SYMHC Classics: Griswold v. Connecticut

right to due process. This is part of the fifth and fourteenth Amendments to the US Constitution, which both specify that no person will be deprived of their life, liberty, or property without due process of law, meaning a fair hearing or some other type of fair proceeding. So we would just like to take a moment to note that this language in both of these amendments applies to persons, not just to citizens. Everyone has the right to do process,

including immigrants regardless of their immigration status. This episode originally came out on July twenty seventh, twenty twenty two. Welcome to Stuff You Missed in History Class, a production of iHeartRadio. Hello and welcome to the podcast. I'm Tracy B. Wilson and I'm Holly Frye. I've been circling the idea of an episode on Griswold versus Connecticut for years. That's the US Supreme Court decision that overturned law's banning contraception, at

least when it came to married couples. That's connected to several of our previous episodes as well. But the recent Supreme Court decision in Dobbs versus Jackson Women's Health Organization is really what finally propelled it up to the top. That's the decision that came out just recently which overturned

Roe versus Wade and Planned Parenthood versus Casey. And in the concurring opinion that he wrote on this case, just as Claris Thomas wrote, quote, in future cases, we should reconsider all of this Court's substantive due process precedence, including Griswold, Lawrence and obergefel So. Substantive due process that's the idea that courts can protect various rights that aren't specifically named in the Constitution, and in this case, it's the right

to privacy. Griswold versus Connecticut wasn't the very first Supreme Court decision ever in the US to mention the right of a concept of privacy, but it was a major decision in that regard. I personally always had a lot of trouble understanding the logic behind the decision of Roe versus Wade, not the outcome, but like the reasoning of how they got there, which was essentially the abortion was

also protected under a right to privacy. That logic, though, makes a lot more sense to me with Griswold versus Connecticut as background. And then this decision has also mentioned and a lot of other decisions that came after it, beyond just the ones that were mentioned in Thomas's concurring opinions. So that's what we're talking about today. Heads up. Obviously, we're going to be talking a lot about contraception in this episode. There's also a bit about abortion and some

things related to pregnancy and birth related trauma. Griswold versus Connecticut overturned a law that was sometimes described as a quote little Comstock law that was a nickname for various state anti obscenity laws that were similar to the Comstock Act of eighteen seventy three, or more formally known as an Act for the Suppression of Trade in and Circulation

of Obscene Literature and articles of immoral use. This law was named for social reformer Anthony Comstock, coincidentally also of Connecticut. Comstock served in the Union Army during the US Civil War. His upbringing had been deeply concerned, and during his time in the army he really disapproved of a lot of his fellow soldier's behavior, especially things like gambling and drinking, using tobacco, and swearing, And then for their part, his fellow soldiers seemed to have seen him mostly as a

sanctimonious prude. After the war was over, Comstock moved to New York, where he similarly really disapproved of the prevalence of things like sex work and explicit literature, so he started advocating for anti obscenity and anti vice laws. He started out doing much of this work through the Young Men's Christian Association, or YMCA, before heading up a new organization just for that purpose that was the New York Society for the Suppression of Vice. These two organizations continued

to be closely connected. YMCA leaders served on the Society's board. There were already laws on the books in various states at this point that regulated or outlawed things like sex work or obscenity. But Comstock did not think that these laws went far enough. He advocated for a much broader federal law, and he developed reports on things like sex work, drug use, and sexually explicit printed materials and delivered them

to members of Congress. He really argued that all of these things were corrupting children, and they were encouraging crime, and he thought they should all be outlawed. The Comstock Act was signed into law in March of eighteen seventy three.

It outlawed using the United States Postal Service to send any quote, obscene, lude, or lascivious book, pamphlet, picture, paper, print, or other publication of an indecent character, or any article or thing designed or intended for the prevention of conception or procuring of abortion. It applied to quote any article or thing intended or adapted for any indecent or immoral use or nature. This also included advertisements, notices, and other publications.

