As the Supreme Court was inaccurate and biased with its interpretation of English common law, it also did not obtain the correct view of early American law. According to the official case document, most restrictive abortion legislation began appearing after the Civil War and was only for the purpose of protecting the interests and health of the mother. For evidence of the first claim, the Court mentioned Eugene Quay, who had written an appendix of all the abortion legislation passed before 1960. Interestingly enough, the very proof that the Courts recommended for their position was the thing that disproved their assertion, as Quay had on record that thirty-one of the states had laws punishing abortive practices before the Civil War even started.* This was not the scarce minority of laws that the Court had claimed existed prior to 1860. With regard to the second claim, that the laws enacted were solely for the protection of the woman, this too is easily refuted by the fact that the evidence the Court cited works against such claims. For example, one of the cases the Court used was an 1858 New Jersey case, State v. Murphy, which has a passage that reads “the procuring of an abortion, or an attempt to procure an abortion, with the assent of the woman, was not an indictable offense, as it affected her, but only as it affected the life of the fetus”.* This passage clearly demonstrates that the protection of the mother was not the only legitimate interest at stake, but, yet, this was the case the Court cited as evidence that American law of the 18th century did not protect the interests of the unborn child. One must therefore conclude that the Court purposely flipped critical information on early American law and relied on a mass of legal language to keep the real truth from emerging.