Even after he leaves the Court, a Justice remains part of the orchestra. Those who succeed him may not copy his style, but often play within the same melodic and rhythmic structures. Justice Blackmun himself, over the course of preparing his Roe and Doe opinions, eventually fell into the structures put in place in cases ranging from Union Pacific Railway Co. v. Botsford to Stanley v. Georgia. The Justices he left behind did much the same with Roe and, more significantly, Bowers. The Court's decision in Planned Parenthood of Southeastern Pennsylvania v. Casey represented a partial "victory" for Justice Blackmun, because it preserved the conceptual nub of the Roe right to abortion. However, Justice Blackmun's real victory came when Justices O'Connor, Kennedy, and Souter embraced the broader outlines of the privacy right implicitly in Romer v. Evans and explicitly in Lawrence v. Texas. In the hardest of senses - in the sense that a legacy is something that outlasts its creator - Justice Blackmun's greatest legacy in this area of law is not the elaborated abortion right coined in Roe, but the fuller conception of personal autonomy in Bowers.

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