Page:NCGLE v Minister of Justice.djvu/54

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Ackermann J

[54]Bowers v Hardwick has been the subject of sustained criticism.[1] It is interesting to note that in the recent case of Romer v Evans,[2] the United States Supreme Court has, without referring to its decision in Bowers v Hardwick, struck down an amendment to the Colorado State Constitution which prohibited public measures designed to protect persons based on their sexual orientation.


  1. See, for example, Tribe American Constitutional Law 2ed 1428 and T Grey “Bowers v Hardwick Diminished” (1997) 68 University of Colorado Law Review 373.
  2. 134 L Ed 2d 855 (1996).
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