As always, you can find the Dobbs v. Jackson decision here.

Paragraph 5 of 11

Sentence 3 of 4

The next sentence contains one claim:

“An internal memorandum characterized this author’s work as donning ‘the guise of impartial scholarship while advancing the proper ideological goals.’39”

This is the revelation from the last sentence, I guess. End note 39 should point us to the appropriate materials.

End note 39:

“Garrow 500–501, and n. 41 (internal quotation marks omitted).”

Maybe I can check into this some day when I have access to Garrow’s book. But for now, this is undetermined:

• “An internal memorandum characterized this author’s work as donning ‘the guise of impartial scholarship while advancing the proper ideological goals.’”