In the leaked draft opinion on Dobbs v. Jackson Women’s Health Organization, Justice Samuel Alito writes that Roe v. Wade (1973) and Planned Parenthood v. Casey (1992) "must be overruled" because a right to abortion is not "implicitly protected by any constitutional provision, including [...] the Due Process Clause of the Fourteenth Amendment", which only guarantees rights unmentioned in the Constitution that are "deeply rooted in this Nation’s history and tradition” – a phrase from Washington v. Glucksberg (1997). But that ruling referred explicitly to both Roe and Casey when discussing that expression, so the logic seems circular here: overturning Roe with the support of a case whose decision depended on Roe. (Andrew Shields, #111words, 8 May 2022)
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