Less Likely to Succeed: Challenges based on Obergefell are less likely to succeed in incestuous marriages. The primary justification for prohibiting these unions revolves around health risks associated with inbreeding and moral concerns, as seen in cases like In re Marriage of R. & M., which upheld state laws against incestuous relationships. Moreover, the social stigmas attached to incestuous unions create a more formidable barrier than those for consensual adult polygamous arrangements. find the" In re Marriage of R. & M., " citing