If "safeguards of individual liberty" do not have "any intrinsic worth," then neither does individual liberty. And if individual liberty has no intrinsic worth, neither does individual life. It is impossible to imagine a more complete denial of President Bush's proclamation of the sanctity of human life, or of his assertion of an "essential human dignity attached to all persons by virtue of their very existence." This is not only legal positivism, it is nihilism. It is not only a denial of any moral foundation of constitutionalism, it is a denial of any moral foundation of political community.

Bush's Lincolnian Challenge (2002)