evidence: What Would It Mean to Codify Roe Into Law? [...] What Does It Mean to Codify Roe v. Wade? [...] Without eliminating the filibuster, which would require 50 votes in the Senate, the bill is unlikely to pass. However, after Dobbs was announced, Democratic Sen. Joe Manchin—who opposes eliminating the filibuster—issued a statement that he supported a bipartisan effort to "put forward" legislation to "codify the rights Roe v. Wade previously protected."