Violating this law was punishable with a fine of not less than one hundred dollars or more than five hundred dollars, or hard labor of not less than one year or more than ten years, or both. After having successfully lobbied for this law to be passed, Comstock was made a special agent for the United States Postal Service and he was tasked with enforcing it there. Since the Act didn't actually define what obscenity was, a lot of this was

up to his discretion. There was also a lot of focus on materials related to contraception, which was specifically referenced in the law. Comstock claimed that his work in this role led to the successful prosecutions of more than thirty six hundred people, and he claimed that he had destroyed more than one hundred and sixty tons of literature that was,

at least in his opinion, obscene. While various states already had anti obscenity laws in place before the Comstock Act was passed, some revised their laws afterward, and many many other states passed new ones. By the early twentieth century, nearly every state had some kind of anti obscenity law. Ultimately, thirty one states legally defined information about contraception as obscenity, and twenty four states also banned the sale of contraceptives.

So to point out one of the links back to an earlier episode of the podcast, when we talked about Catherine Dexter McCormick, who provided a big part of the funding for developing oral contraceptives. We talked about her smuggling diaphragms and to the United States from Europe by sowing them into the hymns and linings of her clothes, because diaphragms were illegal. This was why contraceptive advocates and other reformers pushed for the repeal of the Comstock Act and

all the various state little comstocks for decades. In nineteen sixteen, birth control advocate Margaret Sanger was tried for violating New York's anti obscenity law when she tried to import contraceptive

diaphragms into the United States. The New York State Court of Appeals decided that doctors were exempt from the law because they were making decisions for their patient's health and well being rather than for some obscene purpose, but Sanger's conviction was upheld because she was not a doctor, so that case was specific to New York. At the federal level, a similar case started dismantling the Comstock Acts prohibitions on

birth control in nineteen thirty six. This case was United States versus One package of Japanese Pessaries, which was heard in the United States Court of Appeals for the Second Circuit in New York City. This package named in the case was a box of one hundred and twenty contraceptive diaphragms. The physician Hannah Stone, who was working with Margaret Sanger,

had tried to import from Japan. The package was seized at customs because importing contraceptives was illegal under the Tariff Act of nineteen thirty, which had similar provisions to the Comstock Act. Because Stone had not taken possession of the shipment, she had not technically violated the terms of the Tariff Act, so this case was filed against the package itself. Stone and her attorneys stood in for the package at trial. This is a weirder thing that happens in the law

sometimes where you file suit against an inanimate object. The US Court of Appeals followed the same basic logic that the New York State Court of Appeals had in the earlier case against Margaret Sanger. The anti obscenity provisions in the Teriff Act and also the Comstock Act didn't apply to physicians because their work as doctors was about patient health and not obscenity. So in terms of federal law United States versus one package essentially legalized contraception if that

contraception was provided by a doctor. But this ruling didn't overturn the laws that were still in the books in various states. Most states eventually repealed or otherwise overturned their anti contraception laws by the time the Food and Drug Administration approved the first oral contraceptive pill in nineteen sixty. But at that point, Connecticut's law remained in place. And we'll get to that after a sponsor break. Connecticut's anti

contraception law dated back to eighteen seventy nine. One of its primary supporters had been the chair of the Connecticut legislature Joint Committee on Temperance. That was Phineas Taylor Barnum. Yes, that is P. T. Barnum, the circus guy. Under this law, quote any person who uses any drug, medicinal article, or instrument for the purposes of preventing conception shall be fined not less than forty dollars or imprisoned not less than

sixty days. The law also said, quote any person who assists a bets, counsels, causes, hires, or commands another to commit any offense may be prosecuted and punished as if he were the principal offender. So, in other words, under this law, using contraception was illegal, and so was providing contraception or counseling people about it. People in Connecticut lobbied

for the repeal of the law for decades. This escalated in nineteen twenty three after Catherine Houghton Hepburn and two of her friends established the Connecticut branch of the American Birth Control League. Catherine Houghton Hepburn was the mother of actor Catherine Hepburn, and the American Birth Control League later

became known as Planned Parenthood. But in nineteen thirty eight, authorities rated a contraceptive clinic in Waterbury, Connecticut and pressed charges against its medical staff, which put an end to services at the clinic and also put a damper on the rest of the movement. So we should take a moment to note the birth control movement during this era

was deeply flawed. Although it was rooted in the basic idea of allowing people to choose when and whether to have children, some of its leaders, including Margaret Sanger, were also proponents of eugenics. That's rooted in the idea that the human race can be improved through things like good breeding.

