Justice Antonin Scalia wrote a dissent, which Chief Justice William H. Rehnquist and Justice Clarence Thomas joined. Scalia objected to the Court's decision to revisit "Bowers", pointing out many decisions from lower courts that relied on "Bowers" that might now need to be reconsidered. He noted that the same rationale used to overturn "Bowers" could have been used to overturn "Roe v. Wade", which some of the Justices in the majority in "Lawrence" had upheld in "Planned Parenthood v. Casey" (1992). Scalia also criticized the majority opinion for failing to give the same respect to "stare decisis" that three of those in the majority had insisted on in "Casey". O'Connor's concurrence noted that Scalia's dissent conceded that if cases such as "Romer v. Evans" "have "stare decisis" effect, Texas' sodomy law would not pass scrutiny under the Equal Protection Clause, regardless of the type of rational basis review" applied.