The Anti-Constitutionality of the Deeply Rooted Test in

Dobbs v. Jackson

Reginald Oh*

Introduction

What is the future of fundamental rights after the U.S.

Supreme Court in Dobbs v. Jackson1 held that the right to
terminate a pregnancy is no longer a fundamental right? If
Justice Samuel Alito is to be believed, his majority opinion
leaves other fundamental rights like the right to use
contraceptives and the right to same-sex marriage intact.

People who are concerned that more fundamental rights are in

jeopardy have justifiable fears, because Alito’s analysis in
Dobbs thoroughly undercuts his words of comfort. The logic
of Alito’s opinion applies in full force to rights to
contraception, interracial marriage, and same-sex marriage. If
logic and consistency have any basis for how a court rules,
then the logic of Dobbs compels the outcome that Thomas
desires—the end of the fundamental rights doctrine.

Ultimately, all Justices should reject Alito’s deeply rooted

analysis because it has no legitimate constitutional basis. It is
anti-constitutional because it subverts and alters the
fundamental nature of the Constitution as an integrated,
unified whole.

Alan Miles and Betty Rubin Professor of Law, Cleveland State

*

University College of Law.

1
Dobbs v. Jackson Women’s Health Org., 142 S. Ct. 2228, 2242
(2022).

1
II. The Dobbs Fundamental Rights Analysis

Alito begins his fundamental rights analysis simply enough

by noting that, to determine whether a right is fundamental,
“the Court has long asked whether the right is ‘deeply rooted
in [our] history and tradition’ and whether it is essential to our
Nation’s ‘scheme of ordered liberty.’”2

a. Alito’s First Move: Reducing Deeply Rooted

Analysis to the Counting of State Laws in 1868

For Alito, there is only one point in time that truly matters-
1868, the year that the Fourteenth Amendment was ratified. 3
Alito emphasizes that “how the States regulated abortion
when the Fourteenth Amendment was adopted” is “the most
important historical fact” for deeply rooted analysis.4

What I call Alito’s deeply rooted in 1868 test has two simple
steps. First, conduct historical-legal research and find out how
each state in 1868 regulated a liberty like abortion.5

The second step in the “analysis” requires the Court to count

how many states in 1868 protected the right and how many
restricted it.6 Alito does the math and states, “By 1868, the
year when the Fourteenth Amendment was ratified, three-
2
Id. at 2246 (quoting Timbs v. Indiana, 139 U.S. 682, 687
(2019)).
3
UNITED STATES SENATE, LANDMARK LEGISLATION: THE
FOURTEENTH AMENDMENT, https://www.senate.gov/about/origins-
foundations/senate-and-constitution/14th-amendment.htm (last
visited Aug. 8, 2023).
4
Dobbs, 142 S. Ct. at 2267 (emphasis added).
5
Id.

2
quarters of the States, 28 out of 37, had enacted statues
making abortion a crime. . . . .”7 Alito then declares that the
75% figure reflects an “overwhelming consensus of state
laws” rejecting abortion as a right.8

b. The Implications of Dobbs for Substantive

Due Process Doctrine

Alito takes pain to emphasize that nothing in his opinion

threatens fundamental rights like the right to same-sex
marriage. However, if logic and consistency have any basis
for how the Court decides cases, then the doctrine of
fundamental rights may be nearing its end.

III. Constitutional Interpretation & the Integrated

Constitution

In McCulloch, there were two issues raised by a constitutional

challenge to the National Bank of the United States.9

The first issue was whether Congress had the power to create
a national bank in the first place.10

If Congress did have that power, the second issue was

whether states could tax the national bank.11

6
Id. at 2285.
7
Id. at 2252–53.
8
Id. at 2267.
9
Id. at 400.
10
Id. at 401.
11
Id. at 425.

3
 a. The Constitution as a Great Outline

What does it mean for a constitution to be an outline? In

explaining the fundamental nature of the Constitution, he
asserts that it has “only its great outlines. . .marked, its
important objects designated, and the minor ingredients
which compose those be deduced from the nature of the
objects themselves.”12

The Constitution as a Great Outline has two elements.

First, it is a logically organized set of general principles. As

an outline, the Constitution is organized as main parts, sub-
parts, and sub-sub-parts. The main parts are the seven articles,
several of which are sub-divided into topical sections (sub-
parts) consisting of numbered clauses (sub-sub-parts).

