In support of super-duper extra-special precedent:

The reservations any of us may have in reaffirming the central holding of Roe are outweighed by the explication of individual liberty we have given combined with the force of stare decisis.

She writes that there has "clearly" been no erosion of Roe. Her proof:

The original holding resting on the concurrence of seven Members of the Court in 1973 was expressly affirmed by a majority of six in 1983, see Akron v. Akron Center for Reproductive Health, Inc., and by a majority of five in 1986, see Thornburgh v. American College of Obstetricians and Gynecologists. More recently, in Webster v. Reproductive Health Services, although two of the present authors questioned the trimester framework in a way consistent with our judgment today, a majority of the Court either decided to reaffirm or declined to address the constitutional validity of the central holding of Roe.

She concludes the section:

Whether or not a new social consensus is developing on that [abortion] issue, its divisiveness is no less today than in 1973, and pressure to overrule the decision, like pressure to retain it, has grown only more intense. A decision to overrule Roe's essential holding under the existing circumstances would address error, if error there was, at the cost of both profound and unnecessary damage to the Court's legitimacy, and to the Nation's commitment to the rule of law.

In other words, O'Connor can't find good law to support her decision, but the result would be so "disasterous" that she's going to overlook the lack.

That's my problem with Casey. It's made up out of whole cloth.

On the other hand, I don't really have a problem with the undue burden test, itself. It's much closer to modern Supreme Court jurisprudence than the arbitrary trimester test created by Roe. In my opinion, the new test is much closer to strict scrutiny under the Fourteenth Amendment.