 Courts have been reluctant to apply intermediate scrutiny to cases centered around sexual orientation.For instance, in "Romer v. Evans" 517 US 620 (1996), which struck down an amendment to the Colorado Constitution that invalidated legal protections based on sexual orientation, the United States Supreme Court held that the amendment violated the Equal Protection Clause because the amendment was motivated by a bare desire to harm a politically unpopular group, which is never a legitimate governmental interest.In "Lawrence v. Texas", 539 U.S. 558 (2003), the U.S. Supreme Court struck down anti-sodomy laws as unconstitutional, explicitly overturning its earlier "Bowers v. Hardwick", 478 U.S. 186 (1986) decision, but did not specify the level of scrutiny it applied.