Poe V. Ullman - Impact

Impact

Justice Harlan's general view has had enormous influence on the modern Supreme Court; Justice David Souter endorsed the general reasoning behind Justice Harlan's test in his concurrence in 1997's Washington v. Glucksberg. Souter wrote that Harlan's dissent used substantive due process, and recent cases demonstrated the "legitimacy of the modern justification" for that approach.

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