In the light of the U.S. Supreme Court’s decision in United States v. Windsor, finding Section 3 of the Defense of Marriage Act (DOMA) unconstitutional, the Board of Immigration Appeals (BIA) has held that Immigration must recognize same sex marriages for purposes of permanent residency sponsorship and other benefits under the immigration laws.  The BIA ruled that DOMA is no longer an impediment to the recognition of lawful same-sex marriages and spouses under the Immigration and Nationality Act if the marriage is valid under the laws of the State where it was celebrated. See Matter of Zeleniak, 26 I&N Dec. 158 (BIA 2013)