“Courts are just people. They’re just men and women dressed in black robes who have no power to re-declare, or declare, the social foundation of this nation as being unconstitutional.”

These were the words of Roy S. Moore, chief justice of the Alabama Supreme Court. Moore is a man with a proud history of defying the federal courts. A decade ago he famously refused to remove a monument representing the Ten Commandments from the state courthouse after a federal court ordered him to do so. Today he is making his stand against the growing tide of federal court decisions that have found a constitutional right to same-sex marriage.

Moore was referring specifically to the January 23rd decision of U.S. District Judge Callie V. S. Granade, which struck down Alabama’s prohibition on same-sex marriage. In making this ruling, Moore said, Judge Granade was simply wrong. “Nothing in the United States Constitution grants the federal government the authority to redefine the institution of marriage.”

In Alabama and elsewhere around the country, we are witnessing the endgame of the same-sex marriage campaign. If the Supreme Court issues a ruling in June striking down same-sex marriage bans nationwide, as it is generally expected to do, options for opponents of marriage equality are going to be severely limited. But there is still much that they can and surely will do. “This fight will continue on regardless of which way the Supreme Court rules,” said Brian S. Brown, the president of the National Organization for Marriage, which opposes same-sex marriage.

Supreme Court decisions never truly end constitutional disputes. The pending same-sex marriage decision will be no exception. What kinds of defiance will be available to opponents of same-sex marriage, even if the Supreme Court in June holds that the Constitution includes a right to same-sex marriage?

One of the most common forms of defiance of the Supreme Court is political posturing, i.e., denouncing a Court decision to score some political points. This seems to be the approach Alabama’s governor, Robert Bentley, is taking. When the Supreme Court refused to grant a stay of the district court opinion until the Court decides its own pending same-sex marriage cases, Governor Bentley attacked the Supreme Court’s “cavalier attitude toward the states.” (Here he was just echoing the words of Justice Thomas’s dissent to the refusal to grant the stay. Thomas wrote, “Today’s decision represents yet another example of this Court’s increasingly cavalier attitude toward the States.”)

There is nothing new or all that controversial about campaigning against the Court. Half a century ago, another Alabama governor, segregationist George Wallace, made opposition to the Warren Court a centerpiece of his political career—a career that included several presidential runs. The only people who win before the Supreme Court, Wallace complained on the campaign trail, were “duly and lawfully convicted criminals, communists, atheists and clients of the NAACP.” He also declared the federal courts “the greatest single threat to individual freedom and liberty in the United States today.” More recently, conservative politicians have leveraged the Supreme Court’s Roe v. Wade and Lawrence v. Texas decisions for political advantage. Liberals have sought to do the same (albeit with only limited success thus far) by campaigning against the Court’s Heller gun-rights decision or its Citizens United campaign finance decision.

A more aggressive and controversial posture of defiance is the refusal to follow federal court rulings. This is the approach Judge Moore is attempting to orchestrate in Alabama. He has simultaneously denounced the legal argument of marriage equality proponents and instructed local officials not to issue marriage licenses to gay couples. This kind of defiance might be practiced by political actors—think of George Wallace standing in the schoolhouse door. Or it may be practiced by judicial actors—in 1960, when pressed to desegregate his courtroom, Montgomery municipal court judge Walter B. Jones declared that “the XIV Amendment has no standing whatever in this Court; it is a pariah and an outcast.” This form of direct defiance, whether it be by politicians or judges, gets plenty of attention. It might accrue some short term benefits for resistance efforts. It also risks backfiring, since such open defiance offers an easy target for those who seek to mobilize support for the targeted Court opinion. Regardless of whether it achieves anything, direct defiance generally comes to a predictable end. Wallace stepped aside and the University of Alabama was desegregated; Montgomery courtrooms were eventually desegregated; and there will be gay marriage in Alabama.