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This fall, the Supreme Court of the United States (SCOTUS) will announce when they will hear oral arguments for Dobbs v Jackson Women’s Health Organization. The court will examine a Mississippi law, known as the “Gestational Age Act,” originally passed in 2018, that sought to “limit abortions to fifteen weeks’ gestation except in a medical emergency or in cases of severe fetal abnormality.”1 This sets the stage for SCOTUS to make a major ruling on abortion, one which could affirm or upend landmark decisions and nearly 50 years of abortion legislative precedent. Additionally, SCOTUS’ recent decision to not intervene on Texas’ Senate Bill 8 (SB8), which essentially bans all abortions after 6 weeks’ gestational age, may foreshadow how this case will be decided. The current abortion restrictions in Texas and the implications of SB8 will be discussed in a forthcoming column.
SCOTUS and abortion rights
The decision to hear this case comes on the heels of another recent decision regarding a Louisiana law in June Medical Services v Russo. This case examined Louisiana Act 620, which would have required physicians to have hospital admitting privileges within 30 miles of where they provide abortion services.2 The law was deemed constitutionally invalid, with the majority noting the law would have drastically burdened a woman’s right to access abortion services. The Court ruled similarly in 2016 in Whole Women’s Health (WWH) v Hellerstedt, in which WWH challenged Texas House Bill 2, a nearly identical law requiring admitting privileges for abortion care providers. In both of these cases, SCOTUS pointed to precedent set by Southeastern Pennsylvania v Casey, which established that it is unconstitutional for a state to create an “undue burden” on a woman’s right to abortion prior to fetal viability.3 The precedent to this, Roe v Wade, and 5 decades of abortion legislation set may be upended by a SCOTUS decision this next term.
Dobbs v Jackson
On March 19, 2018, Mississippi enacted the “Gestational Age Act” into law. The newly enacted law would limit abortions to 15 weeks’ gestation except in a medical emergency or in cases of severe fetal anomalies. Jackson Women’s Health Organization, the only licensed abortion provider in the state, challenged the constitutionality of the law with legal support from Center for Reproductive Rights (CRR). The US District Court for the Southern District of Mississippi granted summary judgement in favor of the clinic and placed an injunction on the law’s enforcement. The state appealed to the Fifth Circuit Court of Appeals, which upheld the district court decision in a 3-0 decision in November 2019. Mississippi appealed to the Supreme Court, with their petition focusing on multiple questions from the appeals process. After repeatedly rescheduling the case, and multiple reviews in conference, SCOTUS agreed to hear the case. Most recently, the state has narrowed its argument, changing course, and attacking Roe v Wade directly. In a brief submitted in July 2021, the state argues the court should hold that all pre-viability prohibitions on elective abortions are constitutional.
Interestingly, during this time the Mississippi legislature also passed a law, House Bill 2116, also known as the “fetal heartbeat bill,” banning abortion with gestational ages after detection of a fetal heartbeat. This was also challenged, deemed unconstitutional, and affirmed on appeal by the Fifth US Circuit Court.
While recent challenges have focused on the “undue burden” state laws placed on those trying to access abortion care, this case will bring the issue of “viability” and gestational age limits to the forefront.4,5 In addition to Roe v Wade, the Court will have the opportunity to reexamine other relevant precedent, such as Southeastern Pennsylvania v Casey, in considering the most recent arguments of the state. In this most recent brief, the state argues that the Court should, “reject viability as a barrier to prohibiting elective abortions” and that a “viability rule has no constitutional basis.” The state goes on to argue the “Constitution does not protect a right to abortion or limit States’ authority to restrict it.”6 The language and tone in this brief are more direct and aggressive than the states’ petition submitted last June.
