There is an interesting development that is likely to force Ohio to recognize out of state same sex marriages: Ohio recognizes out of state marriages that are illegal under Ohio law for first cousins or minors under the age of consent that were performed in another state where they were legal, but then passed a constitutional amendment barring the recognition of out of state same sex marriages.

This disparate treatment has been challenged by a gay couple. One of the partners is in hospice care, and the wanted to be recognizes as married on the death certificate once the time comes. So the chartered a medical jet to Maryland, got married on the tarmac, flew back, and filed for an injunction in federal court, ordering county officials to consider them married. They got the injunction the next day, on 14th amendment grounds, with the judge saying that it's an easy case, based on the rationale of the DOMA decision.

This is peculiar to Ohio (and perhaps other states that also recognize some, but not all out of state marriages), but at least in that state it should now be very easy to get our out of state marriage recognized. Even tough right now you'd still have to go to court, writing the petition is a cut and paste job from the decision in that case, based on Windsor.