Christie Lee Van De Putte, a transgender woman considered by many to be a pioneer after she challenged a Texas court ruling which invalidated her marriage to her late husband, died on March 15. She was 51, and a cause of death was not announced.
Van Putte was born March 29, 1962, and was a lifelong resident of San Antonio, Texas. She was a hairstylist, and owned and operated a beauty salon in San Antonio for more than 20 years, according to her website. Van Putte is survived by her siblings Silvia Lira, Estella Nockroes, Mary Lou Carr and Andrew Cavazos, and was preceded in death by her second husband, Pierre Van De Putte.
Van De Putte made history as the plaintiff in the 1999 case Littleton v. Prange, a wrongful death lawsuit filed against the doctor who had treated Van De Putte's then-husband of seven years, Mark Littleton. Although Van De Putte filed the suit — which resulted in a reported $2 million settlement — several Texas courts determined that Van De Putte was not eligible for survivor benefits, agreeing with a district judge who claimed that the widow had male chromosomes and was "male" at the time of her marriage to Littleton, despite the fact that she had undergone gender-confirming surgery more than 10 years earlier, and was recognized as female by the state of Texas. Regardless, the courts declared that Van De Putte's marriage to Littleton technically constituted a same-sex marriage, which was illegal in the state and therefore invalidated her rights as Littleton's surviving spouse, according to trans blogger and activist Monica Roberts. Subsequent appeals all the way to the U.S. Supreme Court either upheld the initial ruling, or declined to review the case. The decision in Littleton v. Prange set a troubling precedent that essentially declared the legality of marriage should be determined by the chromosomal makeup of the parties, not by the actual or legal gender of those involved. In a 2001 case also involving surviving spouse benefits issued to a transgender widow, a Kansas appeals court rejected the conclusions made in the Littleton case, arguing that the Texas court's understanding of Van De Putte's gender was "a rigid and simplistic approach to issues that are far more complex than addressed in that opinion."
In February, a Texas appeals court ruled in favor of a transgender woman Nikki Araguz, whose late husband Thomas died in the line of duty as a firefighter. After control of her husband's estate was awarded to Araguz, her late husband's mother and sister filed a lawsuit, contending that the couple's marriage was illegal under Texas law, since it constituted a same-sex marriage, even though Araguz was legally recognized as female when she married.
Where the outcome of Van De Putte's case in Littleton set a troubling precedent, the newest ruling could ultimately overturn that precedent, since the court determined that Texas law does allow a person who has physically and legally transitioned to enter into a legally binding marriage with someone of the opposite sex.
Upon hearing the news of Van De Putte's death, Araguz shared a message with Roberts at TransGriot. "Rest In Peace Christie Lee Littleton Van De Putte," Araguz said. "I hope you knew your case had been overturned and I will always remember you, as our lives are forever intermingled in history."
Numerous obituaries of Van De Putte commend her warm, kind demeanor. Funeral services were held March 25 at Holy Family Catholic Church in San Antonio, and she is buried at Fort Sam Houston National Cemetery. The San Antonio Gender Association is planning a vigil for Van De Putte, reports Q San Antonio, but details have yet to be announced.