However, the composition of the Court is different than in the past. This case will be argued with Justice Amy Coney Barrett seated in place of Justice Ruth Bader Ginsburg, who was a strong advocate for women’s rights.7 She joins Justices Neil Gorsuch and Brett Kavanaugh, also appointed by President Donald Trump and widely viewed as conservative judges, tipping the scales to a more conservative Supreme Court. This case will also be argued in a polarized political environment.8,9 Given the conservative Supreme Court in the setting of an increasingly politically charged environment, reproductive right advocates are understandably worried that members of the anti-abortion movement view this as an opportunity to weaken or remove federal constitutional protections for abortion.
Continue to: Potential outcome of Dobbs v Jackson...
Potential outcome of Dobbs v Jackson
Should SCOTUS choose to rule in favor of Mississippi, it could severely weaken, or even overturn Roe v Wade. This would leave a legal path for states with pre-Roe abortion bans and currently unenforced post-Roe bans to take effect. These “trigger” laws are bans or severe restrictions on abortion providers and patients intended to take effect if Roe were to be overturned. Alternatively, the Court may overturn Southeastern Pennsylvania v Casey, but maintain Roe v Wade, essentially leaving the regulation of pre-viability abortion care to individual states. Currently 21 states have laws that would restrict the legal status of abortion.10 In addition, state legislatures are aggressively introducing abortion restrictions. As of June 2021, there have been 561 abortion restrictions, including 165 abortion bans, introduced across 47 states, putting 2021 on course to be the most devastating anti-abortion state legislative session in decades.11
The damage caused by such restriction on abortion care would be significant. It would block or push access out of reach for many. The negative effects of such legislative action would most heavily burden those already marginalized by systemic, structural inequalities including those of low socioeconomic status, people of color, young people, those in rural communities, and members of the LGBTQ community. The medical community has long recognized the harm caused by restricting access to abortion care. Restriction of access to safe abortion care paradoxically has been shown not to decrease the incidence of abortion, but rather increases the number of unsafe abortions.12 The American College of Obstetricians and Gynecologists (ACOG) acknowledge “individuals require access to safe, legal abortion” and that this represents “a necessary component for comprehensive health care.”13,14 They joined the American Medical Association and other professional groups in a 2019 amicus brief to SCOTUS opposing restrictions on abortion access.15 In addition, government laws restricting access to abortion care undermine the fundamental relationship between a person and their physician, limiting a physician’s obligation to honor patient autonomy and provide appropriate medical care.
By taking up the question whether all pre-viability bans on elective abortions violate the Constitution, SCOTUS is indicating a possible willingness to revisit the central holding of abortion jurisprudence. Their decision regarding this case will likely be the most significant ruling regarding the legal status of abortion care in decades, and will significantly affect the delivery of abortion care in the future.
Action items
- Reach out to your representatives to support the Women’s Health Protection Act, an initiative introduced to Congress to protect access to abortion care. If you reside in a state where your federal representatives support the Women’s Health Protection Act, reach out to friends and colleagues in states without supportive elected officials and ask them to call their representatives and ask them to support the bill.
- Get involved with local grassroots groups fighting to protect abortion access.
- Continue to speak out against laws and policies designed to limit access to safe abortion care.
- Connect with your local ACOG chapter for more ways to become involved.
- As always, make sure you are registered to vote, and exercise your right whenever you can.
- HB1510 (As Introduced) - 2018 Regular Session. http://billstatus.ls.state.ms.us/documents/2018/html/HB/1500-1599/HB1510IN.htm Accessed August 13, 2021.
- HB338. Louisiana State Legislature. 2014. http://www.legis.la.gov/legis/BillInfo.aspx?s=14RS&b=ACT620&sbi=y. Accessed August 13, 2021.
- Planned Parenthood of Southeastern Pennsylvania v. Casey. Cornell Law School Legal Information Institute. https://www.law.cornell.edu/supremecourt/text/505/833. Accessed August 13, 2021.
- 15-274 Whole Woman’s Health v. Hellerstedt (06/27/2016). Published online 2016:107.
- 18-1323 June Medical Services L. L. C. v. Russo (06/29/2020). Published online 2020:138.