The second element of the Great Outline is that it excludes or

omits secondary principles or details, what Marshall calls
“minor ingredients.”13 The Constitution is intentionally
designed not to be comprehensive and detailed.

The Constitution as Great outline of general principles

functions as a whole to establish an effective, flexible
governmental system designed to adapt to changing
circumstances over time.

For Marshall, the design of the Constitution as a Great

Outline is what enables it to endure over time. Moreover, it
establishes a system of government and provides it with the

12
McCulloch, 17 U.S. at 407 (emphasis added).
13
Outline, MERRIAM-WEBSTER, https://www.merriam-
webster.com/dictionary/outline (last visited Aug. 8, 2023).

4
flexibility it needs to adapt to changing circumstances and act
effectively to promote the general welfare of the people.14

A Constitution Cannot be a Legal Code; A Legal Code is

not a Constitution

Marshall contrasts the Constitution as a Great Outline from a

constitution written and organized as a legal code. A legal
code is the polar opposite of an outline. Instead of consisting
of broad principles with the lesser details omitted, a legal
code is a comprehensive, highly detailed body of law.15

Marshall states that a constitution to spell out “an accurate

detail of all” aspects of a system of government “could
scarcely be embraced by the human mind.”16

2. The Constitution as an Integrated System

In addition to being organized as an outline, the Integrated

Constitution functions as a system. A system is a set of
interconnected components that combine together as an
integrated whole.17 The key elements of a system are:

(1) components that are

(2) interconnected,

(3) combine or work together

14
Id. at 415.
15
Code, BLACK'S LAW DICTIONARY (11th ed. 2019).
16
Id. at 407.
17
See https://www.vocabulary.com/dictionary/system

5
(4) as an integrated whole. A system typically is designed to
perform certain functions.

A simple example of a system is a car. A car is set of

interconnected components designed to work together as an
integrated whole. As an integrated whole, a car functions as a
vehicle. A system is often comprised of components that also
operate as a system. A car engine, for example, is itself a
system, which also is comprised of components that operate
as a system.

Guidelines for Great Outline Constitutional

Interpretation

He states that any constitutional question needs to be

answered based on a “fair construction” of the Constitution as
a [UNIFIED/INTEGRATED whole.18 That means two things.

First, a fair construction of the whole Constitution as a Great

Outline of logically organized general principles. A fair
construction of the whole requires interpretive choices that
are consistent with the Constitution as an integrated system of
logically organized principles.

Second, in interpreting the Integrated Constitution, the words,

clauses, sections, and articles must not be treated as discrete
and isolated provisions, but interconnected and meant to work
together to create and function as an integrated whole/system.

Third, a fair construction of the Constitution as a unified

system requires making interpretive choices that promote
rather than disrupt the smooth functioning of the system and
its interconnected parts.
18
Id. at 406 (emphasis added).

6
Fourth-never interpret the Constitution as a fixed legal code.

Application – Interpreting the NP Clause

Marshall, however, suggested that “necessary” could mean

useful or convenient.19 If necessary means useful, then
Congress would have the power to create a national bank as
long it was useful or expedient for regulating interstate
commerce, an easier standard to meet compared to a standard
in which necessary means indispensable.

First, Marshall sought to determine if the broad interpretation

is logically consistent with the Constitution as a Great
Outline. A key inquiry in making that determination is to
ascertain where the clause is located within the Constitution.
The Necessary and Proper Clause is located in Article I,
Section 8 of the Constitution, the section which includes
Congress’ enumerated powers.20

Each of the first seventeen clauses enumerate broad powers

using broad language, consistent with Congress’ plenary
authority over how it exercises each enumerated power.

Specifically, the restrictive reading would render the

Necessary and Proper Clause an anomaly in Section it
because it would function as a de facto limitation on
Congressional power, rather than as a grant of power.

Because the Necessary and Proper Clause is intertwined

with each and every enumerated power in Section 8. The
clause is triggered only in conjunction with one of the

19
Id.
20
Id. at 418–19.

7
enumerated powers. So, if the restrictive term acts as a
limitation on implied powers, then it acts as a limitation on
each and every enumerated power in Section 8 as well.

Accordingly, by stripping plenary power out of the Necessary

and Proper Clause, the restrictive reading would effectively
strip plenary power out of all the other enumerated powers as
well.

