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J. Joel Alicea

DOBBS AND THE FATE OF THE CONSERVATIVE LEGAL MOVEMENT

The Supreme Court’s ruling in the abortion case, expected next June, will be a
defining moment in the Right’s battle for the Constitution.

/ Politics and law
December 05, 2021 / Share
/ From the Magazine / Politics and law
Winter 2022 / Share

The conservative legal movement finds itself at its most precarious point since
its inception in the early 1970s. That might sound implausible. The last four
years saw the appointment of three Supreme Court justices, dozens of appellate
judges, and nearly 200 district court judges—almost all coming from within the
ranks of the conservative legal movement. Conservatives on the Supreme Court now
(ostensibly) hold a 6–3 majority, making it, in all likelihood, the most
conservative Court we will see in our lifetimes. It would thus be easy to
conclude that the conservative legal movement is at its apogee.

But it is precisely the movement’s success that puts it in peril. After decades
of laying intellectual groundwork, building institutions, and engaging in
politics, legal conservatives are in a position to accomplish what they see as
the revival of the rule of law. But with that success has come high expectations
that the Supreme Court will deliver on the legal goals that have sustained the
movement through many disappointments and false starts. Foremost of those goals:
overruling Roe v. Wade, the 1973 decision establishing a constitutional right to
abortion; and Planned Parenthood v. Casey, the 1992 decision that reaffirmed
Roe’s “central holding.” More than any other Supreme Court decision, Roe is
responsible for the emergence of the conservative legal movement. If there were
only one reason that the movement has endured for decades, it would be to see
Roe overturned.

These will be the stakes when the Supreme Court decides Dobbs v. Jackson Women’s
Health Organization—the lawsuit challenging the constitutionality of
Mississippi’s prohibition on abortions after 15 weeks of pregnancy—next summer.
As December 1’s Supreme Court oral argument highlighted, Mississippi and its
supporting amici have expressly asked the Court to overrule Roe and Casey, and
Dobbs squarely presents that issue because, as Jackson Women’s Health
Organization asserted in its briefing and at oral argument, Mississippi’s ban
“directly contravenes [Roe’s] ‘central holding’ and cannot stand” if Roe remains
good law. This, then, is the moment the conservative legal movement has fought
to bring about. If the Court fails to overrule Roe, the ruling will likely
shatter the movement, and while (under a proper conception of the judicial role)
the potential effect of Dobbs on the conservative legal movement should be
irrelevant to the outcome in that case, it would be a significant legacy of the
Roberts Court if Dobbs brought an end to one of the most successful intellectual
and political projects of the past half-century.

That demise would result not only from dashed expectations but also from
intellectual tensions within the conservative legal movement—present since its
inception and now coming to the fore. The Dobbs decision will likely either
increase those tensions to the point of rupture or greatly alleviate them. Next
summer will be a defining moment in the battle for the Constitution.

What we now know as the conservative legal movement was born in the aftermath of
the Warren Court, the period from 1953 through 1969, when Earl Warren served as
chief justice. It was a time of tremendous upheaval in American constitutional
law. To take just a few examples, the Court required states to provide indigent
criminal defendants with a lawyer, mandated the principle of one-person-one-vote
in redistricting, declared a right to use contraception, and required the
reading of so-called Miranda Rights to those taken into police custody. All
these (and many other) decisions were controversial, and all represented
dramatic departures from well-established constitutional law. A revolution in so
many areas of law and social life was bound to provoke a counterrevolution in
law and politics, and it did.

The legal counterrevolution began when then–Yale law professor Robert Bork
published an article that began laying the intellectual foundation for the
conservative legal movement. “Neutral Principles and Some First Amendment
Problems” argued that the Supreme Court’s legitimacy rests on its ability to
derive principles neutrally from the text and history of the Constitution,
define those principles in a neutral manner, and apply them impartially across
cases. To the extent the justices instead derive principles from their own
viscera, define them arbitrarily, or apply them inconsistently, Bork wrote, they
“claim for the Supreme Court an institutionalized role as perpetrator of limited
coups d’etat.” Bork cited as a prime instance of this illegitimate
decision-making the Court’s opinion in Griswold v. Connecticut, the 1965 case
holding that married couples have a constitutional right to use contraception (a
right that the Court extended to unmarried individuals in the 1972 case of
Eisenstadt v. Baird). Griswold famously (or, to most legal conservatives,
infamously) based its holding on the notion that, while no specific provision of
the Constitution clearly established the right to use contraception, “specific
guarantees in the Bill of Rights have penumbras, formed by emanations from those
guarantees that help give them life and substance.” To Bork, this was emblematic
of the lawlessness of the Warren Court.

