A more thorough explanation:

Ipso facto is a Latin term that means "by the fact itself" or "for this fact alone". It is often used in legal contexts to indicate that something is true simply because of the circumstances or facts surrounding it.

• In the case of Planned Parenthood v. Casey, the Supreme Court of the United States stated that not every law that makes a right more difficult to exercise is, ipso facto, an infringement of that right.
• In Shapiro v. United States, Justice Frankfurter argued that if records are required to be kept by law, they do not ipso facto become public records.

These examples illustrate how ipso facto is used to indicate that something is true simply because of the circumstances or facts surrounding it. In the first example, the Supreme Court is saying that just because a law makes it harder to exercise a right, that doesn't necessarily mean the law is infringing on that right. In the second example, Justice Frankfurter is arguing that just because records are required to be kept by law, that doesn't automatically make them public records.