So broadly speaking, positive eugenics was focused on encouraging the so called right people to have more children, while negative eugenics was focused on preventing the quote wrong people from reproducing. This entire idea of eugenics was simultaneously racist, ablest, and incredibly widely adopted, including in some cases by leader of various groups of people that the eugenics movement as a

whole saw as inferior. Negative eugenics in particular led to horrific human rights abuses and was a major influence on Nazi racial policy. But what were really focused on in this episode today is access to contraception. Eventually, Connecticut mostly stopped enforcing its anti contraception law, but since it was still in the books, this led to disparities and who

could get contraceptives. Condoms were available at some drug stores, but they weren't an option for everyone, especially for people whose partners refused to wear condoms, or for people who needed a more discreet way to prevent pregnancy without their

partner being involved. Middle and upper class people, especially married couples who had money and access to private medical care, could usually find a doctor who was willing to provide them with contraception in spite of the law, or if not that at least to connect them with another provider

in a state where it was legal. But poor people who didn't have these kinds of resources often could not, and people of color who were working within their own communities as doctors were generally at a lot more risk than white doctors were. Compounding that, if they were arrested and lost their medical license, that could mean the loss of medical care for that whole community. That was something people had to take into account when deciding whether to

try to get around the law. In nineteen forty, the Connecticut Supreme Court heard State versus Nelson, involving a case against two doctors who had been running a birth control clinic, one that authorities seemed to have ignored until clergy in the predominantly Catholic neighborhood where it was located demanded it

be investigated. The doctor's attorneys argued that the anti contraception law shouldn't apply to them because they were prescribing contraception to married women for the sake of their health and well being. The court found that the law was unambiguous contraception was illegal no matter who was prescribing it, and upheld it. After this, the state prosecutor agreed to drop charges against the doctors if they closed their clinic, which they did, and that led the other clinics in the

state to also shut down. Yeah, there had been I mean this whole time, there had been people who were trying to provide birth control, and it was like the threat that since the state had upheld the law, that other clinics were also going to be targeted just led a lot of people to make the decision to shut down. So three years later, Yale Medical School professor Wilder Tileston filed suit on behalf of patients, arguing that the Connecticut law needed to have an exception for people whose lives

would be at risk if they became pregnant. This led to the Connecticut Supreme Court case of Tyleston versus Ullman. Allman was the Connecticut state's attorney, Abraham Ullman. The Connecticut Supreme Court rejected Tileston's arguing, noting that people already had a way to prevent pregnancy that was quote positive and certain end results. That method was abstinence. The US Supreme Court heard oral arguments in this case, but eventually dismissed it. Quote.

We are of the opinion that the proceedings in the state courts present no constitutional question which appellant has standing to assert. On June twenty third, nineteen sixty the FDA approved the first oral contraceptive. There's more about this in R. Nelson Pill Hearings episode from May of twenty twenty one. By this point, public opinion polls suggested that more than seventy percent of people in the United States thought information

about contraception should be legal. The introduction of oral contraceptives, which were in many ways more reliable and more convenient than other available methods of contraception, also added a renewed urgency to the effort to get Connecticut's law repealed. In nineteen sixty one, the US Supreme Court heard two cases related to Connecticut's anti contraception law. One was Trubeck versus. Ulman. Again,

that's the same Abraham Ullman as before. Louise and Dave Trubeck had gotten married in nineteen fifty eight while they were both students at Yale Law School. They wanted to have children. One day, they did not want to have children where they were both in law school, but it was illegal for their doctor to discuss contraception with them. The Truebach's case had originally been part of a group of other cases, but they elected not to remain anonymous

and their case was heard separately. The other case was Poe versus Ulman, and it involved an anonymous couple and an anonymous married woman. The couple were known as Pauline and Paul Poe. They had had three children, all of whom had multiple congenital illnesses and had died as newborns. They thought it was unlikely that they could have a child that would survive infancy, and they wanted to avoid future pregnant. The married woman was known as Jane Doe.

