Sorry, but I don't specifically recall Bush's criticism of a SCOTUS ruling. That doesn't mean he didn't, it means that I don't recall it.
It has to do with when and where. I don't find SCOTUS ruling criticism in the middle of SOTU appropriate. So if Bush did criticize a SCOTUS ruling during a SOTU, yes, I'd find that inappropriate for the time and place as well.
Seems that history is against me on this one, but I maintain my position. I don't believe that SCOTUS criticism is appropriate for a SOTU.