Basically, as legal scholar Bernadette Meyler writes, Alito is ignoring the earlier history from the eighteenth century that the Roe Court weighed. Instead, he selectively turns to common-law tradition from the mid-nineteenth century, when the Fourteenth Amendment was ratified. Put simply, he is cherry-picking “the most restrictive history as the main backdrop for his opinion” to further particular ideological goals. Meyler continues: “To put the logic of Alito’s opinion in perspective, if we were to go back to the common law generally as determining the scope of liberty interests around personal autonomy, we would probably roll back the constitutional protections announced for consensual sodomy in Lawrence v. Texas (2003) as well as same-sex marriage. Furthermore, we would return to many other conditions that we would abhor today, including coverture, or the rule that the legal rights of a married woman were subsumed to those of her husband.”