evidence: Circumscribing the power of all branches of government at all levels might be thought to correspondingly increase the freedom of individuals, who are less subject to government regulation. In fact, however, with the exception of a few favored areas where the Court created new rights — the right to carry guns in public80 and the right of government officials to pray at public events81 — the Court’s recent history has been one of withdrawing rights from the public. Most famously, it eliminated the right to reproductive freedom, giving states the power to compel birth.82 It has also effectively eliminated the power of federal courts to enforce the right to vote, announcing that it was withdrawing from efforts to protect the right to vote against partisan gerrymandering a few years back83 and following up by affirmatively preventing federal and possibly even state courts from blocking concededly discriminatory gerrymandering schemes.84 And it declared that one of the most famous rights given to criminal defendants — the Miranda warning — was not in fact a right at all that citizens could enforce, but just a prophylactic rule that the Court might change at any time.85 At least one Justice signaled his desire to go further by rolling back protections for marriage equality and contraception access.86