As for the U.S. Armed Forces, the Court of Appeals for the Armed Forces has ruled that the "Lawrence v. Texas" decision applies to Article 125, severely narrowing the previous ban on sodomy. In both "United States v. Stirewalt" and "United States v. Marcum", the court ruled that the "conduct sodomy falls within the liberty interest identified by the Supreme Court," but went on to say that despite the application of "Lawrence" to the military, Article 125 can still be upheld in cases where there are "factors unique to the military environment" that would place the conduct "outside any protected liberty interest recognized in "Lawrence"." Examples of such factors include rape, fraternization, public sexual behavior, or any other factors that would adversely affect good order and discipline. Convictions for consensual sodomy have been overturned in military courts under "Lawrence" in both "United States v. Meno" and "United States v. Bullock".