Despite the lofty and expansive rhetoric of his majority opinion in Dobbs v. Jackson Women’s Health Organization, Justice Samuel Alito insisted throughout the text that the actual decision was more modest than it might appear. The end of Roe, he said, was not the end of abortion access as much as it was the beginning of a new era of democratic deliberation and decision-making. No longer shackled by a prior dictate of the Supreme Court, the people were free to choose. “It is time to heed…


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