- 19-1392 Dobbs v. Jackson Women’s Health Organization (07/22/2021). Published online 2021.
- What Ruth Bader Ginsburg said about abortion and Roe v. Wade. Time. August 2, 2018. https://time.com/5354490/ruth-bader-ginsburg-roe-v-wade/. Accessed August 13, 2021.
- Montanaro D. Poll: majority want to keep abortion legal, but they also want restrictions. NPR. June 7, 2019. https://www.npr.org/2019/06/07/730183531/poll-majority-want-to-keep-abortion-legal-but-they-also-want-restrictions. Accessed August 13, 2021.
- Abortion support remains steady despite growing partisan divide, survey finds. Washington Post. August 13, 2019. https://www.washingtonpost.com/health/2019/08/13/one-largest-ever-abortion-surveys-shows-growing-partisan-divide/. Accessed August 13, 2021.
- Abortion policy in the absence of Roe. Guttmacher Institute. September 1, 2021. https://www.guttmacher.org/state-policy/explore/abortion-policy-absence-roe#. Accessed September 8, 2021.
- 2021 is on track to become the most devastating antiabortion state legislative session in decades. Guttmacher Institute. Published April 30, 2021. Updated June 14, 2021. https://www.guttmacher.org/article/2021/04/2021-track-become-most-devastating-antiabortion-state-legislative-session-decades. Accessed August 13, 2021.
- Facts and consequences: legality, incidence and safety of abortion worldwide. Guttmacher Institute. November 20, 2009. https://www.guttmacher.org/gpr/2009/11/facts-and-consequences-legality-incidence-and-safety-abortion-worldwide. Accessed August 13, 2021.
- Increasing access to abortion. https://www.acog.org/en/clinical/clinical-guidance/committee-opinion/articles/2020/12/increasing-access-to-abortion. Accessed August 13, 2021.
- ACOG statement on Dobbs vs. Jackson Women’s Health. May 17, 2021. https://www.acog.org/en/news/news-releases/2021/05/acog-statement-dobbs-vs-jackson-womens-health. Accessed August 13, 2021.
- Perryman SL, Parker KA, Hickman SA. Brief of amici curiae American College of Obstetricians and Gynecologists, American Medical Associations, American Academy of Family Physicians, American Academy of Nursing, American Academy of Pediatrics, et al. In support of June Medical Services, LLC, et al. https://www.supremecourt.gov/
DocketPDF/18/18-1323/124091/ . Accessed August 13, 2021.20191202145531124_18-1323% 2018-1460%20tsac%20American% 20College%20of% 20Obstetricians%20and% 20Gynecologists%20et%20al.pdf
This fall, the Supreme Court of the United States (SCOTUS) will announce when they will hear oral arguments for Dobbs v Jackson Women’s Health Organization. The court will examine a Mississippi law, known as the “Gestational Age Act,” originally passed in 2018, that sought to “limit abortions to fifteen weeks’ gestation except in a medical emergency or in cases of severe fetal abnormality.”1 This sets the stage for SCOTUS to make a major ruling on abortion, one which could affirm or upend landmark decisions and nearly 50 years of abortion legislative precedent. Additionally, SCOTUS’ recent decision to not intervene on Texas’ Senate Bill 8 (SB8), which essentially bans all abortions after 6 weeks’ gestational age, may foreshadow how this case will be decided. The current abortion restrictions in Texas and the implications of SB8 will be discussed in a forthcoming column.
SCOTUS and abortion rights
The decision to hear this case comes on the heels of another recent decision regarding a Louisiana law in June Medical Services v Russo. This case examined Louisiana Act 620, which would have required physicians to have hospital admitting privileges within 30 miles of where they provide abortion services.2 The law was deemed constitutionally invalid, with the majority noting the law would have drastically burdened a woman’s right to access abortion services. The Court ruled similarly in 2016 in Whole Women’s Health (WWH) v Hellerstedt, in which WWH challenged Texas House Bill 2, a nearly identical law requiring admitting privileges for abortion care providers. In both of these cases, SCOTUS pointed to precedent set by Southeastern Pennsylvania v Casey, which established that it is unconstitutional for a state to create an “undue burden” on a woman’s right to abortion prior to fetal viability.3 The precedent to this, Roe v Wade, and 5 decades of abortion legislation set may be upended by a SCOTUS decision this next term.
