The Missing Word in Lawrence v. Texas

13 Pages Posted: 16 Mar 2013

Date Written: March 13, 2004


There are many satisfying words in Lawrence v. Texas. Equality and Liberty. Privacy and History. Even a few references to “Lesbian.” What could be missing? An apology. Something like “sorry” or a mention of “remorse.”

The Court stated that, “Bowers was not correct when it was decided, and it is not correct today. It ought not to remain binding precedent. Bowers v. Hardwick should be and now is overruled.” For some, this may have read as an apology. It may be an admittance of error, but it was not the apology that sexual minorities deserve. We deserve an apology for the seventeen years of grief, pain, and death caused by Bowers v. Hardwick, which the Court now admits has always been wrong.

Suggested Citation

Robson, Ruthann, The Missing Word in Lawrence v. Texas (March 13, 2004). Cardozo Women's Law Journal, Vol. 10, 2004, Available at SSRN:

Ruthann Robson (Contact Author)

CUNY School of Law ( email )

2 Court Square
Long Island City, NY 11101
United States

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