This specific case has some earmarks of an intentional judicial probe; however, because it did not stem from New York State, I doubt it.    The gay Marriage case which will eventually end up at the Supreme Court will, more than likely, stem from a divorce in New York, not California or other.
All gay marriage states have a clause extending the legal binding construct of recognition only within the state of origination.    However, New York constructed their specific state legalization of gay marriage with a binding reciprocity clause essentially demanding all other 49 state courts to recognize their marriages.   
The federal challenge, which gay marriage advocates are thirsting for, will come from one of these “reciprocity” cases where the federal government will have to step in and define legality across state lines – ergo basically define federal marriage.
I do find it puzzling however, that you can drive to California and get married without being a resident, but if you want a divorce you MUST be a resident.   Odd, no?
HERNANDO, Miss. (AP) — Lauren Beth Czekala-Chatham wants to force Mississippi, one of the America’s most conservative states, to recognize her same-sex marriage. She hopes to do so by getting a divorce.
She and Dana Ann Melancon traveled from Mississippi to San Francisco to get married in 2008.
The wedding was all Czekala-Chatham hoped it would be, the Golden Gate Bridge in the background, dreams for a promising future. She wrote the vows herself. (more…)