"BLACKMUN'S PAPERS VINDICATE EVERY INDICTMENT of Roe: invention, overreach, arbitrariness, textual indifference. But they also implicate his critics. In a 1970 letter, Chief Justice Warren Burger lectured Blackmun about the evils of injecting personal morality into constitutional law. A year later, though, Burger prodded his colleagues to expand Roe or Doe to address the rights of would-be fathers. In December 1972, when Blackmun asked the other justices to comment on his trimester framework, Burger ignored the request and brought up the question of fathers again. Blackmun fended him off with a footnote pointing out that no law or litigant in either case had raised the question. This didn't stop Burger from resuming the lecture: When Blackmun drafted a decision-day announcement that the justices "have endeavored, too, to note the changes in attitudes" toward abortion among medical organizations, Burger wrote in the margin, "We ought not to look for it!" Burger edited the sentence to read, "We cannot escape noting, too . . ." Judicial restraint turns out to be less a principle than a pose."