In the previous half century the world witnessed dramatic cultural upheavals. Factions of the right and left fought many political battles pitting traditionalism against progressivism, each side arguing for its vision of a virtuous society in the changing cultural landscape. The emerging struggle in many regions of the world over legal recognition of homosexual unions is one of the latest manifestations of this conflict. It pits liberal coalitions against their socially conservative and frequently religious opponents in the latest theater of what might be called a global culture war.

In the United States, the debate over gay marriage and the methods employed in pushing for and resisting its realization were major factors in the 2004 presidential election. The issue has played a substantial role in the national political life of many other countries as well. While homosexual unions have been realized without substantial controversy in some nations, they are a topic of frequent and heated debate in many others. Few countries have fully incorporated homosexual unions into their marital laws, while a larger number have established a more limited menu of partner benefits for same-sex couples. Some countries have uniform national policies while others have differences between regional sub-states. In other countries, homosexuality is still treated as a mental illness or even as a crime.

This wide range of attitudes and policies toward homosexual partnerships reveals a great deal about social and cultural differences among regions of the world and about the conflict between tradition and modernity that shapes global politics. The persistence of the movements for partnership rights and the political forces that resist them within and across various societies demonstrate that this struggle is not one that will be resolved easily or soon. It is thus important to examine the dynamics of the conflict in different regions of the world in order to understand whether and, if so, how gay marriage is politically feasible.

Scandinavia: The Beginning

Denmark was the first country to establish a partnership law for same-sex couples. Axel and Eigil Axgil, two Danish activists, became the world’s first legally recognized gay couple in Copenhagen on October 1, 1989. Called “registered partnerships,” their enactment represented a major shift in Danish attitudes toward homosexuality and the first real victory in the struggle for the recognition of gay unions. The law was known as the “Danish Registered Partnership Act” and provided almost all of the same benefits as standard marriage, or as the law puts it “the same legal effects as the contracting of marriage.” However, there were notable differences: same-sex couples were not allowed to adopt children or to receive artificial insemination, nor could they have their commitment ceremony held in a church. Denmark has since legalized gay adoption, but several of the other differences between registered partnerships and heterosexual marriages persist.

The controversy in Denmark over church recognition of these partnerships is an interesting one, and it reveals much about the religious element of the conflict over same-sex unions. Denmark has an official state church, the Evangelical Lutheran Church, which receives support from the Danish government. The country is split into 12 dioceses, each managed by a bishop. In 1997, in response to the expressed desires of many of the church’s gay members, the bishops established a commission to study whether homosexual partnerships should receive the church’s blessing. The commission found that there are no “theological or moral objections to homosexual practice that are tenable,” and the bishops decided to allow pastors to bless unions, but did not create a standard ritual or mandate such blessings. There was substantial disagreement from conservative theologians about this decision. The Danish Church is unusual in that it is one of the few established, influential religious groups that has been even tepidly supportive of same-sex unions, a distinction shared by the Church of Norway and some other major Scandinavian churches.

Much of Scandinavia followed Denmark’s lead in the 1990s by enacting similar civil union statutes. Norway in 1993, Sweden in 1994, and Iceland in 1996 all passed laws that roughly modeled Denmark’s, granting some but not all of the same rights provided by marriage to gay couples. Greenland, which is a self-governing dependency of Denmark, held off on enacting registered partnerships until 1994. Yet despite all of the attention they have received, these countries’ partnership laws have been relatively unused. As of the year 2000, there were around 2,000 registered same-sex partners in Denmark with about 250 more couples registering per year. At the same time, Sweden and Norway had around 700 partnerships each, a very small number for countries with populations in the millions. The number of registered partnerships is clearly getting larger, however, and will continue to grow. Scandinavia’s unusually liberal population and the other distinguishing cultural factors may have contributed to its early adoption of gay partnership laws. Yet it is now clear that those were the beginning of a series of laws, debates, and court decisions that have profoundly affected politics and policies in all corners of the globe.

Greater Europe

Gay unions of one form or another have become a reality in a great number of European countries. The first country to allow full gay marriage, meaning no legal distinction between heterosexual and homosexual partners, was the Netherlands in 2001. The government had passed a registered partnership law in 1997, but the new law set forth full marriage rights for same-sex couples. The difference between marriage and partnership is often symbolic, as many registered partnership laws confer all the same rights as marriage. Sometimes, however, the differences mean more, as many countries do not allow same-sex partners to adopt children or receive other benefits reserved for marriage. That was the case in the Netherlands and is also often true in countries with federalist political systems where some regions are more accepting of same-sex partnerships than others, since marriage laws tend to be national while civil union laws are often passed by local governments in more liberal regions. This results in federal marriage rights not being accessible to partners with civil unions, as is the case in the United States.