James Watson, a Nashville police officer, was convicted of soliciting sodomy and violating his oath of office after he made sexual proposals to 17-year-old Chase Browning while on duty. Watson argued that Georgia’s solicitation-of-sodomy statute violated free speech, privacy, and due process protections. The Georgia Supreme Court reaffirmed the statute’s narrow construction, under which it reaches only solicitation of a sexual act that is public, commercial, forcible, or involves a person legally incapable of consenting. The Court held that this construction supplied sufficient notice and did not create unconstitutional vagueness. But the State failed to prove the third element of the offense. Watson proposed private encounters, there was no evidence of money or commercial exchange, and his conduct did not establish force as Georgia defines it in sexual-offense cases. Browning was also legally capable of consenting because Georgia’s relevant age threshold was sixteen. The evidence therefore could not sustain the solicitation convictions. Because the oath-of-office counts expressly alleged that Watson violated his oath by committing solicitation of sodomy, their factual foundation disappeared with those convictions. The Court reversed all convictions and sentences.