How did Justice Byron White define the main legal issue in Bowers v. Hardwick?

In the case of Bowers v. Hardwick (1986), Justice Byron R. White narrowly defined the central legal issue as "whether the Federal Constitution confers a fundamental right upon homosexuals to engage in sodomy."1

By framing the question in this specific manner, Justice White rejected the broader interpretation—supported by the 11th Circuit and the dissenting justices—that the case concerned a fundamental right to privacy or an individual's interest in controlling the nature of their intimate associations. Because he concluded that no such fundamental right to engage in homosexual sodomy existed, he determined that the Georgia antisodomy statute did not require strict scrutiny. Instead, he applied the "rational basis" test, ultimately holding that the law was constitutional because it was rationally related to the state's interest in upholding the moral beliefs of its electorate.1