Dobbs v Jackson
On March 19, 2018, Mississippi enacted the “Gestational Age Act” into law. The newly enacted law would limit abortions to 15 weeks’ gestation except in a medical emergency or in cases of severe fetal anomalies. Jackson Women’s Health Organization, the only licensed abortion provider in the state, challenged the constitutionality of the law with legal support from Center for Reproductive Rights (CRR). The US District Court for the Southern District of Mississippi granted summary judgement in favor of the clinic and placed an injunction on the law’s enforcement. The state appealed to the Fifth Circuit Court of Appeals, which upheld the district court decision in a 3-0 decision in November 2019. Mississippi appealed to the Supreme Court, with their petition focusing on multiple questions from the appeals process. After repeatedly rescheduling the case, and multiple reviews in conference, SCOTUS agreed to hear the case. Most recently, the state has narrowed its argument, changing course, and attacking Roe v Wade directly. In a brief submitted in July 2021, the state argues the court should hold that all pre-viability prohibitions on elective abortions are constitutional.
Interestingly, during this time the Mississippi legislature also passed a law, House Bill 2116, also known as the “fetal heartbeat bill,” banning abortion with gestational ages after detection of a fetal heartbeat. This was also challenged, deemed unconstitutional, and affirmed on appeal by the Fifth US Circuit Court.
While recent challenges have focused on the “undue burden” state laws placed on those trying to access abortion care, this case will bring the issue of “viability” and gestational age limits to the forefront.4,5 In addition to Roe v Wade, the Court will have the opportunity to reexamine other relevant precedent, such as Southeastern Pennsylvania v Casey, in considering the most recent arguments of the state. In this most recent brief, the state argues that the Court should, “reject viability as a barrier to prohibiting elective abortions” and that a “viability rule has no constitutional basis.” The state goes on to argue the “Constitution does not protect a right to abortion or limit States’ authority to restrict it.”6 The language and tone in this brief are more direct and aggressive than the states’ petition submitted last June.
However, the composition of the Court is different than in the past. This case will be argued with Justice Amy Coney Barrett seated in place of Justice Ruth Bader Ginsburg, who was a strong advocate for women’s rights.7 She joins Justices Neil Gorsuch and Brett Kavanaugh, also appointed by President Donald Trump and widely viewed as conservative judges, tipping the scales to a more conservative Supreme Court. This case will also be argued in a polarized political environment.8,9 Given the conservative Supreme Court in the setting of an increasingly politically charged environment, reproductive right advocates are understandably worried that members of the anti-abortion movement view this as an opportunity to weaken or remove federal constitutional protections for abortion.
Continue to: Potential outcome of Dobbs v Jackson...
