On February 13, 2014, in Bostic v. Rainey, Judge Arenda L. Wright Allen of the U.S. District Court for the Eastern District of Virginia ruled that any Virginia laws banning same-sex marriage or prohibiting recognition of same-sex marriages – including Article I, Section 15-A of the Virginia Constitution and Sections 20-45.2 and 20-45.3 of the Virginia Code – are unconstitutional under the Due Process and Equal Protection Clauses of the Fourteenth Amendment. If upheld, the ruling, in conjunction with the Supreme Court’s decision in Windsor v. United States, means that Virginia employees who choose to marry a person of the same sex would now have the benefit of spousal status under both state and federal law for the purposes of medical plan coverage, 401(k) and retirement plans, and entitlement to leave under the Family and Medical Leave Act (FMLA).