"The second reason has to do with a belief in Roe’s efficacy. The gains secured by Roe seem more tangible than the gains secured by Brown and Lawrence, so the potential cost of reckless critique seems higher. Brown ended de jure segregation of the schools—but not de facto segregation, and much less real racial subordination: schools as well as neighborhoods remain segregated and unequal in much of the country. Lawrence struck from the books criminal statutes that had not been directly enforced anyway, and left untouched the unequal treatment of gay and lesbian citizens on any number of fronts, from marriage to military service, employment, and tenancy rights. There is much to criticize, if one keeps the focus on the paltry consequences of these decisions, compared with what they promised. Roe, by contrast, was by no means an empty victory, much less a Trojan horse. Rather, Roe sent a clear material and rhetorical signal to women, girls, and the larger society: women’s reproductive lives should be, and henceforth would be, governed by a regime of choice— whose choice is not so clear—and not by fate, nature, accident, biology, or men. The gains of this one decision, in terms of the autonomy and broadened options for women and girls, were felt to be enormous. With the advent of birth control and safe and legal abortion, women can avoid life- and health- threatening pregnancies, can limit the number of children they will mother, and can plan the major sequence of their lives—pregnancies, education, marriage, job, and career—so as to increase hugely their chances of succeeding at all. Without that control, women’s and girls’ control of these life-changing events is severely compromised. Dangerous, injurious, or simply too many pregnancies in one’s teens, twenties, thirties, and forties make completion of high school, college, professional school, graduate school, or vocational training for skilled crafts much harder even to imagine, much less to accomplish. The burdens of unwanted, dangerous, or just too many pregnancies are harder to measure but just as real in private and intimate life. Dangerous pregnancies shorten lives. Too many pregnancies make for difficult and unrewarding mothering. All of it leaves the woman feeling, justifiably, hostage to fate. If she cannot control her reproductivity, she cannot control her life. Without self-sovereignty over her body, all that remains of her life—her work, her sociability, her education, he r mothering, and her impact on the world—is miniaturized. She lives a smaller life."