prolonged as those experienced for most of 2020", and called the pandemic "a Constitutional stress test". According to The New Yorker, since the 2020 appointment of Justice Amy Coney Barrett, Alito has become "the embodiment of a conservative majority that is ambitious and extreme", overruling progressive precedents from the 1960s and '70s that were previously out of conservatives' reach. Abortion In 2003, Congress passed the Partial-Birth Abortion Ban Act, which led to a lawsuit in the case of Gonzales v. Carhart. The Court had previously ruled in Stenberg v. Carhart that a state's ban on partial birth abortion was unconstitutional because such a ban did not have an exception in the case of a threat to the health of the mother. The membership of the Court changed after Stenberg, with Roberts and Alito replacing Rehnquist (a dissenter in Roe) and O'Connor (a supporter of Roe) respectively. Further, the ban at issue in Gonzales v. Carhart was a federal statute, rather than a state statute as in the Stenberg case. On April 18, 2007, the Supreme Court handed down a decision ruling the Partial-Birth Abortion Ban Act constitutional. Justice Anthony Kennedy wrote for the five-justice majority that Congress was within its power to generally ban the procedure, although the Court left open the door for as-applied challenges. Kennedy said that the challenged statute was consistent with the Court's prior decisions in Roe v. Wade, Planned Parenthood v. Casey, and Stenberg v. Carhart. Alito joined fully in the majority, as did Roberts. Thomas filed a concurring opinion, joined by Scalia, contending that the Court's prior decisions in Roe v. Wade and Planned Parenthood v. Casey should be reversed, and also noting that the Partial-Birth Abortion Ban Act may exceed the powers of Congress under the Commerce Clause. Alito, Roberts, and Kennedy did not join that assertion. Justices Ginsburg, Souter, Breyer, and Stevens dissented, contending that the ruling ignored Supreme Court abortion precedent. On May 2, 2022, Politico published a leak of a first draft of a majority opinion by Alito that circulated among the justices in February 2022 for the upcoming decision in Dobbs v. Jackson Women's Health Organization. The opinion would overturn Roe v. Wade and Planned Parenthood v. Casey, and would likely either severely restrict access to abortion or make it completely illegal in states with trigger laws. On June 24, 2022, the ruling was handed down. It was mostly