It was the possibility of a legal challenge in state court that made traditional marriage advocates cite a need for a state constitutional amendment. That amendment was in addition to state law that also bans same-sex unions.

The Utah law may not even be tested, since opponents are working to get an amendment to California's constitution on the November ballot. Also, the Alliance Defense Fund, which opposes legalized gay marriage, said that it would ask the court for a stay on their ruling until after a statewide vote on the amendment.

While Massachusetts was actually the first state to have a gay marriage ban overturned, the California ruling is likely to have a greater national impact. Unlike Massachusetts, there is no residency requirement for marriage, so it will be up to individual states to determine whether they will recognize the marriages.

If the state does start performing gay marriages, Monte Stewart, president of the Orem-based Marriage Law Foundation, said a legal challenge in Utah may not be far behind.

"There will now be a flood of recognition cases all across the country," he said. "We would not be surprised to see Utah getting a recognition case or two."

But Stewart isn't worried, because he says the law is clear: "A state does not need to recognize a marriage by a same-sex couple in another state."

Shurtleff says any challenge to Utah's marriage policy will have to come in federal court, and those challenges have already been brought up in other states, as couples wed in Massachusetts have sought recognition of their relationships elsewhere.

"It's well on its way in other jurisdictions," Shurtleff said. "You're now getting these different decisions in different states. That's when the (U.S.) Supreme Court needs to step up and say, 'we've got to decide this.'"

The cases are based on the same constitutional "full faith and credit" provision that requires states to recognize each other's driver licenses.

Sen. Scott McCoy, D-Salt Lake, says he'd like to see marriage equality but doesn't see it coming through a court challenge. McCoy directed the campaign against Amendment 3, the gay marriage ban, in 2004.

"That has never been used in the 200 years-plus that we've had our Constitution to force one state to recognize a marriage from another state," he said. "Utah has clearly stated, and I think wrongly stated, that marriage is between a man and woman and won't recognize a marriage from another state."

McCoy does, however, see a bright side for the nation as a whole. California, the nation's largest state, has influential clout on other states.