Courts narrow rights by re-reading precedent as limited to family, marriage, or procreation.

Evidence

The Court, however, rejected Hardwick’s portrayal of the Court’s earlier cases, insisting that they all involved a connection to “family, marriage, or procreation.” Because the situation in Bowers differed in this crucial respect from those in earlier cases, the Court concluded that those cases did not require the extension of the right to privacy to protect homosexual activity. — G. Alan Tarr, Judicial Process and Judicial…, 2539

Categorization

• XREF: Same doctrinal move in reverse of Eisenstadt’s expansion — Levi’s rule/standard being rewritten again.
• SEED: Angle: how a single phrase (‘family, marriage, or procreation’) can contract a constitutional right for decades before being overruled.