8
IV. The Dobbs Deeply Rooted Test Subverts the
Integrated Constitution

It bears repeating that the deeply rooted test is supposed

to be a method for interpreting the text of Section 1 of the
Fourteenth Amendment, not just the Due Process Clause.

a. Dobbs’ Use of History Subverts the Fourteenth

Amendment’s Unified Function as a Federal
Check on State Power

The Fourteenth Amendment is logically organized as an

outline of mostly broad principles. It consists of 5 sections,
with each section containing clauses group together based on
the central theme of each section. Collectively, the five
sections are interconnected and work together to serve the
central function and purpose of the Integrated Fourteenth
Amendment.

Section 1 of the Fourteenth Amendment is comprised of

enumerated rights. There are four clauses in Section 1
separated by semi-colons.21 Of the four, three of them are
relevant for purposes of this Article. The first is the Due
Process Clause, which protects persons from deprivations of
liberty by the state without due process of law. 22 The second
is the Equal Protection Clause, which provide persons with
equal protection of the laws.23 The third is the Privileges or
Immunities Clause, which protects the fundamental rights of
U.S. citizens.24

21
U.S. CONST. amend. XIV, § 1.
22
Id.
23
Id.

9
Section 5 of the Fourteenth Amendment grants Congress an
enumerated power to enforce Sections 1-4.

The Fourteenth Amendment amounts to a federal check on

state abuse of power.

But the deeply rooted in 1868 test effectively gives states the
power to check their own power. To determine if the Due
Process Clause checks states from exercising its police power,
Alito’s test gives states the authority to determine if state
power should be checked.

In effect, Alito’s test gives back to the states the power that
Fourteenth Amendment took away from them—the plenary
police power to enact laws restricting liberty.

Moreover, giving the states of 1868 the power to define the

meaning of the Due Process Clause makes little sense given
that they enacted their laws without federal due process
principles guiding them.25

The Fourteenth Amendment did not exist when most of the

laws in existence in 1868 were enacted, which means none of
those laws in 1868 were informed by federal due process
concerns.

b. Dobbs’ Due Process Deeply Rooted Test Conflicts

with the Equal Protection Deeply Rooted Test

24
Id.
25
Calabresi & Vickery, supra note 144, at 1299, 1323.

10
Under equal protection suspect class doctrine, laws that
discriminate against a suspect class are presumed to be
unconstitutional and subject to heightened judicial scrutiny. 26
Suspect classes are politically vulnerable groups subject to
prejudice who need special judicial protection from the
majoritarian political process.

In Frontiero v. Richardson,27 the Court held that women are a

suspect class. The case dealt with a Fifth Amendment equal
protection challenge to a United States military policy
discriminating against women servicemembers with respect
to employee benefits.28

But, the Court’s most in depth explanation for why women

are a suspect class centered on history.29 Specifically, the
long, “firmly rooted” history of invidious discrimination
against women in America going back to the 19th century.30
The Court asserts that “throughout much of the 19th century,”
women were relegated to a position of inferiority
“comparable to that of blacks under the pre-Civil War slave
codes.”31

For the Frontiero Court, the systematic and pervasive

discriminatory treatment of women by virtually all states in
26
Richard H. Fallon, Jr., Strict Judicial Scrutiny, 54 UCLA L.
REV. 1267, 1268, 1276, 1319 (2007) (examining different suspect
classes and strict scrutiny).
27
Frontiero v. Richardson, 411 U.S. 677, 682 (1973).
28
Id. at 680.
29
Id. at 684–85, 687–88.
30
Id. at 684.
31
Id. at 685.

11
the 19th century flowed from a deeply sexist, paternalistic
attitude.32

That sexist attitude was so pervasive that it became “firmly

rooted in our national consciousness.”33

The Frontiero Court used the deeply rooted history of gender

discrimination in 1868 to justify the systematic, permanent
restriction of state power under the Equal Protection Clause.

On the other hand, the Dobbs Court used the deeply rooted
history of laws restricting women’s reproductive autonomy to
protect state power under the Due Process Clause. Virtually
the same history was used to justify opposing outcomes.

Logically, why wouldn’t the Dobbs Deeply Rooted in History

approach also apply to interpreting Equal Protection?

