models of Recognition and the Status of Same-Sex Partnerships in the United States and Northern Europe

in Equality for Same-Sex Couples

Published by University of Chicago Press

Published in print July 2002 | ISBN: 9780226520315
Published online March 2013 | e-ISBN: 9780226520339 | DOI: http://dx.doi.org/10.7208/chicago/9780226520339.003.0008
Contrasts between the Models of Recognition and the Status of Same-Sex Partnerships in the United States and Northern Europe

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This chapter focuses on the two main models of recognition that serve as alternatives to marriage for same-sex couples: registered partnership and domestic partnership. Whereas the Nordic states and Germany limit the applicability of their registered partnership acts to same-sex couples, the Netherlands and France offer the same framework of regulation to both same- and opposite-sex couples. Thus, opposite-sex couples in the Nordic states and Germany can choose between marriage and cohabitation. Opposite-sex couples in the Netherlands and France can choose cohabitation, registered partnership (PaCS in France), or marriage. Same-sex couples in all states but the Netherlands have two options: either cohabiting or registering a partnership. What same-sex couples have in common in these jurisdictions is that they are excluded from the institution of marriage (except, of course, for same-sex marriage in the Netherlands). Opposite-sex couples in the Netherlands and France can choose among three forms of legally regulated cohabitation, since these countries have created a third gender-neutral category for the recognition of partnerships.

Keywords: same-sex partnerships; United States; Northern Europe; registered partnership; domestic partnership; Nordic states; same-sex couples; same-sex marriage

Chapter.  10630 words. 

Subjects: Family Law

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