After Lawrence v. Texas, there was from some circles. But many would assert there's a legitimate state interest tied to welfare of women and children involved in such relationships. Scalia's dissent in Lawrence (which many seem to be asserting here) cited majority morality consensus (legislating on morality, mentioning bestiality specifically as an example). But if you can't find a legitimate state interest against sexuality and civil unions other than "animus" (and Romer suggests, with the current court make-up, that would be difficult), they will eventually fall under Equal Protection. I think it's inevitable with regards to civil unions.

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