right to travel cases!
Liberty has long been part of the Supreme Court's decisions. It's simply set out in their "compelling governmental interest cases" of which there are legion, particularly since the middle 70's.
Shapiro v. Thompson (right to travel), U.S. v. Guest (right to travel), Yoder v. Wisconsin (religious liberty), Sherbert v. Verner (religious liberty). With the exception of Guest, these were all cases in which a statutory enactment burdened a liberty interest and the gummint attempted to assert a defense of a compelling governmental interest.
Lawrence clearly laid a "fundamental" liberty interest against a claim of a compelling state interest. As I said, I see nothing new. But that's because I have made the "compelling governmental interest" (compelling state interest) doctrine a long term study. I routinely see the doctrine used when a liberty or fundamental liberty is at issue.