It also prohibited oral sex and anal sex between heterosexual partners. In 1971, the Florida Supreme Court, ruling in Franklin v. State, struck down the 'crime against nature' statute as unconstitutionally vague. The court retained the state's prohibition on sodomy by ruling that anal and oral sex could still be prosecuted under the lesser charge of 'lewd and lascivious' conduct. Florida further enacted a 'psychopathic offender law' in 1955, under which those convicted of sodomy (labelled as 'criminal sexual psychopathic persons') would be periodically examined to determine if they had 'improved to a degree that will not be a menace to others'. In 1960, the state Attorney General issued an opinion that Florida's sodomy statute did not apply to Indian reservations. The opinion stated that crimes committed between Native Americans or between Native Americans and non-Native Americans were a matter for tribal courts.
