Christie Lee Littleton
Encyclopedia
Littleton v. Prange is a 1999 lawsuit that annulled the marriage between a man and a transexual woman. The precedent may result in some Texas marriages being annulled where one of the partners is transsexual.
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. 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.
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."
The decision made it legal for a woman to marry a man who had undergone sex reassignment surgery and transitioned to female.
Background
Christie Lee Littleton was assigned maleSex assignment
Sex assignment refers to the assigning of the biological sex at the birth of a baby. In the majority of births, a relative, midwife, or physician inspects the genitalia when the baby is delivered, sees ordinary male or female genitalia, and declares, "it's a girl" or "it's a boy" without the...
at birth, in San Antonio, Texas
San Antonio, Texas
San Antonio is the seventh-largest city in the United States of America and the second-largest city within the state of Texas, with a population of 1.33 million. Located in the American Southwest and the south–central part of Texas, the city serves as the seat of Bexar County. In 2011,...
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
Sex reassignment surgery
Sex reassignment surgery is a term for the surgical procedures by which a person's physical appearance and function of their existing sexual characteristics are altered to resemble...
and had her state-issued identification changed to female. 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.
Case
After her husband's death, Christie Lee Littleton brought a medical malpractice suit against her husband's doctor, Mark Prange. The defense attorney argued that the marriage was invalid because Christie Lee Littleton was a biological male. On appeal, Chief Justice Phil HardbergerPhil Hardberger
Phil Hardberger is a former mayor of San Antonio, Texas. He took office in June 2005. He is a Democrat; however, as with all mayoral, city council, and school board positions in Texas, Hardberger was elected on a non-partisan ballot....
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."
The decision made it legal for a woman to marry a man who had undergone sex reassignment surgery and transitioned to female.
External links
- Opinion by Chief Justice Phil Hardberger, Concurring Opinion by Justice Karen Angelini, Dissenting Opinion by Justice Alma López at the Texas Fourth Court of Appeals website
- Court opinion at Google Scholar
- Story of Christie Lee Littleton, personal website