She had had a stroke while pregnant and her child had been stillborn. She was disabled following the stroke and it was unlikely that she could survive another pregnancy. These people all lived in Connecticut, where it was illegal for their doctors to discuss contraception with them. In a five to four ruling, the Supreme Court dismissed this case, finding that quote the records in these cases do not present

controversies justifying the adjudication of a constitutional issue. Justice Felix Frankfurter authored the opinion, which set, in part quote, this Court cannot be umpire to debates concerning harmless empty shadows. In other words, because Connecticut wasn't really enforcing this law very strictly anymore, it was harmless and empty in the eyes of the Court. Also, because none of these plaintiffs had been arrested or convicted of anything, there was no

injury for the court's need to remedy. The Court also dismissed Trubeck versus Ullman without further comment. As part of the same set of decisions. The dissenting justices in Poe versus Ullman all issued their own opinions, arguing, among other things, that people should not have to break the law to get basic health information and that there shouldn't need to be an arrest and conviction in order for the Court

to rule on whether a law was unconstitutional. The dissent by Justice William O. Douglas said, in part quote, what are these people, doctor and patience to do? Flout the law and go to prison, violate the law surreptitiously, and hope they will not get caught By today's decision. We leave them no other alternatives. It is not the choice they need have under the regime of the declaratory judgment and our constitutional system. It is not the choice worthy

of a civilized society. A sick wife, a concerned husband, a conscientious doctor seek a dignified, discreet, orderly answer to the critical problem confronting them. We should not turn them away and make them flout the law and get arrested to have their constitutional rights determined. So after this, it seemed like the Supreme Court would only be willing to examine Connecticut's law if somebody had been convicted of breaking it.

So immediately after the Court announced its decision on June nineteenth, nineteen sixty one, Estelle Griswold and Charles Lee Buxton decided it was time to get arrested. Griswold was executive director of the Planned Parenthood League of Connecticut. Buxton was its medical director, and Jane Doe and Pauline and Paul Poe

had been his patients. At this point, Planned Parenthood League of Connecticut had mostly been providing people with transportation to New York or Rhode Island, where contraception was legal, rather than directly providing contraception. But on June twentieth, nineteen sixty one, just a day after the Supreme Court disc decision, Griswold and Buxton announced that they would be opening a contraceptive

clinic in New Haven. The clinic opened on November first of that year, advertising its services specifically to married couples. They saw ten patients on the first day in operation, and they also held a press conference. Two days later, police stopped by and Griswold helpfully told them all about the work they were doing, the contraceptives they were providing, the counseling that was available to patients, the literature they had available, and the fact that they knew it was

all illegal. On June tenth, police returned with warrants for Griswald and Buxton's arrest, and the clinic was shut down. Griswald and Buxton stood trial, and their attorneys argued that counseling married couples on the use of contraception was protected free speech. The two were convicted and fined one hundred dollars each, and after a series of appeals, their case was before the US Supreme Court under Chief Justice Earl Warren. Warren Court has come up several times on the show.

Earl Warren was Chief Justice when Loving versus Virginia, Brown versus Board of Education, and Hernandez versus Texas were all decided. He was also Chief Justice during Yates versus United States, which we talked about in our episode on co Intel Pro. We've also talked about his time as Governor of California on a couple of episodes, including our two parter on Executive Order ninety sixty six and the mass incarceration of

Japanese Americans during World War Two. We will get to the Court's decision after we pause for a sponsor break. On June seventh, nineteen sixty five, and a seven to two ruling, the US Supreme Court issued its decision in Griswold versus Connecticut, and it overturned Connecticut's anti contraception laws. The justices who were part of the court authored multiple opinions in this case. Justice William O. Douglas, who had authored one of the descents in Poe versus Ullman, which

we read earlier, authored the majority opinion. Justice Arthur Goldberg wrote a concurring opinion that was joined by Justice William J. Brennan Junior and Chief Justice Warren, Justices John M. Harland the Second and Byron White each issued their own concurring opinions, and then Justices Hugo. Black and Potter Stewart dissented, as they had also done in Poe versus Ullman, and each

of them wrote their own descents. The court found that one Griswold and Buxton did have standing in this matter, something that had been an issue in those earlier cases, and the court also found that quote the Connecticut Statute forbidding use of contraceptives violates the right of marital privacy, which is within the p number of specific guarantees of the Bill of Rights. So the easy part with that is that the court found Connecticut's ban on contraousives to

be unconstitutional. But the rest of it is a little trickier because a right to marital privacy isn't mentioned or enumerated in the Constitution. Like we set up at the very top of the show, substantive due process is the idea that the courts can protect unenumerated rights, and in Griswold versus Connecticut, the Court was arguing that the right to privacy was found in the penumbra or the shadow

of other rights that are mentioned. The majority opinion referenced a series of previous cases in which protected rights were interpreted as being broader than what was spelled out in the Constitution. For example, in Meyer versus State of Nebraska, the Court had struck down a law mandating that children

be taught only in English through the eighth grade. The court found that this violated the due process clause of the Fourteenth Amendment, which says that no state shall quote deprive any person of life, liberty, or property without due

process of law. In this case, a teacher in a Lutheran school was teaching reading in German, and the court found that even though the Fourteenth Amendment didn't reference things like languages other than English, quote, his right thus to teach, and the right of parents to engage him so to instruct their children, we think are within the liberty of the Amendment. The majority opinion in Griswold versus Connecticut then ticked through a series of similar cases and their associated freedoms.

