This article suggests that Justice Blackmun's contribution to the jurisprudence of sexual orientation lies in his integration of ideas of liberty and equality. Just as the requirement that laws be applied equally can serve to cabin their infringement on autonomy, so too the recognition of fundamental liberty interests can provide a stronger foundation for recognizing claims of equality.
Pamela S. Karlan,
Some Thoughts on Autonomy and Equality in Relation to Justice Blackmun,
26 Hastings Const. L.Q. 59
Available at: https://repository.uchastings.edu/hastings_constitutional_law_quaterly/vol26/iss1/5