[RobbyS]

Trying to abide by a O'Connor precedent was hard. That's why she didn't try to do it herself.

[Lexinom]

How true, how true! Alito himself admitted to great mental extertion in penning his disent in Casey because he did not understand O'Connor's "undue burden" criteria - so distinct from the more traditional "liberty interest" vs. "fundamental right" bifurcation.