Editing Griswold v. Connecticut (section)

===Right to privacy in private sexual activity, 2003===
''[[Lawrence v. Texas]]'' (2003) struck down a Texas sodomy law that prohibited certain forms of intimate sexual contact between members of the same sex. Without stating a standard of review in the majority opinion, the court overruled ''[[Bowers v. Hardwick]]'' (1986), declaring that the "Texas statute furthers no legitimate state interest which can justify its intrusion into the personal and private life of the individual." [[Sandra Day O'Connor|Justice O'Connor]], who wrote a concurring opinion, framed it as an issue of [[rational basis]] review. [[Justice Kennedy]]'s majority opinion, based on the liberty interest protected by the [[due process clause]] of the [[Fourteenth Amendment to the United States Constitution|Fourteenth Amendment]], stated that the Texas anti-sodomy statute touched "upon the most private human conduct, sexual behavior, and in the most private of places, the home", and attempted to "control a personal relationship that ... is within the liberty of persons to choose without being punished". Thus, the Court held that adults are entitled to participate in private, consensual sexual conduct. While the opinion in ''Lawrence'' was framed in terms of the right to liberty, Kennedy described the "right to privacy" found in ''Griswold'' as the "most pertinent beginning point" in the evolution of the concepts embodied in ''Lawrence.''<ref>{{ussc|name=Lawrence v. Texas|volume=539|page=558|pin=|year=2003}}.</ref>