Two events around 1990 marked the beginning of a new era for gay and lesbian rights movements around the world. The first was the introduction in Denmark in 1989 of a law on registered partnership that granted same-sex couples legal recognition nationally. On 1 October 1989, eleven gay couples registered their partnerships in the City Hall of Copenhagen and met the world press on the City Hall Square ‒ incidentally an old cruising ground for gay men. The second event was the application for marriage licences in Hawaii by one gay and two lesbian couples. They were rejected, but three years later the Hawaii Supreme Court ruled that it was a violation of the state's Constitution to deny marriage licences to same-sex couples.1 Not only did these two actions set the agenda for the majority of the gay and lesbian movements in Europe and the United States for the next decade, but they also signalled the two paths that the political work for gay and lesbian rights would take on each side of the Atlantic. Whereas the U.S. gay marriage lobbyists have relied on court decisions and have waged their struggle for marriage rights mostly in the judiciary, their European counterparts have strived to influence national parliaments and the European Parliament to pass laws and recommendations for the recognition of same-sex couples. Another difference between the European and U.S. experience is that some U.S. jurisdictions have moved directly to full marital rights for gay and lesbian couples, resulting in strong counter movements that in many cases have managed to obtain reverse decisions prohibiting same-sex marriages or civil unions. In Europe, the legislators in general first granted limited marital rights to samesex couples and then alleviated or abolished one limitation after the other, thus paving the road for full marital rights. In a way, the European model has proved more successful, in that it has gradually worn down the opposition to same-sex marriage, with the ironic result that the Christian Democratic parties that first opposed the laws on registered partnership have later defended them as more appropriate for same-sex couples.

For various reasons, it was the gay and lesbian movements in Scandinavia that first succeeded in introducing the idea of a legal regulation of same-sex relationships in the general political debate, but it was far from self-evident that marriage was what the gay and lesbian movements wanted.