By Arshia Jain
Published On: December 28, 2021 at 18:40 IST
Introduction
Abortion is a medical or surgical technique that terminates a pregnancy before the birth of an embryo or fetus. Abortion opponents often oppose the process for religious or ethical reasons, claiming that it is the cruel termination of what they believe is a valid human life. Those who support a woman’s right to choose an abortion claim that it is a human right to have access to safe, legal abortions. In Roe Vs Wade[i] (1973), the United States Supreme Court ruled that a woman’s right to an abortion is protected under the Constitution until the end of the first trimester or the twelfth week of pregnancy. A woman’s right to an abortion may be limited beyond twelve weeks, depending on governmental discretion and the amount of the pregnancy’s health risk.
Abortion is a divisive topic, with state legislatures enacting legislation restricting and controlling access to the procedure. Several of these restrictions have been challenged in federal courts, with some of them upheld, such as the prohibition on using state funding for the procedure. In May 2018, Governor Kim Reynolds signed a measure preventing doctors from performing abortions if a fetus has a detectable heartbeat, which can occur as early as six weeks. Other laws have been overturned, such as those requiring spousal approval for an abortion. Politicians, religious leaders, healthcare providers, and activists all have a say in the ongoing discussion.
Pro-lifers are known as pro-lifers, whereas pro-choice activists are known as pro-choices. Within both movements, there are still differences of opinion. Some pro-life campaigners may support abortions in circumstances of rape or incest, while others are adamant that abortion is murder in all cases. Within the pro-choice movement, some activists believe that there should be no limitations on abortions, while others support legislation that demands a waiting period before the procedure may be performed or regulations that require minors to gain parental consent.
Abortions via Surgical and Medical Means
Surgical abortions are the most common type of abortion done during the first trimester of pregnancy. Suction abortion, also known as vacuum aspiration, is the most common procedure, which includes removing tissue from the uterus through a tiny tube. The surgery is less invasive than subsequent operations that necessitate inducing labor. First-trimester surgical abortions conducted by skilled medical professionals are widely regarded as one of the safest and simplest types of surgery. According to research conducted by the Centers for Disease Control and Prevention (CDC), the Institute of Medicine, and reproductive health care provider Planned Parenthood, abortions performed during the first trimester pose significantly fewer risks to the mother’s health than abortions performed at the end of a normal pregnancy.
Medical abortions are deemed safe and successful till the ninth week of pregnancy because they do not require surgery. Mifepristone and misoprostol used together, are the most often used medicines for medical abortions in the United States. In this situation, a patient is first told to take mifepristone, better known as RU-486 or the “abortion pill,” which is given by a doctor.
The body’s normal production of progesterone, an important pregnancy hormone, is inhibited by this medicine. Two days later, the patient takes the second pill, misoprostol. This medication causes the uterus to contract and the embryo to be expelled. Medical abortions are less effective than surgical abortions, although they are less likely to cause infection. Medical abortions should not be confused with emergency contraception, a type of birth control pill used after unprotected sexual intercourse to prevent pregnancy rather than terminate it, according to health care professionals.
Medical abortions can be interrupted or “reversed” by taking a dose of progesterone, a hormone that mifepristone prevents the body from producing naturally. Medical abortions can be “reversed” or “interrupted” by administering a dose of progesterone, a hormone that mifepristone stops the body from producing naturally. In 2015, Arkansas and Arizona went above and beyond the statute requiring doctors to advise patients that after taking the mifepristone pill, clinical abortions can be interrupted or “reversed” by taking a dose of progesterone, a hormone that mifepristone prevents the frame from producing naturally.
Due to a lawsuit brought jointly by the American Civil Liberties Union, Desert Star Family Planning, the Center for Reproductive Rights, and Planned Parenthood, Arizona governor Doug Ducey revoked his state’s statute in 2016. The state was unable to offer scientific evidence supporting the argument that medical abortions are reversible, therefore the lawsuit was dropped within months after Ducey’s repeal vote. Similar legislation has been enacted in Idaho, South Dakota, and Utah, despite many health care professionals calling such statements ridiculous and emphasizing that no medical evidence suggests the process can be undone.