If the Frontiero Court used the Dobbs deeply rooted in 1868

test, it would have had to conclude that, because the vast
majority of states in 1868 discriminated against women in a
multitude of ways, then gender discrimination is deeply
rooted in history and states are free to discriminate against
women today.

Penalties for miscegenation arose as an incident to slavery

and have been common in Virginia since the colonial
period.”34 Thus, because bans on interracial marriage are
deeply rooted in history going back to slavery and 1868, it
should be permitted?

32
Id. at 684.
33
Id. (emphasis added).
34
Id. at 6.

12
Nonsensical?

Plessy v. Ferguson logic-racial segregation deeply rooted in

history even in 1868

Defendants in Brown v. Board of Education-argued that racial

segregation in schools doesn’t violate EP because it was
deeply rooted in 1868.

13
c. LOVING’s UNIFIED APPROACH consistent with
the Great Outline and the Integrated Constitution and
14th Amendment

Interpreted EP and DP based on the central unifying principle

underlying the entire Fourteenth Amendment-EQUALITY.

It declared that a ban on interracial marriage is “directly

subversive of the principle of equality at the heart of the
Fourteenth Amendment,”35 and for that reason, the ban
violates the fundamental due process right to interracial
marriage.

In short, the Loving Court analyzed the due process issue in

light a fair construction of the Fourteenth Amendment as a
whole.

Consistent with that unified approach, the Court used the

deeply rooted history and tradition of White Supremacy to
treat due process and equal protection as interconnected parts
that must function in conjunction to promote equality.

35
Id. (emphasis added).

14
 d. Alito’s Deeply Rooted Test is anti-
constitutional because it subverts federal supremacy.

1. Alito’s Test Makes State Laws of 1868

the Supreme Law of the Land

The Supremacy Clause in Article VI of the Constitution

states, “The Constitution, and the law of the United States
which shall be made in pursuance thereof…shall be the
supreme law of the land.”36 If there is a conflict between state
law and the Constitution and/or federal law, the Constitution
overrides and disables state law.37

In McCulloch, Marshall concluded that if states have the

power to tax the federal government, it would transfer
supremacy from the federal government to the states. States
with the power to tax one part of the federal government, like
the national bank, would mean the power to tax any part of
the federal government.38 States would be able to tax the U.S.
Postal Service, the federal courts, the Environmental
Protection Agency, the FBI, and every other department,
agency, and branch of the federal government.39

With the blanket power to tax all aspects of the federal

government, states could use that power to obstruct any
federal policy it opposed.

36
U.S. CONST. art. VI, cl. 2.
37
See McCulloch, 17 U.S. at 406.
38
Id. at 431.
39
See id. at 432.

15
Given the power to tax the federal government, Marshall
reasoned that states could change “totally the character” 40 of
the Constitution as a whole by “transfer[ing] supremacy . . .
to the States.”41

Similarly, the Alito deeply rooted test subverts federal

supremacy in a manner arguably more subversive than states
having the power to tax the federal government. The Alito
test does not merely give states supremacy over federal
statutes. The test makes a handful of state laws in 1868
supreme over the Constitution itself.

Specifically, the Alito deeply rooted test empowers a majority

of the 37 states in 1868 to interpret the meaning of the
Fourteenth Amendment Due Process Clause.

In Dobbs, the laws of 28 states in 1868 determined the

meaning of the Due Process Clause, giving 50 states in 2022
virtual plenary power to restrict abortion.

The Alito deeply rooted test functionally transfers to a

majority of states in 1868 the supreme power to define the
scope of the constitutional limits on state power. State laws
enacted by state legislatures before and up to 1868 are now
the supreme law of the land. Alito effectively has written state
laws into the text of the Constitution.

Federal judicial supremacy violated as well. Marbury v.

Madison42 on its head by giving state legislatures of the 19th
century the power to say what the Constitution means.

40
Id.
41
Id. at 432.
42
Marbury v. Madison, 5 U.S. 137, 173–74 (1803).

16
In effect, Alito has delegated or outsourced the Court’s power
of judicial review to a handful of states in 1868 in violation of
federal supremacy.

17
The Dobbs Deeply Rooted Test Turns the Due Process
Clause into a Legal Code

Finally, the Alito deeply rooted test violates Marshall’s clear

instruction not to interpret the Constitution in a manner that
turns it into a legal code. 43 The deeply rooted in 1868 test
does exactly that—it turns the Due Process Clause into a legal
code.

