Commentary by Jon Roland
While this case was decided correctly, the decision should have been based not just on substantive due process but on the intent of the Framers of the 14th Amendment that all rights protected by the Constitution and Bill of Rights from action by the Union government also apply to the states and that U.S. courts have jurisdiction over cases involving those rights between a citizen and his state. See "Intent of the Fourteenth Amendment was to Protect All Rights".