In April 2018, Dr. George Delgado, a general practitioner who first suggested the concept in 2012 with a case series of seven patients, published a paper with a larger case series and six co-authors advising that the method should effectively reduce mifepristone side effects by about 48 percent of medical abortions. Health care professionals and reproductive rights campaigners were skeptical of Delgado’s paper.
Legislative History in United States of America
Abortions were prevalent in the United States at the time of their creation, and they were not prohibited by law until 1821 when Connecticut approved the first anti-abortion statute. Until the Roe Vs Wade decision, abortion laws were left to the discretion of state legislatures. In most situations, abortion was categorized as a felony crime in 49 states and the District of Columbia by 1967. Colorado, on the other hand, approved a law allowing women to seek voluntary abortions the same year. Following Colorado’s lead, several other states liberalized their abortion regulations. Abortion restrictions had been overturned in four states and liberalized in fourteen by 1973.
In states where abortions were illegal, women who wanted to end their pregnancies sought out illegal abortions performed by health care practitioners who risked losing their jobs or by people who lacked the necessary expertise or equipment to perform the surgery safely. In Roe Vs Wade, the United States Supreme Court found that stringent abortion restrictions were unconstitutional and infringed on a woman’s right to privacy. While the Constitution did not expressly mention a right to privacy, the justices who backed the decision argued that the Fourteenth Amendment’s Due Process Clause provided such a right. An unborn fetus is not a person in the legal sense, according to the Court’s opinion.
According to the Supreme Court’s ruling, the government “has legitimate interests in maintaining both the pregnant woman’s fitness and the potentiality of human life, each of which interests will rise and reach a ‘compelling’ status at multiple levels of the woman’s progress to term.” The choice to terminate a pregnancy during the first trimester was made solely by the lady and her physician, according to the verdict. The judgment also allowed state governments to enact second-trimester laws, prohibiting abortion after the fetus has attained viability except in circumstances where the mother’s health is jeopardized.
The ability of a fetus to survive outside of the womb is referred to as viability. The point at which a pregnancy reaches viability is still a source of contention. The term’s vagueness adds to the debate over whether state abortion restrictions are lawful. Similarly, state legislators do not always use the same definitions for what constitutes a pregnancy that puts the mother’s health in jeopardy.
In Doe Vs Bolton[ii], a companion case to Roe Vs Wade decided on the same day, the Supreme Court upheld its ruling in Roe Vs Wade by prohibiting laws that require admission to a sanatorium, approval by a sanatorium abortion committee, a second, and 1/3 scientific opinion, or felony domicile in a province before contraception could be executed. The decision further expanded the definition of what constitutes a health concern to the mother during a post-viability abortion, allowing a doctor to take into account the woman’s age as well as her emotional and psychological well-being. The outcomes of these two cases resulted in a significant reduction in maternal mortality rates.
The Roe Vs Wade judgment gave pro-life campaigners a concrete goal to work toward to develop a political movement. In reaction to states liberalizing their abortion laws, activists created the National Right to Life Committee, the country’s oldest pro-life group, in 1968. In reaction to the Supreme Court’s decision, Americans United for Life, which was founded in 1971, devised a legal defense.
Approximately 20,000 pro-life advocates marched in Washington, DC, on the first anniversary of the Supreme Court’s decision in the March for Life, which has become an annual ritual for pro-life campaigners. In other cases, critics of the court’s ruling argue, unborn children are legally deemed, individuals. For example, unborn children have the right to inherit property. In some states, if an unborn child is killed inadvertently, the person responsible can be charged with manslaughter. These contradictions, according to critics, indicate the decision’s lack of legal grounding.
Even though Roe Vs Wade serves as the national norm for abortion regulation in the United States, the Supreme Court has heard various cases challenging the decision. The outcomes of certain cases have called the initial judgment into doubt, while others have expanded abortion rights. The Supreme Court ruled against various limits imposed by Missouri’s abortion legislation in the 1976 case Planned Parenthood Vs Danforth[iii], therefore extending abortion availability.
