In Lawrence v.Texas, the defendant argued that his conviction for sodomy should be reversed on the grounds:

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Lawrence argued that the Texas statute which criminalized consensual homosexual sodomy violated his substantive due process rights to engage in private intimate conduct without government intrusion. The Supreme Court agreed, holding that the law was an unconstitutional infringement on the liberty of adults to engage in private intimate conduct. Lawrence argued that the Texas law violated his right to privacy and autonomy in his own home, which is protected under the Due Process Clause of the Fourteenth Amendment. The Supreme Court ultimately agreed, ruling that intimate consensual sexual conduct is part of the liberty protected by the substantive due process clause.

In Lawrence V