Potential outcome of Dobbs v Jackson
Should SCOTUS choose to rule in favor of Mississippi, it could severely weaken, or even overturn Roe v Wade. This would leave a legal path for states with pre-Roe abortion bans and currently unenforced post-Roe bans to take effect. These “trigger” laws are bans or severe restrictions on abortion providers and patients intended to take effect if Roe were to be overturned. Alternatively, the Court may overturn Southeastern Pennsylvania v Casey, but maintain Roe v Wade, essentially leaving the regulation of pre-viability abortion care to individual states. Currently 21 states have laws that would restrict the legal status of abortion.10 In addition, state legislatures are aggressively introducing abortion restrictions. As of June 2021, there have been 561 abortion restrictions, including 165 abortion bans, introduced across 47 states, putting 2021 on course to be the most devastating anti-abortion state legislative session in decades.11
The damage caused by such restriction on abortion care would be significant. It would block or push access out of reach for many. The negative effects of such legislative action would most heavily burden those already marginalized by systemic, structural inequalities including those of low socioeconomic status, people of color, young people, those in rural communities, and members of the LGBTQ community. The medical community has long recognized the harm caused by restricting access to abortion care. Restriction of access to safe abortion care paradoxically has been shown not to decrease the incidence of abortion, but rather increases the number of unsafe abortions.12 The American College of Obstetricians and Gynecologists (ACOG) acknowledge “individuals require access to safe, legal abortion” and that this represents “a necessary component for comprehensive health care.”13,14 They joined the American Medical Association and other professional groups in a 2019 amicus brief to SCOTUS opposing restrictions on abortion access.15 In addition, government laws restricting access to abortion care undermine the fundamental relationship between a person and their physician, limiting a physician’s obligation to honor patient autonomy and provide appropriate medical care.
By taking up the question whether all pre-viability bans on elective abortions violate the Constitution, SCOTUS is indicating a possible willingness to revisit the central holding of abortion jurisprudence. Their decision regarding this case will likely be the most significant ruling regarding the legal status of abortion care in decades, and will significantly affect the delivery of abortion care in the future.
Action items
- Reach out to your representatives to support the Women’s Health Protection Act, an initiative introduced to Congress to protect access to abortion care. If you reside in a state where your federal representatives support the Women’s Health Protection Act, reach out to friends and colleagues in states without supportive elected officials and ask them to call their representatives and ask them to support the bill.
- Get involved with local grassroots groups fighting to protect abortion access.
- Continue to speak out against laws and policies designed to limit access to safe abortion care.
- Connect with your local ACOG chapter for more ways to become involved.
- As always, make sure you are registered to vote, and exercise your right whenever you can.
This fall, the Supreme Court of the United States (SCOTUS) will announce when they will hear oral arguments for Dobbs v Jackson Women’s Health Organization. The court will examine a Mississippi law, known as the “Gestational Age Act,” originally passed in 2018, that sought to “limit abortions to fifteen weeks’ gestation except in a medical emergency or in cases of severe fetal abnormality.”1 This sets the stage for SCOTUS to make a major ruling on abortion, one which could affirm or upend landmark decisions and nearly 50 years of abortion legislative precedent. Additionally, SCOTUS’ recent decision to not intervene on Texas’ Senate Bill 8 (SB8), which essentially bans all abortions after 6 weeks’ gestational age, may foreshadow how this case will be decided. The current abortion restrictions in Texas and the implications of SB8 will be discussed in a forthcoming column.
SCOTUS and abortion rights
The decision to hear this case comes on the heels of another recent decision regarding a Louisiana law in June Medical Services v Russo. This case examined Louisiana Act 620, which would have required physicians to have hospital admitting privileges within 30 miles of where they provide abortion services.2 The law was deemed constitutionally invalid, with the majority noting the law would have drastically burdened a woman’s right to access abortion services. The Court ruled similarly in 2016 in Whole Women’s Health (WWH) v Hellerstedt, in which WWH challenged Texas House Bill 2, a nearly identical law requiring admitting privileges for abortion care providers. In both of these cases, SCOTUS pointed to precedent set by Southeastern Pennsylvania v Casey, which established that it is unconstitutional for a state to create an “undue burden” on a woman’s right to abortion prior to fetal viability.3 The precedent to this, Roe v Wade, and 5 decades of abortion legislation set may be upended by a SCOTUS decision this next term.