However, a year later, in Maher Vs Roe[iv], the Supreme Court declared that state governments might refuse to provide public financing for abortions, giving the government more authority over reproductive health care. The Hyde Amendment, a piece of law established by Congress in 1976 that removed abortion from the list of medical services offered and reimbursed by Medicaid, a federal and state government program that subsidizes medical expenditures for low-income patients, was used in the Maher Vs Roe ruling.
Many state legislatures enacted laws in the 1990s that imposed new rules on abortion providers, which pro-choice campaigners claimed would limit access to abortions. Some of these rules included requirements for the size and width of the examining rooms in which the process would be done. Other regulations required abortion practitioners and facilities to be linked with a hospital or to conduct abortions within a set distance of one. These laws are known as Targeted Regulation for Abortion Providers (TRAP) measures by pro-choice advocates. TRAP opponents contend that the rules impose unreasonable costs on patients and healthcare professionals, in contravention of Supreme Court precedents. In Whole Woman’s Health Vs Hellerstedt[v], the Supreme Court considered a Texas measure that imposed limits on abortion providers.
The Texas bill’s requirements did not offer enough medical advantages, according to the court, to warrant the burden placed on women seeking abortions. The distribution of government cash is still a hot topic in the abortion debate. Grants for family planning programs are available under Title X of the Public Health Service Act of 1970. In March 2017, the Senate narrowly passed legislation repealing a prohibition on states refusing Title X payments to abortion providers. The Obama administration released the regulation soon before the president departed office.
The Senate’s resolution prevents more than $200 million from flowing to Planned Parenthood and other abortion-related healthcare facilities. Critics point out that such organizations use the money for healthcare services other than abortions, even though the Hyde Amendment already bars the use of government funds for abortions unless there are exceptional circumstances. On April 13, 2017, President Donald Trump signed the bill into law.
The Supreme Court heard a case in March 2018 involving Crisis Pregnancy Centres (CPCs), which are non-profit organizations that help women avoid terminating undesired pregnancies. CPCs regularly misinform girls seeking abortions, according to reproductive rights activists, by conducting misleading marketing and marketing practices, intentionally imparting misguided information, treating girls seeking abortions with hostility, and lying to traffic to keep them from leaving the facility. California passed the Reproductive Freedom, Accountability, Comprehensive Care, and Transparency (Reproductive FACT) Act in 2015, which requires CPCs to inform their clients that the state offers free or subsidized reproductive health care services, such as family planning, prenatal care, and abortions, to qualified women. Women must be able to call a phone number listed on the facility’s website to confirm their eligibility.
Furthermore, the law mandates that establishments either provide proof of their medical license or disclose that the facility and its staff are unauthorized. This information must be prominently stated on location and in all print and digital advertising, according to the law.
The National Institute of Family and Life Advocates (NIFLA), a pro-life law firm representing over 1,400 licensed and unlicensed CPCs, has filed a lawsuit against the California Department of Justice, saying that the new rule inhibits free speech. Amicus briefs were submitted to the court by religious organizations, health care providers, public policy research institutes, legislators, and government organizations, including filings submitted by state government coalitions, one in favor of the petitioners and one in support of the respondents.
The case’s conclusion is expected to have an impact on prior Supreme Court judgments on free speech and state rights. Since 1973, pro-life and pro-choice groups have each won tiny triumphs in judicial battles over reproductive rights, but research shows that public opinion is more accepting of the Roe Vs Wade decision. According to a Pew Research Center poll published in 2017, 57% of Americans say abortion should be allowed in most or all instances. Despite this, pro-life organizations have been outspoken and even militant in their opposition to abortion.
Social Issues
Many proponents of abortion rights argue that limitations on abortions harm the poor, particularly in developing countries. Though figures vary, the World Health Organization (WHO) believes that tens of thousands of women die each year as a result of complications from unsafe abortions. Despite the lack of specific numbers, WHO and other studies have found that the annual number of women dying from these complications has been consistently declining since the 1990s. The drop, according to the worldwide reproductive rights group Ipas, is due to the liberalization of abortion legislation as well as increased access to safe abortions and effective contraception. Ipas, on the other hand, warns that restrictive abortion policies in South Central Asia and Sub-Saharan Africa continue to play a major role in the global death toll from unsafe abortions.