Instead of treating the clause as a broad principle that should

be broadly construed in light of a “fair construction of the
whole” Fourteenth Amendment and Constitution, Alito
reduced the Due Process Clause into a rigid, fixed rule
determined mechanically by counting the number of 1868
state statutes that restricted a particular liberty.

Moreover, Alito’s test means the meaning of the Due Process

Clause has been conclusively predetermined in 1868. There is
no need for the Supreme Court to issue a ruling, any person
can do research now to see if the Due Process Clause protects
a liberty like same-sex marriage under his test. In fact, no
research even needs to be done to overrule Obergefell.

If Alito’s deeply rooted test continues to make state laws of

1868 the supreme law of the land, then it is only a matter of
time before the Supreme Court rules that the state laws of
1868 declared two centuries ago that same-sex marriage
categorically is not protected by the Due Process Clause of
the Fourteenth Amendment.

43
McCulloch v. Maryland, 17 U.S. 316, 415 (1819).

18
In reducing the Due Process Clause into a legal code, Alito
either forgot or ignored Marshall’s command to “never forget,
that it is a constitution we are expounding.”44

44
Id. at 407 (emphasis added).

19
 Implications

When Alito’s deeply rooted in 1868 test is examined in light

of the Integrated Constitution, the subversiveness of the test
as a method of constitutional interpretation exposes itself. A
method of interpreting the Due Process Clause that turns it
into a legal code goes against the fundamental nature of the
Integrated Constitution. According to Chief Justice Marshall,
turning the Due Process Clause into a legal code makes it no
longer a truly constitutional provision. The Due Process
Clause has been stripped of its fundamental constitutional
nature. Hence, Alito’s test is anti-constitutional and must be
rejected.

Rejecting Alito’s deeply rooted test, however, does not

necessarily require overruling Dobbs and restoring abortion
as a fundamental right. A Justice like Kavanaugh could
disavow the deeply rooted reasoning in Dobbs while adopting
another, much narrower rationale for overruling Roe that is
not based on Alito’s deeply rooted reasoning.

The alternative rationale is the harm-principle which Alito

mentions briefly to in Dobbs.45 He asserts that abortion is not
a fundamental right like rights of autonomy like marriage and
procreation because “[a]bortion destroys . . . the life of an
‘unborn human being.’”46 In other words, because abortion
harms prenatal life in a way that same-sex marriage does not,
the infliction of harm justifies excluding abortion as a
fundamental right of autonomy. The harm principle is
ahistorical in nature, and therefore could be designated

45
Dobbs, 142 S. Ct. at 2258.
46
Id.

20
retrospectively as the central rationale for Dobbs while
jettisoning Alito’s history test.

To be sure, I am not arguing that the harm principle should be

the basis to distinguish abortion from other fundamental
rights. Other Justices could and should argue for overruling
Dobbs entirely and reinstate abortion as a fundamental right.

My plan is to write a follow-up article laying out a test for

fundamental rights under due process and/or privileges or
immunities that I call the deeply rooted in the Constitution
test. I will argue that the test supports the conclusion that the
general right of reproductive autonomy and the specific right
of abortion are implied constitutional rights. I will argue that
the deeply rooted in the Constitution test is itself deeply
rooted in and consistent with the Integrated Constitution. In
making the argument, I will make sure to never forget that it
is a constitution, not a legal code, we are expounding

21
5. A Note on Ratifier’s Intent

The dissent in Dobbs suggests that Alito’s deeply rooted in

1868 test is his method for determining the intent of the
ratifiers of the Fourteenth Amendment.47 In other words, if
the state laws of 1868 is a legitimate method of discerning
ratifier intent, then, it may be a way of getting around some of
the critiques made in this Article.

There are several problems with the ratifiers’ intent

justification for the deeply rooted in 1868 test. First, Alito
himself never explicitly states that his test aims to discern
ratifiers’ intent, so he never explains why and how relying on
state statutes in 1868 is the best way of determining ratifier
intent.48 Second, although it is beyond the scope of this article
to do a full critique of the deeply rooted test as a ratifiers’
intent test, one critique is that the test doesn’t actually
consider the intent of the actual, real life ratifiers themselves.
It does not ask if the actual ratifiers actually approved of the
abortion restriction in their state in 1868.

