Page "Lawrence v. Texas" Paragraph 4

As of 1960, every state had an anti-sodomy law.

In 1961, the American Law Institute's Model Penal Code advocated repealing sodomy laws as they applied to private, adult, consensual behavior.

A few years later the American Civil Liberties Union ( ACLU ) took its first major case in opposition to these laws.

Most judges were largely unsympathetic to the substantive due process claims raised.