This week's pair of Supreme Court rulings on the Defense of Marriage Act and California's Proposition 8 were hailed as historic steps forward for LGBT Americans, but the rulings leave 37 states and 70% of Americans without marriage equality. "Living in this kind of patchwork country is becoming less and less tenable," said Susan Sommer, director of constitutional litigation at Lambda Legal. Because the court's decision in the DOMA case left certain parts of the law intact, advocates say Congress should work to repeal it. "What the Supreme Court basically did ... was put a stake in the heart of DOMA, but it didn’t kill DOMA yet," said Jo Deutsch, the federal director for Freedom to Marry. Inconsistent federal rules concerning marital benefits present a complex challenge for the Obama administration, which must begin to address the issue of legally married same-sex couples who live in states that do not recognize their unions.