"The idea of a broader right to abortion bubbled up from lower courts, propelled by result-oriented arguments that seemed indifferent to how they were supported by the Constitution. The Georgia district court that had decided Doe before the case reached the Supreme Court cited both the "retained by the people" clause and the "penumbras" underlying the right to privacy. "For whichever reason, the concept of personal liberty embodies a right to privacy which apparently is also broad enough to include the decision to abort a pregnancy," the court said. Blackmun's notes convey the same casual attitude. He began with intuition and then looked for a constitutional peg. "Right of the mother to life, health, physical & mental," he wrote in October 1972. "Translated this means 9th and 14th amendment rights." In his notes, he posited an abortion right similar to the right to contraception, then conceded the difference between the two acts, but shrugged, "Whatever the answer, something fundamental is involved. [There's] much precedent for this sort of thing—Griswold, etc." In his final draft of Roe, he concluded that "This right of privacy, whether it be founded in the Fourteenth Amendment's concept of personal liberty [or] . . . the Ninth Amendment's reservation of rights to the people, is broad enough to encompass" abortion. Fourteenth, Ninth, etc., this sort of thing, something fundamental, whatever."