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In 1987, the District Court determined that laws that treat homosexuals as a class must be reviewed under the federal courts' heightened scrutiny standard because homosexuals are a "quasi-suspect class", noting that Bowers v. Hardwick held that only that "under the due process clause lesbians and gay men have no fundamental right to engage in sodomy".
The U.S. Supreme Court in Lawrence had stated that it was adopting the reasoning of Justice John Paul Stevens in his dissent to Bowers v. Hardwick, which Lawrence overruled.
Before the Pilots even played their first game in 1969, Seattle radio disc jockey Robert E. Lee "Bob" Hardwick looked over the list of players drafted by the Pilots, discovered Oyler's batting average and created the "Ray Oyler Fan Club," initially as a radio bit on his radio show.
On April 29, 1919, as a direct result of his sponsorship of the Immigration Act, Senator Hardwick was targeted for assassination by adherents of the radical anarchist Luigi Galleani, who mailed a booby trap bomb to his residence in Georgia.