From 1953 to 1969, Supreme Court Chief Justice Earl Warren presided over a
tremendous upheaval in American constitutional law; the conservative legal
movement was born in its aftermath. (Bettmann/Getty Images)

Bork thus began charting an alternative theory of constitutional adjudication
based on neutral principles derived from the text and history of the
Constitution. It was a path that would lead to the development of originalism,
the theory that constitutional provisions must be interpreted and applied in
accordance with the meaning they had when they were ratified. Subsequent works
by Justice William Rehnquist and Harvard law professor Raoul Berger furthered
originalism’s development, and by 1980, it had become a recognized rival to the
brand of progressive constitutional jurisprudence embodied by the Warren Court.

The election of Ronald Reagan in 1980 proved decisive to originalism’s
ascendancy, ushering in a wave of judicial appointments (including of Bork to
the U.S. Court of Appeals for the D.C. Circuit) and the elevation of committed
originalists to senior positions in the Department of Justice. The appointment
of Justice Rehnquist as chief justice and of Antonin Scalia as an associate
justice, along with several high-profile speeches defending originalism
delivered by Attorney General Edwin Meese in Reagan’s second term, made it clear
that originalism was here to stay. It had become the default theory of
constitutional adjudication for a new coalition that formed the conservative
legal movement.

> “By 1980, originalism had become a recognized rival to the brand of
> jurisprudence embodied by the Warren Court.”

But from the beginning, two major sources of tension beset the movement: a
division among originalists and a division between originalists and conservative
non-originalists.

The first, intra-originalist tension was between those who saw originalism as a
means to achieving some other substantive end and those for whom it was the only
legitimate constitutional methodology. Those holding the instrumentalist view
hoped that originalism would achieve various ends but were usually most
concerned with shrinking the federal judiciary’s role in American life after the
Warren Court’s aggressive intrusion into the political and social realms. They
advocated originalism as a way of achieving “judicial restraint,” by which they
often meant that the judiciary should generally allow the democratic process to
settle controversial political and social questions.

Harvard law professor James Bradley Thayer had articulated this principle in an
1893 lecture, “The Origin and Scope of the American Doctrine of Constitutional
Law.” The Supreme Court, Thayer argued, should hold a political act
unconstitutional only “when those who have the right to make laws have not
merely made a mistake, but have made a very clear one—so clear that it is not
open to rational question.” Progressive constitutional theorists took up
Thayer’s argument in the early twentieth century as a way of criticizing Supreme
Court decisions holding many early progressive and New Deal initiatives
unconstitutional. But things took a turn during the Warren Court as the
judiciary began assertively intervening in state and federal social policy,
leading the New Dealer justice Hugo Black to lament, in his Griswold dissent,
that the progressive Warren Court had betrayed the judicial-restraint principles
of the progressive New Deal Court.

As Princeton professor Keith Whittington has observed, Black’s accusation of the
Warren Court’s hypocrisy in Griswold became a standard attack by early legal
conservatives. Bork made the point explicitly in his 1971 article, as did
Rehnquist in an important 1976 lecture. Early legal conservatism, then, had a
strong commitment to judicial restraint, and it saw originalism as a way of
reining in an out-of-control judiciary. An important implication of this view
was that, to the extent that originalism did not restrain the judiciary, it
should be abandoned as having failed to serve its purpose. The instrumentalist
commitment to originalism was contingent, not based on deep principle.

