How did Antonin Scalia’s dissent in Romer v. Evans rely on Bowers v. Hardwick?

In his dissent in Romer v. Evans (1996), Justice Antonin Scalia relied on Bowers v. Hardwick (1986) to argue that the state of Colorado had a legitimate constitutional interest in preserving traditional moral values.1

Scalia maintained that because the Supreme Court had previously upheld Georgia’s antisodomy law in Bowers, it was constitutionally permissible for a state to enact laws that reflect the moral disapproval of homosexual conduct. He argued that Bowers should have served as the controlling precedent for the case, rather than the civil rights precedents cited by the majority. By referencing Bowers, Scalia sought to establish that the Colorado amendment was a reasonable effort by the electorate to uphold traditional American moral standards against political attempts to revise them, an objective he deemed unimpeachable under constitutional doctrine.1