 In "Lofton v. Secretary of the Department of Children & Family Services", 358 F.3d 804 (11th Cir.2004), the United States Court of Appeals for the Eleventh Circuit explicitly held that "Lawrence" did not apply strict scrutiny.However, in 2008, the California Supreme Court adopted the strict scrutiny standard for state laws that discriminate on the basis of sexual orientation in the case "In re Marriage Cases".