Dobbs v Jackson
On March 19, 2018, Mississippi enacted the “Gestational Age Act” into law. The newly enacted law would limit abortions to 15 weeks’ gestation except in a medical emergency or in cases of severe fetal anomalies. Jackson Women’s Health Organization, the only licensed abortion provider in the state, challenged the constitutionality of the law with legal support from Center for Reproductive Rights (CRR). The US District Court for the Southern District of Mississippi granted summary judgement in favor of the clinic and placed an injunction on the law’s enforcement. The state appealed to the Fifth Circuit Court of Appeals, which upheld the district court decision in a 3-0 decision in November 2019. Mississippi appealed to the Supreme Court, with their petition focusing on multiple questions from the appeals process. After repeatedly rescheduling the case, and multiple reviews in conference, SCOTUS agreed to hear the case. Most recently, the state has narrowed its argument, changing course, and attacking Roe v Wade directly. In a brief submitted in July 2021, the state argues the court should hold that all pre-viability prohibitions on elective abortions are constitutional.
Interestingly, during this time the Mississippi legislature also passed a law, House Bill 2116, also known as the “fetal heartbeat bill,” banning abortion with gestational ages after detection of a fetal heartbeat. This was also challenged, deemed unconstitutional, and affirmed on appeal by the Fifth US Circuit Court.
While recent challenges have focused on the “undue burden” state laws placed on those trying to access abortion care, this case will bring the issue of “viability” and gestational age limits to the forefront.4,5 In addition to Roe v Wade, the Court will have the opportunity to reexamine other relevant precedent, such as Southeastern Pennsylvania v Casey, in considering the most recent arguments of the state. In this most recent brief, the state argues that the Court should, “reject viability as a barrier to prohibiting elective abortions” and that a “viability rule has no constitutional basis.” The state goes on to argue the “Constitution does not protect a right to abortion or limit States’ authority to restrict it.”6 The language and tone in this brief are more direct and aggressive than the states’ petition submitted last June.
However, the composition of the Court is different than in the past. This case will be argued with Justice Amy Coney Barrett seated in place of Justice Ruth Bader Ginsburg, who was a strong advocate for women’s rights.7 She joins Justices Neil Gorsuch and Brett Kavanaugh, also appointed by President Donald Trump and widely viewed as conservative judges, tipping the scales to a more conservative Supreme Court. This case will also be argued in a polarized political environment.8,9 Given the conservative Supreme Court in the setting of an increasingly politically charged environment, reproductive right advocates are understandably worried that members of the anti-abortion movement view this as an opportunity to weaken or remove federal constitutional protections for abortion.
Continue to: Potential outcome of Dobbs v Jackson...
Potential outcome of Dobbs v Jackson
Should SCOTUS choose to rule in favor of Mississippi, it could severely weaken, or even overturn Roe v Wade. This would leave a legal path for states with pre-Roe abortion bans and currently unenforced post-Roe bans to take effect. These “trigger” laws are bans or severe restrictions on abortion providers and patients intended to take effect if Roe were to be overturned. Alternatively, the Court may overturn Southeastern Pennsylvania v Casey, but maintain Roe v Wade, essentially leaving the regulation of pre-viability abortion care to individual states. Currently 21 states have laws that would restrict the legal status of abortion.10 In addition, state legislatures are aggressively introducing abortion restrictions. As of June 2021, there have been 561 abortion restrictions, including 165 abortion bans, introduced across 47 states, putting 2021 on course to be the most devastating anti-abortion state legislative session in decades.11
The damage caused by such restriction on abortion care would be significant. It would block or push access out of reach for many. The negative effects of such legislative action would most heavily burden those already marginalized by systemic, structural inequalities including those of low socioeconomic status, people of color, young people, those in rural communities, and members of the LGBTQ community. The medical community has long recognized the harm caused by restricting access to abortion care. Restriction of access to safe abortion care paradoxically has been shown not to decrease the incidence of abortion, but rather increases the number of unsafe abortions.12 The American College of Obstetricians and Gynecologists (ACOG) acknowledge “individuals require access to safe, legal abortion” and that this represents “a necessary component for comprehensive health care.”13,14 They joined the American Medical Association and other professional groups in a 2019 amicus brief to SCOTUS opposing restrictions on abortion access.15 In addition, government laws restricting access to abortion care undermine the fundamental relationship between a person and their physician, limiting a physician’s obligation to honor patient autonomy and provide appropriate medical care.
