Although there have been around three dozen federal court victories in the past year for marriage equality, there have been only three at the appellate level. Last week's Virginia win may have the most significant reverberations.

Three states have been waiting for this ruling: North Carolina, South Carolina, and West Virginia all lie within the Fourth Circuit. And all three states had lawsuits on hold while judges waited for the Fourth Circuit Court of Appeals to rule.

Now that it has, litigation can resume. In North Carolina, for example, the court has requested updated briefs from all parties by next week. The Fourth Circuit's ruling provides a clear path toward victories in all three states that overturn marriage bans as unconstitutional.

From there it's possible that all three states could attempt to bypass a rehearing and petition directly to the U.S. Supreme Court. That means that within a few weeks, four of the five states in that circuit could have pending cases before the highest court in the land.

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