"It was the use of the Ninth Amendment, according to many legal scholars, that was the most interesting aspect of the Dallas decision. Although it was sometimes included in the list of possible constitutional grounds, no one seriously believed it had much potential for establishing an abortion right. In this article on the constitutional grounds for abortion, for example, Roy Lucas had relegated the Ninth Amendment to a footnote, saying: “Several theoretically feasible but unnecessary constitutional theories are omitted from this discussion. First, whether a physician or an organization would claim a First Amendment right to inform patients as to the whereabouts of competent abortionists. Second, whether the Ninth Amendment, of its own thrust, permits of a fundamental right to abortion.” Most persons thought the woman’s right to abortion would be found in the Fourteenth Amendment-specifically, in the due process clause of the Fourteenth Amendment, which stated that the rights guaranteed to all individuals in the constitution could not be violated or withdrawn except by due process or law. But there were reasons not to rely ont the Fourteenth Amendment; it was in many people’s eyes a tarnished amendment, especially when applied to a case like Roe v. Wade."