Unlike the instrumentalists, other legal conservatives saw originalism as
logically entailed by the Constitution and the principles on which it rested.
This theme, too, can be found in Bork’s 1971 article. Bork argued that the basic
principle of our system is that the majority rules. But the majority established
limits on its own power through the Constitution, and this placed the judiciary
in the position of having to determine, through constitutional interpretation,
when the majority had done so. If the Court wrongly held that the Constitution
limited majority power when it did not, this abetted tyranny of the minority; if
the Court held that the Constitution did not limit majority power when it
actually did, this abetted tyranny of the majority. Bork called this the
Madisonian dilemma, and the only way for the Court legitimately to draw the line
between majority and minority power, he maintained, was to interpret the
Constitution in line with neutral principles, and that could be achieved only by
deriving, defining, and applying those principles based on the text and history
of the Constitution—that is, through originalism. Originalism, for Bork, was the
only plausible methodology of constitutional adjudication because it was
logically required for the legitimacy of judicial review and, by extension, for
the Constitution. This commitment to originalism was not contingent.

Over the next several decades, as scholars and jurists (such as Justice Scalia)
helped refine the theoretical basis of originalism, the non-instrumentalist view
became dominant within conservative intellectual circles, and the
judicial-restraint view subsided, though it remained a significant minority
position and continues to play an outsize role in conservative political
discourse about the Court. Most legal conservatives came to believe that
originalism was the only legitimate constitutional methodology and that the
Court should enforce the Constitution’s original meaning, regardless of how much
or how little intrusion was required. That explains why, for instance, Justices
Scalia, Clarence Thomas, and Samuel Alito were prepared to throw out the entire
Affordable Care Act, in what would have been the most important repudiation of
the political branches since the New Deal; by contrast, Chief Justice John
Roberts—the Court’s most committed Thayerian (though never a committed
originalist)—was unwilling to do so. While the tension between instrumentalists
and non-instrumentalists might, at first glance, appear to be merely a matter of
intellectual history, it has had enormous real-world consequences.

The second tension is equally significant. From the beginning, legal
conservatives have disagreed about whether originalism rests on a sufficiently
robust moral foundation. All constitutional theories, including originalism,
ultimately require a moral argument for why we should obey the Constitution.
Even if a judge believes, based on some ostensibly morally neutral reason, that
the only way to interpret a historical document like the Constitution faithfully
is according to its original meaning, that does not show that the judge should
care about faithfully interpreting the Constitution. If we are not bound by the
Constitution, the judge would be free to ignore a faithful interpretation and
proceed to rewrite the Constitution instead. To explain why this would be wrong,
one would need to show that the judge has an obligation to obey the Constitution
as written. Moreover, the moral stance shapes how we interpret the Constitution
because this tells us the purpose of interpreting it. If, for example, a judge
believes (as many progressive constitutional theorists do) that the only way
that the Constitution can have morally binding force is if its meaning can be
revised without a formal constitutional amendment, that moral justification
would require rejecting originalism and embracing a theory that allowed judges
to change the document’s meaning over time.

Since originalism, like any other constitutional theory, ultimately rests on a
moral argument, it can be challenged by those who find that argument
insufficient. As former Amherst professor Hadley Arkes wrote in First Things
recently (addressing both originalism and its statutory counterpart,
textualism), because originalism is “deeply reluctant to make [the] move beyond
‘tradition’ and [the text] to the moral truth of the matter,” it “indeed has
nothing to say on matters of real consequence. It is a morally empty
jurisprudence.” More recently, Harvard law professor Adrian Vermeule has become
the leading critic of originalism from the right by contending that originalism
is morally bankrupt. Vermeule’s views are complex, but what he has written thus
far attacks originalism from the perspective of the natural-law tradition, in
which the moral legitimacy of the Constitution (as a form of positive law)
depends on its accordance with the natural law. As nothing in originalism
requires it to accord with the natural law, Vermeule argues, no morally
compelling argument favors it.

