"i)Left-wing critics of “Roe” claim, in turn, there exists an inevitable tension between the constitutionally recognized woman’s right to “reproductive freedom” and the role assigned by the Court to physicians who are to act as primary decision-makers even on non-medical issues (Appleton, p.226). These critics of the 1973 decision view abortion restrictions as constitutionally impermissible gender-based discrimination: legislation that singles out abortion for differential treatment is discriminatory because only women become pregnant and have abortions (Law). Another writer suggests that under the proper analysis abortion laws should be seen as unconstitutionally singling our pregnant women as unwilling “good Samaritans” who are obliged to endure life and health-threatening burdens (Reagan, p.1569)."