ABSTRACT
Clause, both to reaffirm Roe and to invent an entirely new standard to govern the constitutionality of abortion restrictions. The application of what the Court titled “Griswold-liberty” ushered in an era of unprecedented raw judicial power in which the Court’s “reasoned judgment” was employed to define “the liberty of all” and to self-servingly rely on the doctrine of stare decisis to, ironically, overrule a portion of Roe.2 As a result, the Court’s decision in Planned Parenthood weakened the liberty of all citizens by undermining their voice in the democratic process and infringing on citizens’ right to determine for themselves, through the democratic process, what right “liberty” ought to encompass.
