http://www.slate.com/articles/news_and_politics/the_breakfast_table/features/2015/scotus_roundup/supreme_court_2015_obergefell_v_hodges_links_liberty_and_equality.html

Justice Anthony Kennedy’s majority opinion echoes the opinion in Loving v. Virginia (1967), in that it recognizes both the liberty and the equality claims made by the plaintiffs. In Loving, the court recognized that the 14^th Amendment’s Equal Protection Clause and the Due Process Clause both required the states to recognize marriages between interracial couples. Unlike Loving, however, which largely treats the equality and liberty claims as parallel and independent claims, Obergefell treats them as intertwined. In a self-conscious reinforcement of Lawrence v. Texas (which struck down sodomy statutes in 2003), Obergefell recognizes the connection between liberty and equality (“In Lawrence the Court acknowledged the interlocking nature of these constitutional safeguards in the legal treatment of gays and lesbians. ... This dynamic also applies to same-sex marriage”). Only future cases will show the full measure of what the recognition of this intersection, which Laurence Tribe and others (including me) have noted, will portend.