WHEREAS, January 22, 2019, marks the 46th anniversary of the United States Supreme Courts landmark decision in Roe v. Wade (1973) 410 U.S. 113, which affirmed that every woman has a fundamental right to control her own reproductive decisions and to decide whether to end or to continue pregnancy, and is an occasion deserving of acknowledgment; and

WHEREAS, Roe v. Wade has been the cornerstone of womens ability to control their reproductive lives, allowing every woman in the United States the right to decide when, if, and with whom to have children, and how many children to have; and

WHEREAS, Womens ability to control their reproductive lives has helped and facilitated their participation in the economic and social life of our nation; and

WHEREAS, Roe v. Wade has drastically reduced the maternal mortality rate for women terminating their pregnancies in the United States. In the years prior to the decision, illegal abortion accounted for approximately 17 percent of all reported deaths attributable to pregnancy and childbirth, and many women were severely injured as a result of back alley abortion procedures; and

WHEREAS, Interference with a womans right to choose causes women to be forced into illegal and dangerous abortions, as they often were in the United States before the Roe v. Wade decision. Many women are forced to make these decisions today in countries where abortion is illegal and where the unsafe methods of illegal abortion lead to 13 percent of global maternal deaths annually, or eight maternal deaths every hour. Many survivors of an illegal abortion suffer serious and often permanent injuries; and

WHEREAS, Roe v. Wade continues to protect the health and freedom of women throughout the United States; and

WHEREAS, Roe v. Wade is in serious jeopardy due to President Donald J. Trumps appointment of two justices to the United States Supreme Court who have a record of being hostile to a womans constitutional right to choose, Neil Gorsuch and Brett Kavanaugh; and

WHEREAS, The State of California stands in strong support of every womans fundamental right, as confirmed in Roe v. Wade, to make her own decisions regarding her pregnancy; now, therefore, be it

Resolved by the Senate of the State of California, That the Senate urges the President of the United States and the United States Congress to express their support for a womans fundamental right to control her own reproductive decisions, as well as their support for access to comprehensive reproductive health care, including the services provided by Planned Parenthood; and be it further

Resolved, That the Secretary of the Senate transmit copies of this resolution to the President and Vice President of the United States, to the Speaker of the House of Representatives, to the Majority Leader of the Senate, to each Senator and Representative from California in the Congress of the United States, and to the author for appropriate distribution.

 THIRD READING  

Bill No: SR 7

Author: Leyva (D), Atkins (D), Caballero (D), Durazo (D), Galgiani (D), Hurtado (D), Jackson (D), Mitchell (D), Rubio (D) and Skinner (D)

Amended: 1/7/19

Vote: Majority

SENATE JUDICIARY COMMITTEE: 6-0, 1/17/19

AYES: Jackson, Allen, Caballero, Monning, Umberg, Wieckowski

NO VOTE RECORDED: Borgeas, Stern

SUBJECT: Women’s Reproductive Health

SOURCE: Author

DIGEST:

This resolution marks the 46th anniversary of the U.S. Supreme Court’s decision in the case Roe v. Wade (1973) 410 U.S. 113, which established the constitutional right to choose whether or not to carry a pregnancy to term.

ANALYSIS:

Existing federal law:

1. Holds that the federal constitution’s implied right to privacy extends to a woman’s decision about whether or not to have an abortion. (Roe v. Wade (1973) 410 U.S. 113.)
2. Authorizes the government to impose restrictions on abortion as long as those restrictions do not create an undue burden on a woman’s right to choose to terminate a pregnancy. (Planned Parenthood of Southeastern Pennsylvania v. Casey (1992) 505 U.S. 833.)

Existing state law:

1. Holds that the state constitution’s express right to privacy extends to a woman’s decision about whether or not to have an abortion. (People v. Belous (1969) 71 Cal.2d 954.)
2. Provides that every woman has the fundamental right to choose to bear a child or to choose and to obtain an abortion, with specified exceptions. (Health & Saf. Code Sec. 123462(b).)
3. Prohibits the state from denying or interfering with a woman’s fundamental right to choose to bear a child or to choose to obtain an abortion, with specified exceptions. (Health & Saf. Code Sec. 123462(c).)

This resolution:

1. Declares that:
2. the 46th anniversary of Roe v. Wade is an occasion deserving of acknowledgement;
3. Roe v. Wade has been the cornerstone to the ability of women to control when, if, with whom, and how many children to have, thus facilitating women’s participation in economic and social life;
4. Roe v. Wade has drastically reduced the percentage of women who die or are severely injured while attempting to terminate their pregnancies;
5. interference with the constitutional right to terminate a pregnancy forces women into illegal and dangerous abortions;
6. Roe v. Wade continues to protect the health and freedom of women throughout the U.S. by providing access to a safe medical procedure that nearly 25 percent of women will use;
7. the central holding of Roe v. Wade is in serious jeopardy as a result of recent U.S. Supreme Court appointments and state legislation creating barriers to abortion;
8. abortion service providers are facing increasing levels of violence for their work; and
9. the State of California strongly supports the constitutional right set forth in the holding of Roe v. Wade.
10. Urges the U.S. President and Congress to express their support for a woman’s fundamental right to control her own reproductive decisions, as well as their support for access to comprehensive reproductive care, including those provided by Planned Parenthood.

