Homosexuality and the Constitution: A Legal Analysis of the Supreme Court Ruling in Lawrence v. Texas

 At the time of the Lawrence decision, twelve other states, in addition to Texas, had anti-sodomy laws on their books. However, of the thirteen states with anti-sodomy laws, only four states, including Texas, had laws that criminalized sodomy between same-sex couples but not between heterosexual partners.

https://www.everycrsreport.com/reports/RL31681.html#:~:text=At%20the%20time%20of%20the,but%20not%20between%20heterosexual%20partners.