"Neither the vulnerability nor efficacy of Roe, nor the partial truth it expresses, is a good reason not to engage in critique. There are also, however, costs to the reticence. The lack of such a critique, I will argue, has dulled us to the degree to which the rhetoric of adjudicated abortion rights might have weakened reproductive justice more broadly conceived. But it is also worth noting that even if feminism’s or progressivism’s or the Democratic Party’s sole goal were to strengthen this embattled right, there is a strong pragmatic case for pro-choice feminist critiques of the way that right is now constructed: by its steadfast loyalty to Roe the pro-choice community is in danger of losing this war by fighting—even if winning—yesterday’s battle. Pro-life movement activists increasingly look to reduce abortions not by reversing Roe and criminalizing abortion, but rather through a three-pronged strategy, no part of which is dependent upon Roe’s reversal: first, by passing restrictions the Court will uphold even with Roe on the books; second, by reducing abortion supply and demand by intimidating clinics and clinicians and shaming the women who use them; and third, by reducing the long-range cost of pregnancy by urging more political and communitarian support for motherhood, particularly for poor women. For pro-life constituencies, the grounds of contestation of legal abortion have shifted to the local, political, and moral, and away from the constitutional-adjudicative. The pro- choice community’s fixation on the apparently never-ending project of finding adequate grounds for adjudicated abortion rights blinds it to this development."