In light of the United States Supreme Court's decision in United States v. Windsor, holding Section 3 of the Defense of Marriage Act (DOMA) unconstitutional, the Department of Labor (DOL) has issued a Notice of Proposed Rulemaking seeking to change the definition of "spouse" under the Family and Medical Leave Act (FMLA).  The proposed definition will include individuals, including same-sex and common law couples, who enter into marriage in a state that recognizes their marriage as valid.  It also includes same-sex marriages entered into in another country that could have been entered into in at least one state.  The Notice of Proposed Rulemaking was published in the Federal Register on June 23, and comments may be submitted until August 11.