A same-sex civil union entered into in Vermont is not a marriage under Vermont law and not a marriage under Pennsylvania law, so Pennsylvania divorce law does not apply. Corrado v. Musto, 6 Fid.Rep.3d 237, 153 Montg. 173, No. 2015-14981 (Fam.Div., 9/24/2015), app. discontinued, 3101 EDA 2015.
Note: The Superior Court has since reached the opposite conclusion, holding that Pennsylvania courts have jurisdiction to dissolve a Vermont civil union because it is the “functional equivalent” of marriage. Neyman v. Buckley, 2016 PA Super 307 (12/28/2016).