Glorfindel of Gondolin

Here's a simple test for ranking the federal circuit courts of appeal according to how liberal or conservative they are:

Step 1: Shepardize Lawrence v. Texas, 539 U.S. 558 (2003) on Lexis. Or use Westlaw if you prefer Pepsi.

Step 2: Count how many times each circuit follows Lawrence. Count how many times each circuit distinguishes Lawrence.

The most liberal circuit is the one that follows Lawrence the most. That'd be the Ninth Circuit, following Lawrence twice and distinguishing Lawrence once. The most conservative circuit is the Fourth, distinguishing Lawrence three times and not ever following it.

I know, I know; you're going to say that it's silly to draw any conclusions from such a small number of cases, and that the value of my little test depends completely on what you mean by "liberal" and "conservative." To which I say, no test is perfect -- but at least mine is simple.