"Brennan’s biographers, Stern and Wermiel, put it even more bluntly: In the years to come, many of Brennan’s colleagues learned to watch for the seemingly innocuous casual statement or footnote-seeds that would be exploited to their logical extreme in a later case. As another Brennan biographer has written “Brennan found a way not only to connect the case to the abortion debate but to use it as another strong leg on which a future opinion legalizing abortions could stand.”"