Journalist Craig Unger wrote that President George W. Bush and Karl Rove used coded "dog-whistle" language in political campaigning, delivering one message to the overall electorate while at the same time delivering quite a different message to a targeted evangelical Christian political base. William Safire, in "Safire's Political Dictionary", offered the example of Bush's criticism during the 2004 presidential campaign of the U.S. Supreme Court's 1857 "Dred Scott" decision denying the U.S. citizenship of any African American. To most listeners the criticism seemed innocuous, Safire wrote, but "sharp-eared observers" understood the remark to be a pointed reminder that Supreme Court decisions can be reversed, and a signal that, if re-elected, Bush might nominate to the Supreme Court a justice who would overturn "Roe v. Wade". This view is echoed in a 2004 "Los Angeles Times" article by Peter Wallsten.