Maybe the strategy of insisting that Lawrence is (really) a "sort of
fundamental rights" case is mistaken.  (Certainly libertarians will
think it is.)  Maybe it's a good idea to say that the government has to
have pretty good/really good/compelling reasons to restrict any liberty
at all (subject to the qualification that a different test should be
applied when the Constitution specifically identifies a particular
liberty -- e.g., property, free speech).  Maybe a general theory of
substantive due process, suitably confined, with respect to (mere)
liberties isn't such a bad idea.
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