While listing every right that a constitution should protect is hard, there is another way to protect rights: an "etcetera clause." The Ninth Amendment states that there are rights beyond those specifically listed: "The enumeration in the Constitution, of certain rights, shall not be construed to deny or disparage others retained by the people." While scholars are divided on whether or not the Ninth Amendment actually protects unenumerated rights, and the Supreme Court has almost entirely ignored it, two-thirds of state constitutions have equivalent provisions, or "Baby Ninth Amendments." Baby Ninth Amendments is the story of how the "Baby Ninths" came to be. The book argues that state judges should do their duty and live up to their constitutions to protect the rights "retained by the people" that these "etcetera clauses" are designed to guarantee. That these provisions have been included so many times in so many states demonstrates that unenumerated rights are not only protected by state constitutions, but that they are popular. Unenumerated rights are not a weird exception to American constitutional law, they are at the center of it.