In May 2001, Minnesota courts struck down the state's sodomy law which had been on the books since the 1800s. The law prohibiting oral and anal sex allowed for penalties of up to a year in jail and up to $3,000 in fines.

In 1841, Alabama adopted a new code. In doing so, the first sodomy law was created in Alabama. Using the common-law definition, the penalty was set to 2-10 years in jail.