By taking up the question whether all pre-viability bans on elective abortions violate the Constitution, SCOTUS is indicating a possible willingness to revisit the central holding of abortion jurisprudence. Their decision regarding this case will likely be the most significant ruling regarding the legal status of abortion care in decades, and will significantly affect the delivery of abortion care in the future.
Action items
- Reach out to your representatives to support the Women’s Health Protection Act, an initiative introduced to Congress to protect access to abortion care. If you reside in a state where your federal representatives support the Women’s Health Protection Act, reach out to friends and colleagues in states without supportive elected officials and ask them to call their representatives and ask them to support the bill.
- Get involved with local grassroots groups fighting to protect abortion access.
- Continue to speak out against laws and policies designed to limit access to safe abortion care.
- Connect with your local ACOG chapter for more ways to become involved.
- As always, make sure you are registered to vote, and exercise your right whenever you can.
- HB1510 (As Introduced) - 2018 Regular Session. http://billstatus.ls.state.ms.us/documents/2018/html/HB/1500-1599/HB1510IN.htm Accessed August 13, 2021.
- HB338. Louisiana State Legislature. 2014. http://www.legis.la.gov/legis/BillInfo.aspx?s=14RS&b=ACT620&sbi=y. Accessed August 13, 2021.
- Planned Parenthood of Southeastern Pennsylvania v. Casey. Cornell Law School Legal Information Institute. https://www.law.cornell.edu/supremecourt/text/505/833. Accessed August 13, 2021.
- 15-274 Whole Woman’s Health v. Hellerstedt (06/27/2016). Published online 2016:107.
- 18-1323 June Medical Services L. L. C. v. Russo (06/29/2020). Published online 2020:138.
- 19-1392 Dobbs v. Jackson Women’s Health Organization (07/22/2021). Published online 2021.
- What Ruth Bader Ginsburg said about abortion and Roe v. Wade. Time. August 2, 2018. https://time.com/5354490/ruth-bader-ginsburg-roe-v-wade/. Accessed August 13, 2021.
- Montanaro D. Poll: majority want to keep abortion legal, but they also want restrictions. NPR. June 7, 2019. https://www.npr.org/2019/06/07/730183531/poll-majority-want-to-keep-abortion-legal-but-they-also-want-restrictions. Accessed August 13, 2021.
- Abortion support remains steady despite growing partisan divide, survey finds. Washington Post. August 13, 2019. https://www.washingtonpost.com/health/2019/08/13/one-largest-ever-abortion-surveys-shows-growing-partisan-divide/. Accessed August 13, 2021.
- Abortion policy in the absence of Roe. Guttmacher Institute. September 1, 2021. https://www.guttmacher.org/state-policy/explore/abortion-policy-absence-roe#. Accessed September 8, 2021.
- 2021 is on track to become the most devastating antiabortion state legislative session in decades. Guttmacher Institute. Published April 30, 2021. Updated June 14, 2021. https://www.guttmacher.org/article/2021/04/2021-track-become-most-devastating-antiabortion-state-legislative-session-decades. Accessed August 13, 2021.
- Facts and consequences: legality, incidence and safety of abortion worldwide. Guttmacher Institute. November 20, 2009. https://www.guttmacher.org/gpr/2009/11/facts-and-consequences-legality-incidence-and-safety-abortion-worldwide. Accessed August 13, 2021.
- Increasing access to abortion. https://www.acog.org/en/clinical/clinical-guidance/committee-opinion/articles/2020/12/increasing-access-to-abortion. Accessed August 13, 2021.
- ACOG statement on Dobbs vs. Jackson Women’s Health. May 17, 2021. https://www.acog.org/en/news/news-releases/2021/05/acog-statement-dobbs-vs-jackson-womens-health. Accessed August 13, 2021.
