Kramer made headlines in March 2005 when he struck down Proposition 22, a California ballot initiative defining marriage as between a man and a woman on the grounds that it denies the "basic human right to marry a person of one's choice." In his decision, he pointed out the "obvious natural and social reality that one does not have to be married in order to procreate, nor does one have to procreate in order to be married” and that "California's enactment of rights for same-sex couples belies any argument that the State would have a legitimate interest in denying marriage," concluding that "there is no rational state interest in denying them the rites of marriage as well."