The moral critique of originalism came to the fore in the summer of 2020 when
the Supreme Court decided Bostock v. Clayton County, which held that Title VII
of the Civil Rights Act of 1964 prohibits discrimination on the basis of sexual
orientation or transgender status. The case involved statutory interpretation
(textualism), not constitutional interpretation (originalism). But the
justifications for, and methodologies of, textualism and originalism overlap
significantly, which is why moral critics of originalism often use the term
interchangeably with textualism. Arkes, for instance, argued that the Bostock
opinion, written by the originalist and textualist Justice Neil Gorsuch, proved
that originalism lacks a sufficiently compelling moral account. Following
Bostock, the conservative legal movement expressed widespread frustration and
disillusionment with originalism, as manifested by Senator Josh Hawley’s
statement that Bostock “represents the end of the conservative legal movement.”
My own anecdotal sense is that the Vermeulian critique of originalism has gained
significant momentum among younger legal conservatives since Bostock. Once
again, what might seem like mere intellectual history does, in fact, have
potentially profound practical consequences, since the triumph of the Vermeulian
critique would be the end of the originalist project that has been at the heart
of legal conservatism for decades.

For nearly 50 years, the goal of overruling Roe has united all sides:
instrumentalist and non-instrumentalist originalists; critics of originalism’s
morality and its defenders. It is the only case that inspires such fervent
agreement within the intellectual wing of legal conservatism.

Roe is unique among modern constitutional decisions in the intensity with which
it has been resisted. It was, in Justice Ruth Bader Ginsburg’s words, a
“breathtaking” decision; four characteristics of the decision engendered the
immediate and enduring backlash. First, Roe was unexpected. No long series of
decisions had telegraphed the future recognition of this new right (unlike the
Court’s 2015 decision in Obergefell v. Hodges requiring states to recognize
same-sex marriages). Second, Roe was extraordinarily sweeping in its
implications. Roe did not merely invalidate the statute challenged in that case;
it (in combination with its companion case, Doe v. Bolton) effectively
invalidated the abortion laws of all 50 states and effectively mandated that the
right to abortion be protected all the way up to the moment of birth. Third, Roe
wrote into America’s fundamental law what many Americans saw then, and see now,
as a right to kill babies. Finally, Roe was and is widely perceived as having no
plausible legal basis, as commentators from the Right and the Left stated when
it was handed down. As then–Yale law professor John Hart Ely—a supporter of the
policy outcome dictated by Roe—noted immediately after the decision, Roe is “bad
because it is bad constitutional law, or rather because it is not constitutional
law and gives almost no sense of an obligation to try to be.” Indeed, it is
notable that, at the December 1 oral argument in Dobbs, none of the justices or
advocates who support Roe devoted much time to defending the decision as an
original matter, instead relying primarily on the principle of stare decisis
(the idea that the Court should generally stand by its previous decisions, even
if they were wrong).

These characteristics of Roe had different political and legal effects.
Politically, Roe became the case that social conservatives would rally against.
While the conservative legal movement started as a reaction against the Warren
Court, it matured in reaction against the Warren and Burger Courts. The
imperative to select justices who would overrule Roe was a major reason that
social conservatives joined the broad coalition supporting Ronald Reagan, as
reflected in the 1980 Republican Party platform promising “the appointment of
judges at all levels of the judiciary who respect traditional family values and
the sanctity of innocent human life.”

Yale law professor Robert Bork helped spark a legal counterrevolution when he
argued that the Court’s legitimacy rests on its ability to derive principles
neutrally from the text and history of the Constitution. (Bob Daugherty/AP
Photo)

It is also the primary reason that antiabortion voters have continued to support
the Republican Party in the four decades since 1980, including through bruising
(and not always successful) confirmation battles. Even after the deep
disappointment of the Court’s refusal to overrule Roe in Casey—a refusal
spearheaded by three Reagan- and Bush-nominated justices—these voters stayed
with the broader conservative legal movement, always being promised that
overruling Roe was just around the corner. Without these voters, the legal
movement would never have achieved the success that it has in remaking the
federal judiciary, since political victories are needed to change the
orientation of legal institutions. Dahlia Lithwick has rightly observed that
“the notion that Roe created an almost irreversible political ‘backlash’ that
led to the creation of the powerful modern conservative legal movement is almost
an article of faith among legal academics.”

