Doe v. Commonwealth's Attorney for Richmond

How later courts describe this case

• upholding statute as applied to homosexual acts between two consenting adults in private places
• permitting a homosexual to proceed under a pseudonym in challenging state sodomy law
• constitutionality of Virginia sodomy law upheld in declaratory judgment action against due process, freedom of expression, and privacy attacks
• three-judge district court decision holding the state of Virginia could constitutionally apply its sodomy statute to private sexual conduct between consenting male adults
• summarily affirming three judge federal district court decision dismissing challenge by male homosexuals to statute forbidding sodomy
• with two justices favoring a postponement of consideration of jurisdiction on the merits
• “we must view disciplinary proceedings as judicial rather than administrative in nature”
• discussed in Tribe at 941-43, & 1979 Supp. at 87