"As for Harlan, he noted during the Justices’ discussion of Griswold in April 1965 that “he would feel differently if the Connecticut law were not a ‘[marital] use’ statute and did not apply to married couples.” Harlan’s opinion in Griswold pointed to limits on judicial discretion from “respect for the teachings of history, solid recognition of the basic values that underlie our society, and wise appreciation of the great roles that the doctrines of federalism and separation of powers have played in establishing and preserving American freedoms.” Harlan’s biographer Tinsley Yarbrough, contends that Harlan never expressly revealed his views on the constitutionality of abortion laws during the deliberations over Vuitch, and that “given his flexible approach to due process, he might well have accepted at least limited restrictions on governmental authority in that highly sensitive field."