Abortion restrictions, according to proponents of reproductive rights, can make abortion prohibitively expensive for low-income women. Restrictions on using government funds to pay for abortions, for example, prevent women from having equal access to the procedure. Furthermore, state laws that place limits on abortion may force a woman to seek an abortion in another state. Traveling to another state imposes a financial burden on the woman that she may not be able to meet.
Most nations across the world have regulations in place that restrict when, when, why, and how abortions can be performed. In the Dominican Republic, El Salvador, Nicaragua, the Philippines, Vatican City, and Malta, abortion is prohibited under any circumstances. Other countries, such as those in Latin America and the Caribbean, have draconian abortion regulations that allow abortions only when the mother’s life is in jeopardy.
Several developed countries, including Australia, Japan, and Sweden, allow voluntary abortions until the end of the first trimester while placing limitations during the second and third trimesters.
Activism and Reactions
The pro-life movement has spawned a slew of zealous activists, including those who stage public protests outside abortion clinics. Protesters at abortion clinics frequently brandish signs depicting fetuses to frighten witnesses, as well as yell condemnations and threats of violence at doctors and patients who enter these facilities. In 1994, Congress passed the Freedom of Access to Clinic Entrances (FACE) Act, making blocking the entrances of places that provide abortion counseling or services a federal felony punishable by penalties and jail.
To further their goal, some anti-abortion activist groups have used extreme tactics. Domestic terrorism has been committed by members of the militant pro-life movement Operation Rescue, including the bombing of abortion facilities and the relentless intimidation of health care personnel who perform abortions. Scott Roeder, a member of Operation Rescue, assassinated famed abortion practitioner George Tiller at his Kansas church in 2009.
The Center for Medical Progress, a pro-life organization, gained national notoriety in 2015 when it released footage of Planned Parenthood employees secretly recorded by activists. Employees talked about fetal tissue sales, sex-selective abortions, and abortions for teenage prostitutes on the tapes. Reproductive rights groups denounced the videos as being manipulated deceptively and misleadingly, while anti-abortion activists praised them as citizen journalism. F However, the two anti-abortion activists who recorded the undercover recordings were charged in March 2017 with fifteen felony counts of invasion of privacy for videos shot in California.
As a result of the threats to reproductive rights, pro-choice organizations have rallied to defend themselves. After conservative Republicans blocked President Obama’s Supreme Court nominee, Merrick Garland, during his final year in office, and then won majorities in both houses of Congress and the presidency in 2016, many pro-choice organizations were concerned that a Republican-majority government would impose further restrictions on abortion access and nominate a pro-life justice to the Supreme Court, many pro-choice organizations were concerned that a Republican-majority government would impose further restrictions on abortion access and nominate a pro-life justice.
Even though Gorsuch has not ruled on any abortion cases, pro-life organizations praised Trump’s choice because of his opposition to assisted suicide and other related problems. Senate Democrats filibustered Gorsuch’s nomination until Senate Republicans, who were in the majority at the time, voted to amend the Senate rules, allowing Gorsuch’s confirmation to be decided by a simple majority vote—a method known as “the nuclear option.” Gorsuch received his confirmation on April 7 and was sworn in two days later.
The election of President Trump, paired with Republican majorities in both chambers of Congress, has been attributed with encouraging state legislatures in Indiana, Kentucky, Ohio, and Mississippi to implement or propose more draconian abortion restrictions. The new legislation has been challenged in court by civil liberties and women’s rights organizations. For example, in April 2018, the Jackson Women’s Health Organization, Mississippi’s only legal abortion facility, filed a lawsuit against the state, claiming that a new law prohibiting abortions after fifteen weeks violates the Supreme Court’s precedent that women have the right to terminate a pregnancy before the fetus reaches viability.
Recent scenario of Abortion rights in the United States
Several states have passed laws this year limiting or preventing access to abortion care, as they have done since the United States Supreme Court’s Roe Vs Wade ruling in 1973. In two respects, however, these legislative attempts differ from those of past years. First, there’s the contrast in sheer volume: According to the Guttmacher Institute[vi], the United States has already experienced the largest number of abortion restrictions implemented in a single year in 2021. The legal context: Under a majority-conservative Supreme Court, the constitutional and judicial landscape in which this newly adopted statute will operate is extremely precarious.
