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I added the following to the article:

In February 2014, when a ruling by Allen overturned Virginia's ban on same-sex marriage, she wrote in her ruling, "Our Constitution declares that ‘all men’ are created equal." ^[1] Conservatives pointed out that those words were actually from the Declaration of Independence, not the Constitution. ^[2]

72.77.61.208 ( talk) 21:42, 14 February 2014 (UTC) reply

Given the historic nature of her ruling, I don't know how it could possibly be left out of her biography. Her error is noteworthy, but isn't the lead. John2510 ( talk) 16:32, 17 February 2014 (UTC) reply