"This, as a general rule, should counsel against attempts by the State, or a court, to define the meaning of the relationship or to set its boundaries absent injury to a person or abuse of an institution the law protects."This would have tied it more directly to Mill's harm edict.
Similarly, Kennedy states "The statutes do seek to control a personal relationship that, whether or not entitled to formal recognition in the law, is within the liberty of persons to choose without being punished as criminals". Again, this is a very libertarian argument. If one were to substitute the word "activity" for "relationship" would be applicable to an argument against drug use laws; why activities regarding relationships deserve different Constitutional treatment than others is not well defined, especially "absent injury to a person or abuse of an institution the law protects".
Upon reflection, my article would have been stronger had I originally included them, and as such I have added it to my article at the source. I do not believe that it impacts the central thesis, which is that this was a significant case of judicial activism, unsupported by the Constitution, that will be inevitably revisited.
Thanks for the critique.