"Justice Blackmun’s tally in his opinion in Roe was six federal decisions to strike state abortion statutes and five to sustain, plus two state court decisions to strike state laws, and three state courts to uphold them. The actual tally was: seven federal court decisions struck down state laws, five federal decisions upheld state laws; five state court decisions struck downs state abortion laws, sixteen state courts upheld state laws. A number of other abortion cases in federal court had been thrown out on procedural grounds. Among the nine courts (seven federal, five state) that held state statutes “unconstitutional,” however, there was little consensus in their explanation for why abortion laws were unconstitutional or in their definition of the scope of the abortion right. About the only common theme among the courts was Griswold: the courts cited each other for the notion that Griswold’sbroad phrasesmeant that abortion laws were unconstitutional. The legal advocates put all their hopes on the Supreme Court’s decision in Griswold."