Relying on state laws in 1868 to discern ratifiers’ intent is one

step removed from the actual intent of the ratifiers. In all
likelihood, many of the individual legislators who voted to
ratify the Fourteenth Amendment in 1868 did not vote to
enact the abortion law on the books in 1868. Rather, the test
imputes approval of existing laws in 1868 in a state to the
specific legislators who ratified the Fourteenth Amendment.
It is an argument for constructive ratifiers’ intent, not actual

47
Thomas B. Colby & Peter J. Smith, Living Originalism, 59
DUKE L.J. 239, 250–52 (2009) (analyzing ratifier’s intent in order
to understand amendments and laws).
48
See generally 142 S. Ct. at 2246, 2248.

22
ratifiers’ intent, and it is based on the dubious assumption that
a person approves of all existing laws in the state.

But, that assumption simply cannot be true, because the states

in 1868 that ratified the Fourteenth Amendment were voting
to invalidate some of their very own laws in 1868. One of the
purposes of the Fourteenth Amendment was to invalidate a
host of state laws in 1868 that violated equal protection and
due process.49 The former slave states that voted to ratify the
Fourteenth Amendment did so knowing it would invalidate
their racially discriminatory Black Codes.50

In other words, the very act of ratification was a declaration

that the states did not approve of some of their own laws. Yet,
the deeply rooted in 1868 test presumes the legitimacy of all
existing state statutes at the time of ratification. Ultimately,
Alito’s deeply rooted in 1868 test is not a sound basis for
determining the intent of the ratifiers of the Fourteenth
Amendment.

49
Bryan H. Wildenthal, The Fourteenth Amendment and The Bill
of Rights: Nationalizing the Bill of Rights: Scholarship and
Commentary on the Fourteenth Amendment in 1867-1873, 18 J.
CONTEMP. LEGAL ISSUES 153, 191, 286 (2009) (discussing the
repeal of state laws after the privileges and immunities clause was
enacted).
50
John Harrison, Reconstructing the Privileges or Immunities
Clause, 101 YALE L.J. 1385, 1388–89, 1396 (1992)
(demonstrating how the Fourteenth Amendment affected the Black
Codes).

23
d. The Dobbs Deeply Rooted Method Conflicts
with the Fifteenth and Nineteenth
Amendments

The Fifteenth Amendment protecting the right of racial

minorities to vote,51 and the Nineteenth Amendment
protecting the right of women to vote,52 support the rejection
of the Dobbs deeply rooted method of interpreting the
Fourteenth Amendment.

Constitutional amendments should be integrated into the

Constitution as a whole. In other words, amendments should
not be treated as add-ons to the Constitution, but as new parts
“updating” the previous version of the Constitution into a new
iteration. Thus, the Fourteenth Amendment should be
understood in light of the Fifteenth and Nineteenth
Amendments, in particular, because all three amendments are
about promoting the integrity of the democratic political
process.

The Fifteenth and Nineteenth Amendments function to

include racial minorities and women into the state political
processes and empower them with the right to vote. They
implicitly call into question laws enacted by states negatively
affecting racial minorities and women prior to their political
inclusion. Bottom-line: they had no say at all in the enactment
of such laws.

Accordingly, the Fifteenth and Nineteenth Amendment

bolster the argument that the Dobbs deeply rooted method of
interpretation should be rejected as fundamentally in conflict

51
U.S. CONST. amend. XV, § 1.
52
U.S. CONST. amend. XIX, § 1.

24
with the Fourteenth Amendment itself. It is inconsistent to
use the laws enacted by state political processes that excluded
women and African Americans to determine their
constitutional rights under the Fourteenth Amendment.

Relying on the decision by states governed only by white men

to enact racial segregation laws in 1868 to conclude that such
invidious discrimination does not violate equal protection for
African Americans is anti-democratic. Similarly, relying on
the decision by states governed only by white men to enact
laws restricting the reproductive autonomy of women as the
basis for permitting states in the present to restrict the
reproductive autonomy of women is anti-democratic.

Incorporating the democracy principle of the Fifteenth and

Nineteenth Amendments into the Fourteenth Amendment
provides further support for the critical use of history and
tradition in equal protection cases such as Frontiero and
Loving. T

25