First, the Court stated that its decision in "Bowers" went against its statements in cases involving child-rearing ("Pierce v. Society of Sisters" and "Meyer v. Nebraska"), contraception ("Griswold v. Connecticut" and "Eisenstadt v. Baird", and abortion ("Roe v. Wade") that the Constitution protects a right to privacy and personal autonomy. Next, Kennedy wrote that in "Bowers" the Court had misread the historical record regarding laws criminalizing homosexual relations. He stated that, after further research, the Court had found that historical American anti-sodomy laws had been directed at "nonprocreative sexual activity more generally," rather than specifically at homosexual acts, contrary to the Court's conclusions in "Bowers". Combined with the fact that these laws were often unenforced, the Court saw this as constituting a tradition of avoiding interference with private sexual activity between consenting adults.