Michigan Law Review
On the night of September 17, 1998, someone called the police to report that a man was going crazy with a gun inside a Houston apartment. When Harris County sheriff's deputies entered the apartment they found no person with a gun but did witness John Lawrence and Tyron Garner having anal sex. This violated the Texas Homosexual Conduct law,3 and the deputies hauled them off to jail for the night. Lawyers took the men's case to the Supreme Court and won a huge victory for gay rights.
Dale Carpenter, The Unknown Past of Lawrence v. Texas, 102 Mich. L. Rev. 1464 (2004), available at http://scholarship.law.umn.edu/faculty_articles/143.