Dobbs Vs Jackson[vii] Women’s Health Organization, a lawsuit challenging Mississippi’s 15-week abortion prohibition, will be heard by the Supreme Court in May 2021. In September 2021, the Supreme Court approved the implementation of S.B., a Texas statute. S.B. essentially bans abortion beyond six weeks and establishes a private right of action that empowers “any individual” to sue anybody who assists a person in obtaining abortion treatment, such as abortion providers, abortion funding, family members, or acquaintances[viii]. Both of these bills are in direct conflict with Roe Vs Wade and Planned Parenthood of South-eastern Pennsylvania Vs Casey[ix], which protect the right to abortion and forbid states from prohibiting it before viability.
This issue brief examines the abortion bans[x] and limitations enacted by state legislatures this year, including Texas’ most recent bill, as well as states that have safeguarded and extended abortion rights.
States having abortion bans or restrictions in place for 2021
This year, several state legislatures have stood out as particularly unfriendly to abortion access. So far in 2021[xi], Arkansas has adopted draconian abortion legislation. A near-total prohibition on abortion, limits on medication abortion access, TRAP laws targeting abortion clinics, an ultrasound requirement, a ban restricting the use of public funding for abortion, and other measures are among them. Arizona enacted a bill containing several abortion restrictions, including a genetic anomaly-based cause ban, pharmaceutical abortion limitations, TRAP legislation, financing limits for research utilizing fetal tissue, and a prohibition on providing abortion treatment at public educational institutions[xii]. These limitations would exacerbate existing hurdles to abortion care and put abortion out of reach for many people in these states.
Near-total bans, trigger bans, reason bans, and gestational bans are among the new limitations adopted this year that fall under the heading of an abortion ban. Arkansas’ new legislation forbids abortion in all circumstances, except endangering the life of the pregnant woman. Abortion is legal in Oklahoma only if it is “necessary to avert the mother’s death or considerable or irreparable bodily disability that considerably raises the risk of death[xiii]“.
Idaho, Texas, Oklahoma, and South Carolina have all implemented restrictions that go into effect when a fetal “heartbeat[xiv]” is detected in an ultrasound, which is usually before most women are even aware they are pregnant. Because of how early in pregnancy they fall—typically six weeks after a pregnant person’s LMP—these so-called heartbeat laws are manifestly illegal and will most likely be challenged in the courts. Even if the Supreme Court rules that Mississippi’s 15-week ban is constitutional, the ruling might be construed in such a manner that it rules that six-week restrictions are not. These laws are all the more concerning now that the fate of constitutional abortion protections is in the hands of the Supreme Court, especially given the court’s recent failure to intervene in Texas’ S.B. These laws are all the more concerning now that the fate of constitutional abortion protections is in the hands of the Supreme Court.
Other broad-based restrictions passed this year include trigger bans in Oklahoma and Texas, which will outlaw abortion if the Roe Vs Wade judgment is overturned or gutted, joining ten other states that have already done so. Oklahoma adopted a law this year that will take away medical licenses from those who provide abortion treatment, with few exceptions, in addition to adopting both a trigger ban and a near-total ban. Finally, the legislatures of Kansas, Kentucky (for the second year in a row), and Iowa passed amending their constitutions to include language saying that the state does not recognize or grant a right to abortion. The legislation in Kansas and Kentucky have been passed, but they must be approved by a voter initiative before the state constitutions may be changed. They indicate the legislators’ resistance to the right to abortion, even if they have a limited immediate effect.
The coronavirus pandemic demonstrated the value of telemedicine in increasing access to health care and guaranteeing continuity of treatment, as well as the crucial role of medication abortion in extending safe abortion alternatives. Even though several states took steps to improve telemedicine access, some specifically excluded abortion from their plans and imposed new limitations on medication abortion. Arizona, Indiana, Montana, Ohio, and Oklahoma have all passed legislation mandating medication abortion care to be delivered in person, thus prohibiting abortion care through telemedicine.
