In May of 1999, Johnson, who was then a couple of weeks away from graduating law school, married his wife, Kelly, a schoolteacher whom he met at a wedding. Almost two years later, a photo of the smiling couple ran with an Associated Press story, under the headline “Can states successfully legislate marital bliss?”

The story explained that Mike and Kelly had entered a “covenant marriage.” This meant that, prior to marrying, they had to undergo premarital counseling and sign a binding contract agreeing that they would divorce only in the case of abuse, abandonment, imprisonment of a spouse, or lengthy separation. A covenant couple, no matter how miserable, cannot simply decide to divorce.