[Torie]

I guess looking at the exact language would be useful. But assuming SCOTUS did not explicitly say, that Kansas was to review its decision in light of its overturning of Bowers, but rather in light of its decision in Lawrence, I can't imagine personally just what there is in the soaring prose of Lawrence other than its interment of Bowers, that would be applicable to statutory rape.

[AntiGuv]

I am in full agreement with your post #347 and moreover you've elsewhere persuaded me that the outcome of Limon is hardly as assured as I'd previously assumed. I do think the reversal of Bowers is the singular reason for the remand [this much was evident all along], but I'm far less certain that the Court will ultimately overrule the Kansas ruling, whatever that might be - so long as it argues on grounds other than the defunct Bowers precedent.