Background

Roe v. Wade (1973) 410 U.S. 113, is the landmark U.S. Supreme Court decision holding that the constitutional right to privacy extends to a woman’s decision whether to terminate a pregnancy, while acknowledging that some state regulation was permissible. The plaintiff in the case was “Jane Roe,” an unmarried woman who wanted to end her pregnancy under safe and clinical conditions but was unable to get a “legal” abortion in Texas because her life was not threatened by the continuation of the pregnancy. Unable to afford travel to another state to obtain an abortion, she challenged the statute making it a crime to perform an abortion unless a woman’s life was at stake. She also claimed that the Texas law abridged her right of personal privacy.

The court struck down the Texas law, finding for the first time that the constitutional right to privacy is “broad enough to encompass a woman’s decision whether or not to terminate her pregnancy.” At the same time, the high court also defined two compelling state interests that would satisfy restrictions on a woman’s right to choose to terminate a pregnancy: 1) states may regulate the abortion procedure after the first trimester of pregnancy in ways necessary to promote a woman’s health; and 2) after the point of fetal viability, a state may, to protect the potential life of the fetus, prohibit abortions that are not necessary to preserve a woman’s life or health.

Ongoing Legal Challenges to Roe v. Wade

Roe v. Wade has been one of the most debated U.S. Supreme Court decisions, and its application and continued validity have frequently been challenged in the courts. Most significantly, in Planned Parenthood of Southeastern Pennsylvania v. Casey (1992) 505 U.S. 833, the Court reaffirmed the basic holding of Roe v. Wade, yet also permitted the state to impose restrictions on abortion as long as those restrictions do not create an undue burden on a woman’s right to choose to terminate a pregnancy.

Exactly what constitutes an undue burden remains a point of frequent legal contention. For example, under this line of cases, the U.S. Supreme Court recently struck down a Texas law that required any facility performing abortions to meet the state requirements for an ambulatory surgical center and also required any doctor performing abortions to have admitting privileges at a hospital with 30 miles. (Whole Woman’s Health v. Hellerstedt (2016) ___ U.S. ___; 136 S. Ct. 2292). Since, in practice, almost no abortion facility or provider could meet these mandates, the Texas law had the practical effect of dramatically restricting access to abortion services in the state. By contrast, under Casey the U.S. Supreme Court upheld a federal statute that restricted so-called “partial birth abortions.” (Gonzales v. Carhart, 550 U.S. 124.)

Throughout this time, a minority of the U.S. Supreme Court’s justices have at various times indicated a belief that Roe v. Wade should be overturned. (See, e.g., Webster v. Reprod. Health Servs. (1989) 492 U.S. 490.) With President Trump’s recent appointment of Justices Neil Gorsuch and Brett Cavanaugh to the high court, it may be that a majority for overturning Roe v. Wade now exists.

As this resolution declares, there are numerous lawsuits regarding access to abortion services that are currently working their way through the courts. (See, e.g., Jackson Women’s Health Org. v. Currier (S.D.Miss. Nov. 20, 2018, No. 3:18-CV-171-CWR-FKB) 2018 U.S.Dist.LEXIS 198937; Whole Woman’s Health v. Paxton (W.D.Tex. 2017) 280 F. Supp. 3d 938; Hopkins v. Jegley (E.D.Ark. 2017) 267 F. Supp. 3d 1024; W. Ala. Women’s Ctr. v. Miller (M.D.Ala. 2016) 217 F. Supp. 3d 1313.) Any one of these could serve as a vehicle for weakening or overturning the central holding in Roe v. Wade. State governments or the federal government would then be free to impose additional restrictions on abortion or even outlaw it entirely.

Access to abortion in California might not be immediately affected by such a ruling, since the California Supreme Court has found a right to abortion access in the state constitution’s privacy clause. (People v. Belous (1969) 71 Cal.2d 954.) If Roe v. Wade were overturned, however, the federal government could potentially seek to impose nationwide restrictions on abortion that might override the existing state protections.

Economic and Social Impacts of Roe v. Wade

The existence of a constitutional right to choose whether, when, with whom, and how many children to bear has had a profound impact on the lives of women in the U.S. Indeed, in upholding the fundamental conclusion of Roe v. Wade while reaching its decision in Planned Parenthood v. Casey, the U.S. Supreme Court noted that “the ability of women to participate equally in the economic and social life of the Nation has been facilitated by their ability to control their reproductive lives.” (588 U.S. 833, 856.)

