"As Lazarus has written, “Brennan knew well the tactic of ‘burying bones’-secreting language in one opinion to be dug up and put to use in another down the road.” Lazarus continues: Eisenstadt provided the ideal opportunity to build a the rhetorical bridge between the right to use contraception and the abortion issue pending in Roe. And taking full advantage, Brennan slipped into Eisenstadt the tendentious statement explicitly linking privacy to the decision whether to have an abortion. As one clerk from that term recalled, “We all saw that sentence, and we smiled about it. Everyone understood what that sentence was doing.” It was papering over holes in the doctrine."