The New York Times quickly criticized the selection of Alito. In an editorial titled “Another Lost Opportunity” the paper questioned Alito’s attitudes toward civil rights, privacy and federalism. The paper highlighted several past rulings by Alito: In 1992 he ruled in the case of Planned Parenthood v. Casey that all of Pennsylvania’s limitations on abortion were constitutional, including the requirement that women be forced to notify their husbands before they have an abortion. In 1996 Alito declared that Washington could not regulate the sale of fully automatic machine guns. In 2000 he said Washington could not compel state governments to abide by the Family and Medical Leave Act. The Times also reports Alito has favored an inflated standard of evidence for racial- and sex-discrimination cases that would make it harder to bring them to court. When lawyers for an African-American death-row inmate sought to demonstrate bias in jury selection by using statistics, Alito dismissed that as akin to arguing that Americans were biased toward left-handers because left-handed men had won five out of six of the preceding presidential elections.