Gallagher, president of the National Organization for Marriage and a leading strategist among opponents of same-sex marriage, writes in Human Events that Calif. Atty. Gen. Jerry Brown's change of the Prop 8 ballot title to say the initiative would "eliminate" the right of same-sex marriage has a "silver lining."

That silver lining is "clarity. Only one marriage amendment has ever been defeated, and that happened in Arizona in 2006. Polls taken after the election suggest that the ballot language confused voters about whether a “yes” or a “no” vote protected marriage as one man and one woman." Her side -- the Prop 8 supporters -- had fought the initiative in court.

She also sees advantage in the "No on Prop 8" strategy of emphasizing the fact that the passage of Prop 8 could threaten the marriages of gay couples that are currently taking place. She writes: "For better or for worse, Jerry Brown’s ballot language, along with the Supreme Court decision, the highly publicized flood of same-sex unions, and even several planned celebrity same-sex unions slated for October, locks anti-Prop. 8 opponents into a messaging strategy that has never worked for them in any other state marriage amendment battle: Focus relentless attention on the same-sex couples and the rights they stand to lose. It’s a risky gamble with an uncertain payoff this November for gay marriage advocates."