In reviewing a wide selection of data in 2013, the Guttmacher Institute reached similar conclusions. “Once young women were able to satisfy their education and first full-time job aspirations with a reduced risk of unplanned interruptions, their own expectations of their career trajectories—and the expectations of employers—evolved. Many began to seek and attain jobs and professional status in fields previously dominated by men.”

Sources for the Statistics Cited in this Resolution

This resolution states that, prior to Roe v. Wade, illegal abortion accounted for approximately 17 percent of all reported deaths attributed to pregnancy and childbirth, a statistic that comes from the Guttmacher Institute’s 2003 special analysis of conditions prior to the decision.

This resolution next declares that, globally, 13 percent of maternal deaths each year can be attributed to unsafe abortion. That statistic appears in a Review in Obstetrics & Gynecology article on the subject. The figure is also backed by the World Health Organization’s February 2018 Fact Sheet on the subject. That Fact Sheet, citing an internal WHO study, states that: “[e]ach year between 4.7% – 13.2% of maternal deaths can be attributed to unsafe abortion.”

This resolution goes on to assert that national peer-reviewed studies show that abortion is a safe medical procedure. This was the conclusion of a National Academies of Science, Engineering, and Medicine study on the matter.

With regard to the fraction of women who will access abortion services at some point in their lifetimes, this resolution states that it is one in every four women. This statistic is drawn from research published in the American Journal of Public Health.

Finally, this resolution’s statistics regarding rising levels of violence against abortion providers is supported by data collected and published by the National Abortion Federation.

SUPPORT: (Verified 1/22/19)

Planned Parenthood Affiliates of California

OPPOSITION: (Verified 1/22/19)

Californians for Life

ARGUMENTS IN SUPPORT: According to the author:

The 1973 Roe v. Wade decision ensuring safe and legal access to abortion has been the cornerstone of women’s ability to control their reproductive lives and has greatly improved the health of California women and families. The Roe v. Wade decision continues to improve women’s economic and societal participation by allowing women to decide when, if and with whom to have children. As other states are passing laws that create deliberate barriers to abortion access, it is critically important that California stands strong in support of Roe v. Wade. SR 7 validates that the State of California is committed to protecting and advancing access to reproductive health.

In support of this resolution, Planned Parenthood Affiliates of California writes:

Abortion accessibility has had a profound impact on the lives of women and families, giving all people the ability to control their reproductive decision and ensures their right to decide if, and when, to have children. With one in four women obtaining an abortion in their lifetime, the 46th anniversary of Roe V. Wade is a significant historical reminder of the importance of safe and medically accurate reproductive and sexual health care.

ARGUMENTS IN OPPOSITION: Californians for Life states in opposition, “In the US, 60 million human lives have been killed by abortion since 1973. […] Abortion is… inhumane, hurting millions of women for a lifetime…”

Prepared by: Timothy Griffiths / JUD. / (916) 651-4113

1/22/19 10:10:12

**** END ****

SENATE JUDICIARY COMMITTEE

Senator Hannah-Beth Jackson, Chair

2019-2020 Regular Session

Bill No: SR 7 (Author:Leyva)

Version: January 7, 2019

Hearing Date: January 17, 2019

Fiscal: No

Urgency: No

Consultant: TSG

SUBJECT

Women’s Reproductive Health

DIGEST

This resolution marks the 46th anniversary of the U.S. Supreme Court’s decision in the case Roe v. Wade (1973) 410 U.S. 113, which established the constitutional right to choose whether or not to carry a pregnancy to term.

EXECUTIVE SUMMARY

Roe v. Wade was decided on January 22, 1973. To mark the anniversary of the ruling, this resolution makes a series of California Senate findings regarding the positive impact of that ruling on the reproductive, economic, and social life of women and the nation as a whole. The resolution highlights recent trends – legal, legislative, and in the form of targeted violence and obstruction – that threaten to weaken or even overturn Roe v. Wade’s essential holding. It reaffirms California’s strong support for every woman’s fundamental right to make decisions regarding pregnancy and her own reproduction. With this in mind, the resolution urges the U.S. President and Congress to express support for a woman’s constitutional right to control her own reproductive decisions as well as for access to comprehensive reproductive health care services, including those of Planned Parenthood.

The resolution is author-sponsored. It is supported by reproductive health rights advocates and providers. Opposition is likely to come from those favoring greater restriction or outright prohibition on access to abortion.

PROPOSED CHANGES TO THE LAW

Existing federal law:

1. Holds that the federal constitution’s implied right to privacy extends to a woman’s decision about whether or not to have an abortion. (Roe v. Wade (1973) 410 U.S. 113.)
2. Authorizes the government to impose restrictions on abortion as long as those restrictions do not create an undue burden on a woman’s right to choose to terminate a pregnancy. (Planned Parenthood of Southeastern Pennsylvania v. Casey (1992) 505 U.S. 833.)

