I see you're a lawyer. You may appreciate this comment I left in the Penguin's argumentative piece on the Alito decision:

"Holdings are different than the reasoning. If there is other and better reasoning for a prior holding, the prior case should not be overturned. It should be affirmed on other grounds.

Laws that criminalize or otherwise prevent pre-viability abortion codify certain religious views over others and thus violate the 1st Amendment's anti-establishment of religion clause. That is the firm foundation under which Roe (and the other privacy rights cases--(sodomy/contraception/etc)) should have been decided and it is the grounds under which they should be affirmed. This is my essay on the matter that I wrote in December. https://medium.com/illumination-curated/abortion-is-murder-4d234daa2e71 Let me explain my title. I do believe that human life begins at conception but I am 100% pro-choice. My subtitle is "Yet I steadfastly believe the decision is a personal one that should not be criminalized before the point of fetal viability as there is no justification for human laws to ban it."

If you want to read Argumentative Penguin's piece, here's that link: https://medium.com/lucid-nightmare/alito-is-right-roe-v-wade-does-need-to-be-overturned-108a8e36c61