Ross v. Goldstein, 203 S.W.3d 508 (Tex. App. – Houston [14th Dist.] 2006, no pet.).
Son, as the independent administrator of Father’s estate, brought 
		suit against Partner to recover estate assets. Partner argued that the 
		court should adopt the marriage-like relationship doctrine so that he 
		could claim the assets. Both the trial and appellate court rejected 
		Partner’s claim and refused to recognize this doctrine. Partner asserted 
		that the doctrine is an equitable remedy which is not against the public 
		policy of Texas and that it would “aid the courts in addressing the 
		growing reality of same-sex relationships.” Ross at 514. The appellate 
		court explained that it was unwilling to recognize the marriage-like 
		relationship doctrine and that “same-sex couples must address their 
		particular desires through other legal vehicles such as contracts or 
		testamentary transfers.” Id.
		
		The court examined two provisions of Texas law; first, Article 1, § 32 
		of the Texas Constitution which provides that no state or political 
		subdivision may create or recognize any legal status identical or 
		similar to marriage for same-sex partners and second, Texas Family Code 
		§ 6.204 which states that it is contrary to Texas public policy to 
		recognize or give effect to a same-sex marriage or civil union. 
		Accordingly, the court held that it lacked the power to create an 
		equitable remedy akin to marriage.
		
		Moral: Texas does not recognize the marriage-like relationship doctrine 
		and thus unmarried partners must use other legal techniques to achieve 
		their estate planning desires.