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→O'Connor's concurrence
In reaching his opinion, Kennedy noted favorably the international trend in support of gay rights.
In reaching his opinion, Kennedy noted favorably the international trend in support of gay rights.
== [[Sandra Day O'Connor|O'Connor's]] concurrence ==
== [[Sandra Day O'Connor|Justice O'Connor's]] concurrence ==
Justice O'Connor concurred in the outcome of the case, but suggested an equal protection basis for the holding. Specifically, she sought to reconcile her concurrence in this opinion with her concurrence in ''Bowers v. Hardwick'', the case which allowed anti-sodomy laws, and which ''Lawrence'' specifically overturns.
Justice O'Connor concurred in the outcome of the case, but suggested an equal protection basis for the holding. Specifically, she sought to reconcile her concurrence in this opinion with her concurrence in ''Bowers v. Hardwick'', the case which allowed anti-sodomy laws, and which ''Lawrence'' specifically overturns.