Beginning in the 1980s, the National Gay Task Force (NGTF) began a campaign to erase sodomy statutes from American law. By the mid-1980s, however, the U.S. Supreme Court had only heard two gay rights cases, Doe v. Commonwealth's Attorney (1976) and National Gay Task Force v. Board of Education of Oklahoma City (1984), both of which were summary affirmances that did not result in written opinions. The NGTF, along with the American Civil Liberties Union (ACLU), believed that if they could get the right case in front of the court, ...

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