“When Lisa Miller and Janet Jenkins, a lesbian couple living in Vermont, separated in 2003, a judge awarded custody of their child to Miller and visitation rights to Jenkins. That same year, Miller, the biological mother, moved to Virginia, renounced homosexuality, and adopted the evangelical Christian faith. She appealed to the supreme courts of Virginia and Vermont to revoke Jenkins’s right to see their daughter Isabella, born via artificial insemination in 2002, on the grounds that a relationship with Jenkins would hamper her new religion. The courts ruled against her, noting custody cases for same-sex couples worked like those for heterosexual couples. Miller still refused to let Jenkins see the child—so the court reversed custody to ensure Jenkins would have access to Isabella. Miller has since disappeared, along with the child.”