In the aftermath of the U.S. Supreme Court’s decision in Lawrence v. Texas [539 U.S. 558 (2003)] (holding that state laws criminalizing homosexual sodomy violated substantive due process), the Kansas Supreme Court reversed the conviction of Matthew Limon, who at the age of 18 had performed consensual oral sex on a boy three years younger. Matthew had been sentenced to 17 years in prison. Had Matthew performed the act on a 15-year-old girl, under Kansas law he would have been sentenced to only 15 months in prison. The author explains that Limon’s application of Lawrence is very narrowly construed, and does advance an equal protection claim, or heightened scrutiny. At best, the author argues, the Kansas Supreme Court has said that “a law punishing homosexuals fifteen times more harshly than heterosexuals for the same conduct is invalid.”