In re Gardiner was similar to the Texas ruling in that an appeals court invalidated a marriage after the husband had died. The man, Marshall Gardiner, died without a will in 1999. The widow, J'Noel Gardiner (born Jay Ball), sought to split the $2.5 million estate with her late husband's son by a previous marriage. The son countered that his stepmother had no spousal rights, given her sex at birth, and the Kansas Supreme Court agreed.