Another restriction enacted this year is that in Oklahoma, only physicians who are board-certified in obstetrics and gynaecology are allowed to perform medication abortions—a restriction on access that has been determined to not affect safety or quality of treatment. Furthermore, “abortion reversal” legislation has been established in Arkansas, Indiana, Louisiana, Montana, South Dakota, West Virginia, and Oklahoma, which force physicians to fraudulently advise patients that they may “reverse” an abortion after taking the first of two tablets in the pharmaceutical abortion regimen[xv].
Many legislators have done the exact opposite in a year when they have a special responsibility to maintain and extend access to high-quality, comprehensive health care. The power of courts to serve as a stopgap has already been weakened. If the Supreme Court finds against abortion rights in Dobbs Vs Jackson, Women’s Health Organization, that sliver of protection would be obliterated, making abortion care considerably more dependent on a person’s location and money than it is now. Individuals of color, low-income people, young persons, people with disabilities, transgender and nonbinary people, immigrants, and people residing in the South and Midwest will be disproportionately affected.
Efforts to defend and enhance Abortion Rights.
Relying on the courts for protection is insufficient, and proactive action is required to mitigate the effects of these state laws and to protect and extend access to abortion care. Some states have taken crucial measures to establish legislation that preserves and extends access to abortion care amid this assault of bans and restrictions: As a result of the six-week restriction in Texas, some physicians in states where abortion is regarded as vital health care are already seeing an inflow of patients.
- New Mexico: New Mexico removed its pre-Roe abortion restriction in February[xvi].
- California: In April, the state of California approved a resolution encouraging the federal government to defend reproductive rights such as the basic right to an abortion and access to comprehensive reproductive health care, which includes services offered by Planned Parenthood health centers[xvii].
- Hawaii: In April, the state of Hawaii passed a bill allowing advanced practice nurses to offer abortion care, hence increasing abortion access by allowing more trained clinicians to give treatment[xviii].
States have also taken steps to extend abortion insurance coverage and remove coverage limits, in addition to expanding providers:
- Virginia: In March, the state of Virginia passed legislation removing the bar on abortion coverage in health insurance plans purchased via the state’s insurance marketplace[xix].
- Washington: The state of Washington approved legislation in April mandating any student health plan that covers maternity treatments to also cover abortion services. This bill strengthens the state’s requirement that any state-regulated health plan that covers maternity care also cover abortion services[xx].
- Colorado: In May, the state of Colorado passed a bill easing limitations on abortion treatment in cases of rape or incest financed by public funding. It eliminates the requirement that these abortion services be performed only by physicians and in specific facilities, allowing a broader range of providers to provide medically necessary abortion care, including nurse practitioners and physician assistants who are licensed and acting within their scope of practice[xxi].
- Connecticut: In May, Connecticut’s governor signed a bill prohibiting crisis pregnancy centers from engaging in deceptive activities, such as not providing full reproductive health care and routinely attempting to discourage patients from seeking abortion treatment. These organizations frequently spread false information regarding abortion, such as claims that they can do abortion reversals, which are medically impossible[xxii].
Even with these proactive steps in place, abortion prohibitions in other states may limit abortion access across state boundaries. As a result of the six-week restriction in Texas[xxiii], some physicians in states where abortion is regarded as vital health care are already seeing an inflow of patients. One clinic in Oklahoma City has seen an increase in the number of calls it receives from Texas residents seeking abortions[xxiv] since S.B. went into effect, up from around five per day before the ban to roughly 55 per day since then.
Planned Parenthood facilities in Colorado, New Mexico, Arkansas, Kansas, and Oklahoma are likewise attempting to meet the increased demand for services. The rising number of individuals seeking medical help risks overburdening facilities and lengthening wait times[xxv]. Only Texas has been able to put a six-week ban into action so far, but clinics in abortion-friendly states are ready for additional states to follow suit. States will be better positioned to assist persons seeking abortion care locally and across state boundaries, if they take more aggressive initiatives to enhance access.
