By Reagan Keener Introduction On June 24, 2022, the Supreme Court in Dobbs v. Jackson Women’s Health Organization declared that the Constitution “does not confer a right to abortion,” returning the issue to “the people and their elected representatives.” [1] For nearly half a century, abortion jurisprudence had been structured around judicially enforced constitutional limits. Dobbs promised a different settlement in democratic control and, according to many of the decision