"Justice Harry Blackmun devoted more than half of his majority opinion in Roe v. Wade to an account of “the history of abortion, for such insight as that history may afford us.” This narrative preceded any legal analysis and, rather than any interpretation of the Constitution, is Roe’s real foundation. While it has acquired the status of “orthodox abortion history,” however, this narrative has been crumbling since it was created. As Roe was heading for the Supreme Court, Cyril Means, General Counsel of the National Association for the Repeal of Abortion Laws, was constructing a “radically revisionist history” of abortion in America. His goal was to paint a long-term picture of abortion as a common procedure that the law treated lightly, if at all, in order to support the argument that abortion should be recognized as a constitutional right. To that end, Means made two primary claims that the Supreme Court would later embrace: American women enjoyed a “liberty of abortion” under the common law “at every stage of gestation,” and the 19th-century statutes that replaced the common law were enacted “to protect the health of mothers, not to protect the lives of unborn children.” This narrative “simply left the unborn child out of the moral and legal equation.” The legal team challenging the Texas abortion statute in Roe placed Means’ narrative at the center of their argument despite their own concern, reflected in an internal memorandum, that his conclusions “sometimes strain credibility.” This was a profound understatement, as a vast amount of scholarship and commentary, including by abortion rights supporters, has exposed the Means–Blackmun narrative as selective at best—and fiction at worst."