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Oral sex has long had a special criminal status in Georgia law; until 1998, oral sex even between husband and wife was punishable with up to 20 years in prison. The United States Supreme Court, in 1986, originally upheld Georgia's anti-sodomy law (which covered both oral sex and anal sex) as constitutional even when applied to criminalize two consenting adults in the privacy of their bedroom ("Bowers v. Hardwick", 478 U.S. 176). Twelve years later, Georgia's Supreme Court would, however, find that the same law upheld by the U.S. Supreme Court was unconstitutional on state constitutional grounds, at least as applied to oral sex with persons over the age of consent ("Powell v. Georgia", S98A0755, 270 Ga. 327, 510 S.E. 2d 18 (1998)).