gives almost no sense of an obligation to try to be.The Wages of Crying Wolf projected a profound influence over legal opinions concerning Roe, with the article eventually becoming the third most-cited work in the history of The Yale Law Journal according to a 1991 study by Fred R. Shapiro. In a 2022 piece for The New York Times, Emily Bazelon described it as having "eviscerated Blackmun's opinion," with Linda Greenhouse stating that Ely "sent Roe into the world disabled...It really was very damaging. Not because the American public cared about doctrine—they cared about results—but because it left Roe without friends in high places." When the Supreme Court overruled Roe in Dobbs v. Jackson Women's Health Organization, Justice Samuel Alito cited Wages as an example of the academic criticism it faced. Democracy and Distrust While a professor at Harvard, Ely produced his most notable work: a book titled Democracy and Distrust: A Theory of Judicial Review published in 1980. The text would become one of the most influential works about American constitutional law, and among the most praised for deconstructing—and defending—the doctrine of judicial review on procedural grounds. Democracy and Distrust rejected theories which had no basis in the constitutional "text, history, or structure", using political theory as opposed to originalism to serve as argumentative foundations. The book may be effectively divided as two separate books: one criticizing constitutionally ungrounded legal theories, and the other as Ely providing his own theory for judicial interventions. Ely expounds a theory of constitutional interpretation known as political process theory, suggesting that judges ought to focus on maintaining a well-functioning democratic process and guard against systematic biases in the legislative process. Ely asserts that the Supreme Court should interpret the Constitution so as to reinforce democratic processes and popular self-government by ensuring equal representation in the political process (as in the Court's decision in Baker v. Carr). He argues that the Constitution's unenumerated rights (such as the Ninth Amendment and the Privileges or Immunities Clause of the Fourteenth Amendment) are procedural in nature, rather than substantive, and thus protect rights to democratic processes but are not rights of a substantive nature. Justice Stone's Footnote Four from United States v. Carolene Products Co. (1938) is a chief inspiration for Ely's theory of judicial review. The initial release of Democracy and Distrust was controversial; it received a large amount of criticism from academics, including a dismissive