Freedom of movement
The Court then surveyed Angevin law under Magna Carta, citing Article 42 in support of the right to travel as a "liberty" right. It referenced Chafee in "Three Human Rights in the Constitution of 1787". At that point the Court began to use the phrase "freedom of movement" as in "Freedom of movement is basic in our scheme of values", citing "Crandall v. Nevada" "Williams v. Fears", "Edwards v. California", and Vestal, "Freedom of Movement", 41 Iowa L.Rev. 6, 13-14, although all the cases it cited involved interstate travel. The Court concluded that although "Freedom to travel is, indeed, an important aspect of the citizen's liberty" it need not decide the extent to which it can be curtailed because it was first concerned with the extent, if any, to which Congress had authorized its curtailment.