Like in earlier cases, the court had found that the First Amendment protection of free speech also included the right to read and to receive information. The court had also described the First Amendment freedom to assemble as extending to the freedom of association with other people. So assembly did not just mean physically going to a meeting. It also involved being affiliated with a group and expressing personal philosophies through being a member of that group. Having been through

all of that, the major already opinion read quote. The foregoing cases suggest that specific guarantees in the Bill of Rights have p numbers formed by emanations from those guarantees that help give them life and substance. Various guarantees create zones of privacy. The right of association contained in the penumber of the First Amendment is one, as we have seen.

The Third Amendment, in its prohibition against the quartering of soldiers in any house in time of peace without the consent of the owner, is another facet of that privacy. The Fourth Amendment explicitly affirms the right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures. The Fifth Amendment, in its self incrimination clause, enables the citizens to create a zone of privacy which government may not force him to surrender

to his detriment. The Ninth Amendment provides the enumeration in the Constitution of certain rights shall not be construed to deny or disparage others retained by the people. Yeah, that last one basically means just because a specific right is not mentioned in the Constitution, that doesn't mean that right doesn't exist, like not saying every single right on the planet has to be specifically named or it's not a

real thing. This decision went on to build the idea of a zone of privacy that was specifically related to a marital relationship. Quote. The present case then concerns a relationship lying within the zone of privacy created by several fundamental constitutional guarantees, And it concerns a law which, in forbidding the use of contraceptives, rather than regulating their manufacture or sale, seeks to achieve its goals by means having

a maximum destructive impact upon that relationship. It went on to rhetorically ask, quote, would we allow the police to search the sacred precincts of marital bedrooms for tell tale signs of the use of contraceptives? The very idea is repulsive to the notions of privacy surrounding the marriage relationship. So all those various concurring opinions agreed with the idea that the right to privacy could be inferred from some part of the Constitution. They just all differed a little

bit on exactly how or where. And then the two dissenting justices made it clear that they did not like this law either, even though they didn't find that there was a constitutional reason to overturn it. Justice Hugo. Black's read in part quote, I feel constrained to add that the law is every bit as offensive to me as it is to my brethren of the majority, and my brothers Harlan White and Goldberg, who, reciting reasons why it

is offensive to them, hold it unconstitutional. Justice Potter Stewart wrote in his dissent quote, I think this is an uncommonly silly law. As a practical matter, the law is obviously unenforceable except in the oblique context of the present case. It's a philosophical matter. I believe the use of contraceptives in the relationship of marriage should be left to personal and private choice based upon each individual's moral, ethical, and

religious beliefs. As a matter of social policy, I think professional counsel about methods of birth control should be available to all, so that each individual's choice can be meaningfully made. But we are not asked in this case to say whether we think this law is unwise or even asinine. We are asked to hold that it violates the United

States Constitution, and that I cannot do. The majority, though, had found that it violated the Constitution, and by finding Connecticut's anti contraception law unconstitutional, the Supreme Court made contraception and contraceptive counseling legal nationwide in the context of married couples. So this also struck down the anti contraception language in the Comstock Act, which was still on the books. So this was a victory in terms of access to contraception,

but it was definitely incomplete. Number One, it applied only to married couples. The focus was on the idea that privacy was intrinsic to a married relationship, so laws forbidding contraceptive use or counseling for single people were unaffected. Number two, This idea that there were p numbers creating zones of privacy was immediately controversial. There were and continue to be legal scholars who argue that this isn't really a thing, and that this was faulty reasoning on the part of

the justices. Beyond that, there were people, particularly women's rights activists, who raised concerns about this ruling's focus. There is no constitutional guarantee of equal rights for women in the United States, and at this point, the Equal Rights Amendment had not yet been passed by Congress. As we discussed in our

previous episode on the Equal Rights Amendment. Even though Congress did did eventually pass it, not enough states ratified it by the deadline for it to become part of the Constitution. So there were a lot of women in particular who thought that the Court should have used a different reasoning, like maybe one that interpreted the Fourteenth Amendment's equal Protection and do process clauses as protecting a woman's right to

bodily autonomy. We recognize that not everyone who can get pregnant is a woman, including transmen and non binary people, and that there were also plenty of people living at the time who were living outside the gender binary in various ways, But really the focus of the response to this in nineteen sixty five was on women. During research for this episode, Tracy read a paper in the American

