"Rather than defending what the Supreme Court actually said in Roe, some scholars resort to “rewriting” it or suggesting “what Roe v. Wade should have said.” Just 14 years after Roe was decided, the critical literature had so proliferated that three scholars organized it into 12 different categories. Scholars and commentators across the ideological spectrum have shown how little, if anything, Roe has to commend it. Professor John Hart Ely, who candidly favored Roe’s result, called it a “very bad decision...because it is...not constitutional law and gives almost no sense of an obligation to try to be.”"