Powell v. State
[1][2] While the plaintiff in Powell had been engaged in heterosexual sex, the overturning of the anti sodomy law also decriminalized same-sex sexual activity within the state of Georgia.Anthony Powell was charged with a complaint in which he had performed non-consensual oral sex upon his wife's 17-year-old niece in his house.In Bowers, the Attorney General of Georgia had conceded that the sodomy law could not be applied to married heterosexuals, given the U.S. Supreme Court's ruling in Griswold v. Connecticut.[2] The majority noted that "privacy rights protected by the U.S. Constitution are not at issue in this case," while the dissenting justice cited Bowers extensively.Sodomy laws were overturned nationwide five years later, when Lawrence v. Texas (2003) overruled Bowers v. Hardwick.