"It is also commonly asserted that the Court caused conflict because it rendered a decision that diverged from popular opinion. Jeffrey Rosen, for example, contrasts Roe with Brown, which he asserts “was supported by more than half of the country when it was handed down . . . [while] Roe v. Wade was an entirely different matter. The Court’s decision, in 1973, to strike down abortion laws in forty-six states and the District of Columbia was high-handed, and represents one of the few times that the Court leaped ahead of a national consensus.” Jeffrey Rosen, The Day After Roe, THE ATLANTIC, June 2006, at 56, 56-57. Rosen also contends that the Court could have avoided backlash if only it had limited its holding to the termination of early pregnancies. Jeffrey Rosen, The Supreme Court: Judicial Temperament and the Democratic Ideal, 47 WASHBURN L.J. 1, 8 (2007) (“The parts of Roe that provoked a backlash were those that called into question later term restrictions that most Americans support.”). Historical evidence does not suggest that a more temporally limited abortion right would have been acceptable to the antiabortion movement at the time of Roe. The fervent minority who entered politics to work against abortion rights before and after Roe sought criminalization and were not willing to settle for less. To those who believe that abortion is murder, there is no middle ground; it makes no difference whether a judicial or legislative decision permits abortion up to twelve weeks’ gestation or twenty. That is why the Catholic Church began to organize at the national level to block abortion reform when the only reform on offer was the ALI therapeutic legislation. see supra notes 66-79 and accompanying text; see also Eugene Quay, Justifiable Abortion—Medical and Legal Foundations, 49 GEO. L.J. 173, 173 (1960) (attacking, from a Catholic perspective, the abortion provisions of the proposed Model Penal Code, recently tentatively approved by the ALI, and describing the proposal as “a violent departure from all existing laws”)."