Justices Clarence Thomas and Brett Kavanaugh wrote separate concurrences.[119] Thomas argued that the Court should go further in future cases, reconsidering other past Supreme Court cases that granted rights based on substantive due process, such as Griswold v. Connecticut (the right to contraception), Obergefell v. Hodges (same-sex marriage), and Lawrence v. Texas (banned laws against sodomy).[130][3] Thomas wrote, "Because any substantive due process decision is 'demonstrably erroneous,' we have a duty to 'correct the error' established in those precedents."[131]