Legally, Roe catalyzed the nascent conservative legal movement. Legal
conservatives from all camps came to see Roe as a constitutional abomination
that had to be overturned. From the instrumentalist perspective of
judicial-restraint conservatives, Roe remains the most aggressive judicial
intervention into American social policy since Brown v. Board of Education. But
unlike Brown, which the vast majority of originalists embrace as rightly
decided, no plausible originalist argument exists for Roe, so the
non-instrumentalist view of originalism has always aligned against Roe, too.
Overruling Roe would, as Justice Brett Kavanaugh put it during the Dobbs oral
argument, allow the Court to remain “scrupulously neutral on the question of
abortion,” an issue that inspires a fervor matched by few in American history.
And because originalism’s moral critics within the conservative legal movement
are typically social conservatives who regard legalized abortion as a moral evil
rivaled in our history only by legalized slavery, they, too, have unflinchingly
opposed Roe. Many positions generate significant divisions among legal
conservatives, but that Roe is a uniquely lawless decision that must be
overruled is not among them.

Dobbs has the potential to destroy this unity. Just as the goal of overruling
Roe is unique in its ability to unite the movement, the failure to overrule Roe
in Dobbs would be unique in its ability to destroy the movement.

Expectations play a decisive role in this dynamic. Though (again, under a proper
understanding of the judicial role) those expectations should play no role in
the Court’s decision in Dobbs, they are essential in considering the potential
effect of Dobbs on the conservative legal movement. On the political side, the
failure of the Reagan and Bush appointees to overrule Roe in Casey was a huge
blow to the conservative legal movement, and the feeling of disgust after
decades of political and legal efforts was palpable. Nonetheless, the movement
pressed on over the next 30 years. In the intervening period, two of the five
justices who voted to reaffirm Roe’s central holding in Casey were replaced with
committed originalists, as was Justice Ginsburg. Each of those replacements
(Justices Alito, Kavanaugh, and Amy Coney Barrett) involved tremendous risks and
expenditures of political capital—and, in the cases of Alito and especially
Kavanaugh, perseverance through vicious confirmation battles. The conservative
legal movement fought those battles with the expectation that, when the day
came, the reconstituted Court would finally consign Roe and Casey to the
anti-canon of disgraced constitutional cases, alongside its
segregation-defending decision in Plessy v. Ferguson (1896).

That day has arrived. In its opening brief last summer, Mississippi could have
tried (unconvincingly) to argue that its abortion restriction was consistent
with Roe and Casey, or that those cases only had to be overruled in part.
Instead, it adopted a more coherent approach, spending most of its brief urging
the Court to overrule the cases entirely. One reason Mississippi might have
taken that approach is that, as Notre Dame law professor Sherif Girgis has
argued, there is no logically sound way for the Court to uphold Mississippi’s
law without overruling Roe and Casey, since those cases prohibit states from
banning abortion before the child reaches viability, as Mississippi’s statute
does. Indeed, as noted above, Jackson Women’s Health Organization has made
precisely the same argument as Girgis before the Supreme Court: “There are no
half-measures here.” The organization reinforced that view at oral argument in
response to questions by Justice Gorsuch, as did the solicitor general in
support of Jackson Women’s Health Organization.

Regardless of why Mississippi decided to make overruling Roe the focus of its
brief, it raised expectations of what the Court would do in Dobbs. Those
expectations were reinforced when, in the week after Mississippi filed its
brief, almost three-quarters of the amicus briefs filed in support of the state
called for overruling Roe and Casey. And they were solidified after oral
argument, when at least five of the conservative justices asked questions that
were widely interpreted as signaling a willingness to overrule Roe and Casey.
With both Jackson Women’s Health Organization and the solicitor general likewise
arguing that the Court must either reaffirm or overrule Roe and Casey, legal
conservatives now expect that, after nearly 50 years of unceasing effort to
overrule Roe, they will finally see the Court do it. If it does not, a sense of
betrayal and disillusionment will likely follow.

That would place enormous strain on the intellectual fault lines within the
movement. If a Supreme Court with a 6–3 conservative majority consisting of five
committed originalists refuses to overrule Roe and Casey, it is unlikely that
any originalist Court will ever do so—raising serious questions within the
conservative legal movement about its attachment to originalism. Immediate
recriminations and accusations of betrayal would ensue, likely tearing the
movement apart. Those who offer a moral critique of originalism would point to
Dobbs as proof positive that originalism lacks the moral foundation necessary to
be a plausible constitutional methodology. Vermeule has openly predicted that if
“Roe (not merely Casey) survives in any form without being overturned [in
Dobbs], it will represent a shattering crisis for the conservative legal
movement.” If the Court fails to overrule Roe and Casey, there is a very good
chance that Vermeule would become the most important intellectual figure in
whatever succeeds the current conservative legal movement.

