Caveat:  the title is a misnomer.

The June ruling by the United States Supreme Court holding unconstitutional state bans on same sex marriage created another validation:  same sex divorce.

Thirty-seven states and the District of Columbia recognized same sex marriage prior to the Supreme Court decision.  Same sex couples validly married in those states sometimes moved to states which did not recognize or even specifically outlawed same sex unions.  In those states they lived in legal limbo.  The state of residence would not recognize the marriage, and neither would the state accept US Constitutional responsibility to give legal effect to a marriage contracted under the laws of another state.

The validity of same sex marriage – marriage in every legal sense of the word – is now established under the US Constitution.  The frontier may be all the follow on issues.  The first and most prominent is same sex divorce.

The first issue, but perhaps already resolved:  even those legal subdivisions (usually counties) that still refuse to issue marriage licenses appear willing to dissolve marriages legally performed under the laws of another state.  The sound and the fury surrounding same sex marriage vanishes when the request is for a same sex divorce.

Freedom to Marry, a LGBT lobbying organization, tracks those jurisdictions that do not grant same sex marriage licenses.  Apparently with same same sex divorce, there will be no residual refusal jurisdictions to track.  One study shows that the rate of same sex divorce may be about the same as the rate for oppose-sex marriages, although the amount of data is obviously not the same.

Regarding the caveat:  this does not seem to be a frontier.  These are cases of marriage validly done under the laws of another state, dissolved under the laws of a recently-recognizing state.  If every state must grant same-sex marriages equal status with all marriages, then it seems to follow that the rules, statutes, procedures and results of divorce must apply as well.

Is there a frontier?  Yes, but I suggest these are the frontier areas:  same sex “common law” marriages; the precise applicability of opposite-sex precedent to same sex cases; community property rules (in states where applicable); conflict of law questions; and rules of heirship.