Federalism and same-sex marriage have worked together to promote change in the United States, particularly through the Windsor case. By removing a key provision in the Defense of Marriage Act, federalism has allowed states to push the federal government towards recognizing marriage equality. This interaction between rights and structure has facilitated the legal recognition of same-sex marriage and advanced the constitutional project of integration. Heather Gerken's analysis emphasizes the diverse forms of federalism at play in this process, highlighting the complex and dynamic nature of federalism in shaping social change.