Professor Collett’s article applies the concept of judicial modesty to the constitutional jurisprudence of abortion. Her article begins with a criticism of the Roe decision’s lack of constitutional reasoning and then examines the application, and arguable expansion, of Roe’s flawed reasoning to subsequent abortion cases. The article further examines the most recent abortion cases since the confirmation of Chief Justice Roberts, concluding that while a judicially modest approach to the abortion issue will result in less successful challenges to abortion regulation, an overturning of Roe v. Wade remains unlikely.