As recently as 1986, the Supreme Court took an overtly hostile stance toward homosexuality. In Bowers v. Hardwick, the Court ruled that state "morals legislation"—including anti-sodomy laws, which criminalize gay sex—were constitutional. In defending the power of states to pass laws that criminalized homosexual acts, Justice Warren Burger noted that "condemnation of [homosexual activity] is firmly rooted in Judeo-Christian moral and ethical standards." And he even cited (rather provocatively) the eighteenth-century legal scholar, William Blackstone, in support of his twentieth-century conclusion. "Blackstone described 'the infamous crime against nature' as an offense of 'deeper malignity' than rape, a heinous act 'the very mention of which is a disgrace to human nature,' and 'a crime not fit to be named.'"blank" href="https://www.shmoop.com/equal-protection/same-sex-marriage.html">Same-Sex Marriage & the 14th Amendment."