Conclusion
Finally, persistent state-level legislative initiatives to restrict abortion rights, as well as mounting legal threats, underline the need for a proactive abortion agenda at the federal and state levels that go beyond depending on the courts and secures meaningful access to abortion care for all. These attacks highlight the necessity for federal legislation, such as the Women’s Health Protection Act, to protect women’s health and codify meaningful abortion rights that are free of government intervention[xxvi].
Legislators and administrations at the state and federal levels may and should act to protect and extend abortion access, ensuring that, regardless of what happens in the courts, abortion access is not based on a person’s ZIP code, identity, or money.
Policymakers must continue to back and monitor activists, organizers, and advocates on the ground who are striving to provide genuine access to abortion care and to build a culture that values and accepts abortion as a vital medical procedure.
ABOUT THE AUTHOR
Arshia Jain is a second-year law student at SVKM’s NMIMS, School of Law in Navi Mumbai, Mumbai, India, pursuing a BBALLB. When it comes to work, she is a dedicated and hardworking individual. She believes in pursuing one’s dreams and remaining optimistic throughout life.
Edited by: Aashima Kakkar, Associate Editor, Law Insider
References
- State Abortion Legislation 2021 covered by american progress
- overview of abortion laws by guttmacher
- Why US abortion laws could be changed by Supreme Court ruling
- How the US Supreme Court’s verdict on Mississippi abortion law can affect women’s rights
- Why US abortion rights may be overturned covered by the week
- open access abortion by gale
[i] Roe Vs Wade, 410 U.S. 113 (1973)
[ii] Doe Vs Bolton, 410 U.S. 179 (1973)
[iii] Parenthood Vs Danforth, 428 U.S. 52 (1976)
[iv] Maher Vs Roe, 432 U.S. 464 (1977)
[v] Whole Woman’s Health Vs Hellerstedt, 579 U.S. 582 (more) 136 S. Ct. 2292; 195 L. Ed. 2d 665
[vi]State Policy Trends at Midyear 2021: Already the Worst Legislative Year Ever for U.S. Abortion Rights (Last Visited on December 28th, 2021)
[vii] Dobbs Vs Jackson, U.S. 19-1392
[viii] UNITED STATES DISTRICT COURT (Last Visited on December 28th, 2021)
[ix] Parenthood Vs Casey, 505 U.S. 833 (1992)
[x] U.S. Supreme court cases (Last Visited on December 28th, 2021)
[xi] STATE LEGISLATION TRACKER (Last Visited on December 28th, 2021)
[xii] abortion; unborn child; genetic abnormality (Last Visited on December 28th, 2021)
[xiii] An Act relating to physician licensure (Last Visited on December 28th, 2021)
[xiv] LEGISLATURE OF THE STATE OF IDAHO (Last Visited on December 28th, 2021)
[xv] 2021 South Dakota Legislature (Last Visited on December 28th, 2021)
[xvi]Legislation Chamber by Nmlegis (Last Visited on December 28th, 2021)
[xvii] BILL INFORMATION (Last Visited on December 28th, 2021)
[xviii] Hawaii State Legislature (Last Visited on December 28th, 2021)
[xix] HB 1896 Essential health benefits; abortion coverage. (Last Visited on December 28th, 2021)
[xx] Abortion covered by washington state department of health (Last Visited on December 28th, 2021)
[xxi] Health Care Access In Cases Of Rape Or Incest covered by Colorado General Assembly (Last Visited on December 28th, 2021)
[xxii] ACT CONCERNING DECEPTIVE ADVERTISING PRACTICES OF LIMITED SERVICES PREGNANCY CENTERS. by PUBLIC HEALTH COMMITTEE, CONNECTICUT (Last Visited on December 28th, 2021)
[xxiii] Texas Abortion Laws (Last Visited on December 28th, 2021)
[xxiv] Oklahoma Abortion Clinic’s Call Volume Spikes Over 10-Fold as Texas Law Takes Hold (Last Visited on December 28th, 2021)
[xxv] Texas Is Already Creating Abortion Refugees (Last Visited on December 28th, 2021)
[xxvi] A Proactive Abortion Agenda (Last Visited on December 28th, 2021)