Historical Review. This suggested that this privacy angle might have been influenced by the Wolfenden Report, which was published in the UK in nineteen fifty seven. This report followed a rise in convictions for breaking laws against homosexual behavior, including convictions of some high profile men. A committee was formed to investigate UK laws around homosexuality and sex work, and

it recommended decriminalization of homosexuality. In the words of that report, their quote must remain a realm of private morality and immorality, which is, in brief and crude terms, not the law's business. But if this idea influenced the thought process of the justices in Griswold versus Connecticut, it didn't make its way into Supreme Court decisions about same sex relationships until much later.

As we said at the top of the show, the Supreme Court decision in Griswold versus Connecticut and the reasoning that was used to make that decision have become part of a lot of other cases. In nineteen sixty nine, the Supreme Court cited Griswald be Connecticut and its decision in Stanley versus Georgia, which found that possession of obscene materials was protected in part because of a right deprivacy. In nineteen seventy two, the Court struck down a Massachusetts

law banning the distribution of contraceptives to unmarried people. Although the question before the court was whether this law violated the privacy standard established in Griswold versus Connecticut, the Court found that it violated the Fourteenth Amendment Due process clause.

In nineteen seventy three, the Court issued its decision in Roe versus Wade, finding the right to privacy established in Griswold as being inherent in the due process clause of the Fourteenth Amendment and also extending to a person's decision to terminate a pregnancy. But the Court also ruled that this right had to be balanced out with other concerns related to protecting a person's health and to quote, the

potentiality of human life. In nineteen eighty six, the Supreme Court cited Griswold versus Connecticut in its ruling in Bowers versus Hardwick, which upheld a Georgia law banning sodomy. Although attorneys had argued that sodomy was protected under the right to privacy that was established in Griswold, the court disagreed. This ruling was overturned in two thousand and three in Lawrence versus Texas, which was related to both the right to privacy and to the due process clause of the

Fourteenth Amendment. In twenty fifteen, the Court once again issued a ruling that was partly underpinned by Griswold versus Connecticut, and that was Obergefell versus Hodges. This decision recognized same sex marriages as legal nationwide, and it cited Griswold at several points, including the decision's description of marriage as a right that's older than the Bill of Rights. And most recently, the Court issued its decision in Dobbs versus Jackson Women's

Health Organization, overturning Roe v. Wade. This decision also overturned Planned Parenthood v. Casey, in which the Court had upheld Roe v. Wade and a constitutional right to abortion in nineteen ninety two. The Court's opinion, written by Justice Samuel Alito, noted that the Constitution makes no mention of abortion, something also true of the right place to privacy established in

Griswold versus Connecticut. But in the Court's opinion, Roe versus Wade was different from Griswold versus Connecticut because it did not involve quote, the destruction of what Roe called potential life. So the majority opinion in this case noted the connection

to several cases we just mentioned. There was Griswold, there was Eisenstadt versus Baird, which is the one that overturned the Massachusetts law barring contraception for unmarried people, and also Obergefell, calling the fear that the Dobbs decision would apply to

those rulings as quote unfounded. But as we said at the top of the show, in his concurring opinion, Clarence Thomas wrote that future cases should reconsider rulings that have relied on substantive due process, including Griswold, Lawrence, and Obergefell. So that suggests otherwise that is Griswold versus Connecticut, which, as I said of the tapish d working my way through all that made it a lot easier for me to understand what the logic had been behind the ruling

in Roe versus Weights. Thanks so much for joining us on this Saturday. Since this episode is out of the archive, if you heard an email address or a Facebook RL or something similar over the course of the show, that could be obsolete. Now our current email address is history podcast at iHeartRadio dot com. You can find us all over social media at Missed History, and you can subscribe to our show on Apple podcasts, Google podcasts, the iHeartRadio app,

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