The ideological shift of the Supreme Court that culminated with the 2020 appointment of Justice Amy Coney Barrett, who was outspoken against abortion before her appointment, made Dobbs a potential vehicle to challenge both Roe and Casey. More than 20 states prepared legislation, including 13 with trigger laws, to strictly regulate abortion should Dobbs overturn Roe and Casey. Dobbs gained more attention in the wake of legal battles over the Texas Heartbeat Act, enacted in May 2021, leading to near record-setting amicus curiae submissions in Dobbs.