Similarly, those advocating an instrumental view of originalism, especially in
favor of judicial restraint, would have good reason to question whether
originalism actually achieves the restrained judiciary they favor, since the
failure to overrule Roe would keep the Court enmeshed in the most contentious
social issue in America, without clear constitutional warrant. Some may argue
that the more restrained position would be to uphold Roe, since that would be
minimally disruptive to American constitutional law. But Chief Justice
Roberts—the most committed judicial-restraint member of the Court—has shown
himself willing to make great changes in constitutional law to keep the Court
out of political and social policy if the Court’s intervention has no firm
constitutional basis. For example, he wrote the Court’s opinion in Rucho v.
Common Cause (2019), which held that the federal judiciary has no authority to
adjudicate political-gerrymandering challenges to redistricting maps. That
controversial decision ended several decades of gerrymandering jurisprudence,
but its effect was to withdraw the Court from fraught political and social
battles.

> “A forthright overruling of Roe would alleviate the tensions within the
> movement and bolster its long-term outlook.”

Those who believe that originalism is the only legitimate methodology of
constitutional adjudication would have no logical reason to abandon their view,
since it is not based on the results that originalism achieves. But their
theoretical arguments would sound less convincing to an audience that had
witnessed such a seismic failure of originalism to translate its arguments into
reality, just as those arguments have already lost some of their purchase after
Bostock. The conservative legal movement has always been an intensely
intellectual but also intensely practical movement; a methodology right in
theory but self-defeating in practice will not retain many adherents.

What if the Court instead adopts some middle ground: sustain the Mississippi
statute without overruling Roe, but lay the groundwork for overruling Roe later?
That is what the Court did in a series of cases leading up to Janus v. AFSCME
(2018), in which the Court overruled a previous precedent, Abood v. Detroit
Board of Education (1977), which had allowed public-sector unions to collect
union fees from nonunion members. But two key factors render that step-by-step
approach implausible in Dobbs. First, as Girgis points out, because of the
factual context of Dobbs—its straight-on challenge to a core tenet of Roe and
Casey—it is impossible for the Court to craft a logical opinion that sets up the
eventual overruling of those two decisions, which was not true of the cases
preceding Janus. Instead, any middle-ground option would have to divorce the
viability standard from Casey’s undue-burden standard, which Girgis rightly
argues would fundamentally rewrite Casey in a way that would make it very
difficult for this same Court to overrule later.

Second, as noted above, both Jackson Women’s Health Organization and the
solicitor general essentially disavowed such a middle-ground option in their
briefs and at oral argument, and Mississippi’s briefs effectively acknowledged
that an incrementalist approach would be unprincipled or unworkable. Thus,
neither side in Dobbs seeks a middle ground, and none of the justices at oral
argument—other than perhaps the chief justice—seemed interested in such an
approach. In light of those two factors and the expectations of a full
overruling, commentators make a serious mistake if they think that a timid,
first-step opinion making yet another promise of Roe’s eventual demise would
avoid a potentially fatal blow to the conservative legal movement.

A forthright overruling of Roe, however, would significantly alleviate the
tensions within the movement and bolster its long-term outlook. It would, in the
eyes of instrumentalist and non-instrumentalist originalists alike, vindicate
their half-century support for originalism. It would take much of the wind out
of the sails of originalism’s moral critics, since originalism will have been
the means of achieving the critics’ most earnestly sought moral goal. There is
likely no avoiding the consequences, then, for the conservative legal movement
in Dobbs: complete victory or crisis-inducing defeat.

J. Joel Alicea is an assistant professor of law at the Catholic University of
America, Columbus School of Law.

Top Photo: Pro-choice and pro-life activists demonstrate outside the Supreme
Court, October 2021 (Kevin Dietsch/Getty Images)

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Also by J. Joel Alicea
An Originalist Victory
Eye on the News Jun 24 2022
Winter 2022

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