"As David Garrow has shown, the issues of race and poverty did come up during the Court's first conference of Roe v. Wade and Doe v. Bolton.' 99 Roe involved a Texas statute that prohibited all abortions but those necessary to save the life of the mother. By contrast, Doe involved a statute patterned on the American Legal Institute's ("ALI") model reform: the statute allowed abortions subject to particular restrictions, requiring, among other things, several diagnoses by licensed physicians. During the conference, the Justices generally favored striking down the Texas law but found the constitutionality of the Georgia statute to be a closer question. Warren Burger, who led off voting on the Georgia measure, stated that it was constitutional. In discussing Doe, William Douglas, the next to vote, raised questions about the practical operation of the Georgia statute, asking: "Is it weighted on [the] side of only those who can afford this? What about the poor?" Thurgood Marshall similarly expressed concern about the impact of the Georgia statute on women in rural areas where "there [were] no negro doctors." Although there was some discussion of whether the Court ought to remand for lower court findings as to how the statute affected poor, non-white women, it ultimately did not. Just the same, Douglas and Marshall's comments revealed a doctrinal path the Court could have followed in Roe or Doe if it had wanted to address the question of race, poverty, and abortion. Under the Equal Protection Clause, the Court could have asked whether facially neutral statutes, like the ALI model, had an impermissibly discriminatory impact on poor, non-white women. Assuming that there was some constitutional right or liberty interest protecting the abortion decision, unequal access to abortion services might have posed an equal-protection problem."