In Wilkinson v. Russell, 182 F.3d 89, 108 (2d Cir. Vt. 1999), Sotomayor quoted from Frazier v. Bailey, 957 F.2d 920. She described the case by stating, "In reaching its conclusion, the Frazier court emphasized the murky nature of parental rights". Quoting another case, she said, "Although recognizing that the Constitution extends "certain fundamental parental rights," the court held that plaintiff's allegations did not even "implicate the constitutional guarantees at issue."