- Perryman SL, Parker KA, Hickman SA. Brief of amici curiae American College of Obstetricians and Gynecologists, American Medical Associations, American Academy of Family Physicians, American Academy of Nursing, American Academy of Pediatrics, et al. In support of June Medical Services, LLC, et al. https://www.supremecourt.gov/
DocketPDF/18/18-1323/124091/ . Accessed August 13, 2021.20191202145531124_18-1323% 2018-1460%20tsac%20American% 20College%20of% 20Obstetricians%20and% 20Gynecologists%20et%20al.pdf
- HB1510 (As Introduced) - 2018 Regular Session. http://billstatus.ls.state.ms.us/documents/2018/html/HB/1500-1599/HB1510IN.htm Accessed August 13, 2021.
- HB338. Louisiana State Legislature. 2014. http://www.legis.la.gov/legis/BillInfo.aspx?s=14RS&b=ACT620&sbi=y. Accessed August 13, 2021.
- Planned Parenthood of Southeastern Pennsylvania v. Casey. Cornell Law School Legal Information Institute. https://www.law.cornell.edu/supremecourt/text/505/833. Accessed August 13, 2021.
- 15-274 Whole Woman’s Health v. Hellerstedt (06/27/2016). Published online 2016:107.
- 18-1323 June Medical Services L. L. C. v. Russo (06/29/2020). Published online 2020:138.
- 19-1392 Dobbs v. Jackson Women’s Health Organization (07/22/2021). Published online 2021.
- What Ruth Bader Ginsburg said about abortion and Roe v. Wade. Time. August 2, 2018. https://time.com/5354490/ruth-bader-ginsburg-roe-v-wade/. Accessed August 13, 2021.
- Montanaro D. Poll: majority want to keep abortion legal, but they also want restrictions. NPR. June 7, 2019. https://www.npr.org/2019/06/07/730183531/poll-majority-want-to-keep-abortion-legal-but-they-also-want-restrictions. Accessed August 13, 2021.
- Abortion support remains steady despite growing partisan divide, survey finds. Washington Post. August 13, 2019. https://www.washingtonpost.com/health/2019/08/13/one-largest-ever-abortion-surveys-shows-growing-partisan-divide/. Accessed August 13, 2021.
- Abortion policy in the absence of Roe. Guttmacher Institute. September 1, 2021. https://www.guttmacher.org/state-policy/explore/abortion-policy-absence-roe#. Accessed September 8, 2021.
- 2021 is on track to become the most devastating antiabortion state legislative session in decades. Guttmacher Institute. Published April 30, 2021. Updated June 14, 2021. https://www.guttmacher.org/article/2021/04/2021-track-become-most-devastating-antiabortion-state-legislative-session-decades. Accessed August 13, 2021.
- Facts and consequences: legality, incidence and safety of abortion worldwide. Guttmacher Institute. November 20, 2009. https://www.guttmacher.org/gpr/2009/11/facts-and-consequences-legality-incidence-and-safety-abortion-worldwide. Accessed August 13, 2021.
- Increasing access to abortion. https://www.acog.org/en/clinical/clinical-guidance/committee-opinion/articles/2020/12/increasing-access-to-abortion. Accessed August 13, 2021.
- ACOG statement on Dobbs vs. Jackson Women’s Health. May 17, 2021. https://www.acog.org/en/news/news-releases/2021/05/acog-statement-dobbs-vs-jackson-womens-health. Accessed August 13, 2021.
- Perryman SL, Parker KA, Hickman SA. Brief of amici curiae American College of Obstetricians and Gynecologists, American Medical Associations, American Academy of Family Physicians, American Academy of Nursing, American Academy of Pediatrics, et al. In support of June Medical Services, LLC, et al. https://www.supremecourt.gov/
DocketPDF/18/18-1323/124091/ . Accessed August 13, 2021.20191202145531124_18-1323% 2018-1460%20tsac%20American% 20College%20of% 20Obstetricians%20and% 20Gynecologists%20et%20al.pdf