The insignificance of Miller-Jenkins

This article on Findlaw, titled "The Virginia Supreme Court Enforces Vermont's Custody and Visitation Order Regarding a Same-Sex Couple's Child: Why an Anti-Same-Sex-Marriage State Recognized a Same-Sex Union For This Purpose", points out that the recent Supreme Court case was decided on technical grounds, and even so came with a warning from the Chief Justice in his separate opinion that might be a preview of how he (if not others) would decide future cases on the merits.