id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cjgl-2521	Garland, James Allon	Sex As A Form of Gender and Expression After Lawrence v. Texas	2006	29	.pdf	application/pdf	14290	567	55	This not only suggests a sophisticated awareness in the Lawrence majority's reluctance to define the meaning of relationships; it also precludes a simple preview of First Amendment claims for any particular message attached to sex, except to note that if the Lawrence dissenters are correct-that most laws against sex are sustainable only in light of [Hardwick's] validation of laws based on moral choices' virtually any First Amendment claim for private sex that passes the Spence test should prevail, as morality is not a basis for regulation of private sexual expression.l 2 Under Spence, of course, it is irrelevant that some individuals, including judges, may not be able to conceptualize or understand expression in sex, as the intent of those who engage in sex to express a feeling or idea should be evaluated in light of the understanding of those likely to view that expression, not a court or the general public. [Vol. 15:1 Sex as a Form of Gender and Expression Amendment claim for private sex when governments make further attacks on sexual, expressive, and associational interests.	cache/cjgl-2521.pdf	txt/cjgl-2521.txt