In 1976, Richard Posner and William Landes coined the term "super-precedent," in an article they wrote about testing theories of precedent by counting citations. Posner and Landes used this term to describe the influential effect of a cited decision. The term "super-precedent" later became associated with different issue: the difficulty of overturning a decision. In 1992, Rutgers professor Earl Maltz criticized the Supreme Court's decision in "Planned Parenthood v. Casey" for endorsing the idea that if one side can take control of the Court on an issue of major national importance (as in "Roe v. Wade"), that side can protect its position from being reversed "by a kind of super-stare decisis." 