In early 1975, when Richard Frank Adams, a United States citizen, and Anthony Corbett Sullivan, an Australian citizen, obtained a marriage license from the Boulder, Colorado county clerk, they thought their immigration worries were over. Four days after they were married by a minister, Adams petitioned the Immigration and Naturalization Service (INS) for adjustment of Sullivan's status from that of a non-immigrant visitor to that of a permanent resident alien "immediate relative." The INS, and subsequently the Bureau of Immigration Appeals, rejected the petition, holding that the relevant portions of the Immigration and Nationality Act (INA or the Act) did not apply to gay persons. The federal courts affirmed, and Sullivan was ordered deported.
Sandra E. Lundy,
"I Do" But I Can't: Immigration Policy and Gay Domestic Relationships,
Yale L. & Pol'y Rev.
Available at: https://digitalcommons.law.yale.edu/ylpr/vol5/iss1/10