The constitution does not give six unelected old f##ts the power to tell the states what they can and cannot make private. As a federal constitutional power, it does not exist. Thus, as a federal constitutional right, it was entirely manufactured out of, dare I say, wholecloth.
Do you have any doubt but that the founding fathers thought state sodomy laws were constitutional and based on sound policy? Or that the post-civil-war congress (who passed the 14th amendment) also felt the same way. If so, why did both groups write a constitution that banned state sodomy laws? The answer (of course) is, they did not and no reasonable person can argue otherwise, without being willfully blind to the constitution and the historic record.
It took 230 years for six old f##ts to make-up the right of Sodomy (or the right of "privacy" for the squeamish who need nice euphemisms). "Manufactured right" is a reasonable synonym for this entirely made up right.
And that's why the term "manufactured" right is repeated over-and-over. And that's why, for that use, the term is quite precise.