to privacy" inferred from the Fourteenth Amendment, a reasoning that some critics argued was circuitous, and the case was overturned by Dobbs v. Jackson (2022). Legal scholars, justices, and presidential candidates have criticized the Roe decision. The progressive Brown v. Board of Education decision banning racial segregation in public schools has been criticized by conservatives such as Patrick Buchanan, former associate justice nominee and solicitor general Robert Bork and former presidential contender Barry Goldwater. More recently, Citizens United v. Federal Election Commission was criticized for expanding upon the precedent in First National Bank of Boston v. Bellotti (1978) that the First Amendment applies to corporations President Abraham Lincoln warned, referring to the Dred Scott decision, that if government policy became "irrevocably fixed by decisions of the Supreme Court... the people will have ceased to be their own rulers." Former justice Thurgood Marshall justified judicial activism with these words: "You do what you think is right and let the law catch up." During different historical periods, the court has leaned in different directions. Critics from both sides complain that activist judges abandon the Constitution and substitute their own views instead. Critics include writers such as Andrew Napolitano, Phyllis Schlafly, Mark R. Levin, Mark I. Sutherland, and James MacGregor Burns. Past presidents from both parties have attacked judicial activism, including Franklin D. Roosevelt, Richard Nixon, and Ronald Reagan. Failed Supreme Court nominee Robert Bork wrote: "What judges have wrought is a coup d'état,– slow-moving and genteel, but a coup d'état nonetheless." Brian Leiter wrote that "Given the complexity of the law and the complexity involved in saying what really happened in a given dispute, all judges, and especially those on the Supreme Court, often have to exercise a quasi-legislative power," and "Supreme Court nominations are controversial because the court is a super-legislature, and because its moral and political judgments are controversial." Judicial interference in political disputes Some Court decisions have been criticized for injecting the court into the political arena, and deciding questions that are the purview of the other two branches of government. The Bush v. Gore decision, in which the Supreme Court intervened in the 2000 presidential election and effectively chose George W. Bush over Al Gore, has been criticized extensively, particularly by liberals. Another example are Court decisions on apportionment and re-districting: in Baker v. Carr, the court decided it could rule on apportionment questions; Justice Frankfurter in a