Question Presented
               This memorandum is a revised and updated response to your prior request of October
                  20, 2008 for an opinion as to whether a Connecticut marriage certificate from a same-sex
                  marriage can be used as proof of a name change.  You also inquired as to the actual
                  date Connecticut can start legally performing same-sex marriages and issuing marriage
                  certificate to same-sex couples. Finally, you inquired as to what terms Connecticut
                  would use on a marriage certificate to refer to the parties to a same-sex marriage. A
                  Connecticut marriage certificate from a same-sex marriage may be used as proof of
                  a name change in Connecticut. Connecticut began issuing marriage certificate to same-sex
                  couples on November 12, 2008 and the first same-sex marriages took place on that date. 
                  Connecticut marriage applications and certificates contain three designations in referring
                  to each of the parties to a marriage: bride/groom/spouse. 
               
               Background
               The Connecticut Supreme Court issued a decision effective October 28, 2008, which
                  held that same-sex couples cannot be precluded from marrying under Connecticut law.
                   Kerrigan v. Commissioner of Public Health, 289 Conn. 135, 957 A.2d 407 (Conn. 2008). On November 12, 2008, the Connecticut
                  Superior Court entered a final order granting the plaintiff’s motion for summary judgment
                  and application for injunctive relief. Marriage licenses were made available to same
                  sex couples on November 21, 2008, and the first same-sex weddings took place on that
                  date. As of November 12, 2008, marriage application worksheets and certificates have
                  had three designations for each party to a marriage: bride/groom/spouse. On April
                  23, 2009, Connecticut amended its marriage laws to expressly allow for same-sex marriage,
                  defining marriage as “the legal union of two persons.” Public Act No. 09-13, section
                  3, codified as Conn. Gen. Stat. § 46b-20(4).
               
               DISCUSSION
               Connecticut permits the use of an original or certified copy of a marriage license
                  or certificate of civil union as proof of an individual’s name or name change for
                  purposes of obtaining a driver’s license. Conn. Agencies Regs. § 14-137-63(b).  Thus,
                  a name change request based upon a Connecticut marriage certificate relating to the
                  union of two individuals of the same sex should be processed under Program Operating
                  Manual System (POMS) RM 10212.035 and RM 10212.055 in the same fashion as any other name change request based upon a Connecticut marriage
                  certificate.
               
               We also note that with respect to the dissolution of a Connecticut same-sex marriage,
                  Connecticut’s statutes concerning dissolution of a marriage would apply equally to
                  opposite-sex and same-sex marriages. In Connecticut a marriage is dissolved by a decree
                  of annulment or dissolution. Conn. Gen. Stat. § 46b-40.  Under Conn. Gen. Stat. §
                  46b-63(a), at the time of entry of a decree dissolving a marriage, upon the request
                  of either party, the court shall restore a person’s birth name or former name. The
                  court may also modify a previously issued decree dissolving a marriage to restore
                  a birth name or former name. Conn. Gen. Stat § 46b-63(b).  Connecticut state agencies
                  appear to accept as proof of a name change an original or certified copy of certificate
                  of dissolution of marriage. See, e.g., Conn. Agencies Regs. § 14-137-63(b). 
               
               It should be noted that, effective October 1, 2010, all still-existing (i.e., not dissolved or annulled or previously converted to marriage) civil unions registered
                  in Connecticut were transformed into marriages by operation of law, except for such
                  instances where proceeding for dissolution, annulment or legal separation were pending
                  on October 1, 2010.  In the latter cases, such civil unions were to continue to be
                  governed by the prior law which had governed civil unions. CONN. GEN. STAT. ANN. §
                  46b-38rr.  Accordingly, dissolution of civil unions converted into marriage by operation
                  of law should be treated in the same fashion as other Connecticut same-sex marriages.
               
               CONCLUSION
               A Connecticut same-sex marriage certificate may be used as proof of a name change
                  in Connecticut. Connecticut began performing same-sex marriages and issuing marriage
                  certificate to same-sex couples as of November 12, 2008. Connecticut marriage applications
                  and certificates contain three designations in referring to the parties to a marriage: bride/groom/spouse. 
                  Finally, we note that a same-sex marriage, like an opposite-sex marriage, is dissolved
                  in Connecticut by a court decree of dissolution or annulment of the marriage, and
                  a marriage dissolution decree may also be used as proof of a name change.