Existing state law:

1. Holds that the state constitution’s express right to privacy extends to a woman’s decision about whether or not to have an abortion. (People v. Belous (1969) 71 Cal.2d 954.)
2. Provides that every woman has the fundamental right to choose to bear a child or to choose and to obtain an abortion, with specified exceptions. (Health & Saf. Code Sec. 123462(b).)
3. Prohibits the state from denying or interfering with a woman’s fundamental right to choose to bear a child or to choose to obtain an abortion, with specified exceptions. (Health & Saf. Code Sec. 123462(c).)

This resolution:

1. Declares that:
2. the 46th anniversary of Roe v. Wade is an occasion deserving of acknowledgement;
3. Roe v. Wade has been the cornerstone to the ability of women to control when, if, with whom, and how many children to have, thus facilitating women’s participation in economic and social life;
4. Roe v. Wade has drastically reduced the percentage of women who die or are severely injured while attempting to terminate their pregnancies;
5. interference with the constitutional right to terminate a pregnancy forces women into illegal and dangerous abortions;
6. Roe v. Wade continues to protect the health and freedom of women throughout the U.S. by providing access to a safe medical procedure that nearly 25 percent of women will use;
7. the central holding of Roe v. Wade is in serious jeopardy as a result of recent U.S. Supreme Court appointments and state legislation creating barriers to abortion;
8. abortion service providers are facing increasing levels of violence for their work; and
9. the State of California strongly supports the constitutional right set forth in the holding of Roe v. Wade.
10. Urges the U.S. President and Congress to express their support for a woman’s fundamental right to control her own reproductive decisions, as well as their support for access to comprehensive reproductive care, including those provided by Planned Parenthood.

COMMENTS

1. Background

Roe v. Wade, (1973) 410 U.S. 113, is the landmark U.S. Supreme Court decision holding that the constitutional right to privacy extends to a woman’s decision whether to terminate a pregnancy, while acknowledging that some state regulation was permissible. The plaintiff in the case was “Jane Roe,” an unmarried woman who wanted to end her pregnancy under safe and clinical conditions but was unable to get a “legal” abortion in Texas because her life was not threatened by the continuation of the pregnancy. Unable to afford travel to another state to obtain an abortion, she challenged the statute making it a crime to perform an abortion unless a woman’s life was at stake. She also claimed that the Texas law abridged her right of personal privacy.

The court struck down the Texas law, finding for the first time that the constitutional right to privacy is “broad enough to encompass a woman’s decision whether or not to terminate her pregnancy.” At the same time, the high court also defined two compelling state interests that would satisfy restrictions on a woman’s right to choose to terminate a pregnancy: 1) states may regulate the abortion procedure after the first trimester of pregnancy in ways necessary to promote a woman’s health; and 2) after the point of fetal viability, a state may, to protect the potential life of the fetus, prohibit abortions that are not necessary to preserve a woman’s life or health.

2. Ongoing Legal Challenges to Roe v. Wade

Roe v. Wade has been one of the most debated Supreme Court decisions, and its application and continued validity have frequently been challenged in the courts. Most significantly, in Planned Parenthood of Southeastern Pennsylvania v. Casey (1992) 505 U.S. 833, the Court reaffirmed the basic holding of Roe v. Wade, yet also permitted the state to impose restrictions on abortion as long as those restrictions do not create an undue burden on a woman’s right to choose to terminate a pregnancy.

Exactly what constitutes an undue burden remains a point of frequent legal contention. For example, under this line of cases, the U.S. Supreme Court recently struck down a Texas law that required any facility performing abortions to meet the state requirements for an ambulatory surgical center and also required any doctor performing abortions to have admitting privileges at a hospital with 30 miles. (Whole Woman’s Health v. Hellerstedt (2016) ___ U.S. ___; 136 S. Ct. 2292). Since, in practice, almost no abortion facility or provider could meet these mandates, the Texas law had the practical effect of dramatically restricting access to abortion services in the state. By contrast, under Casey the U.S. Supreme Court upheld a federal statute that restricted so-called “partial birth abortions.” (Gonzales v. Carhart, 550 U.S. 124.)

Throughout this time, a minority of the U.S. Supreme Court’s justices have at various times indicated a belief that Roe v. Wade should be overturned. (See, e.g., Webster v. Reprod. Health Servs. (1989) 492 U.S. 490.) With President Trump’s recent appointment of Justices Neil Gorsuch and Brett Cavanaugh to the high court, it may be that a majority for overturning Roe v. Wade now exists.

As the resolution declares, there are numerous lawsuits regarding access to abortion services that are currently working their way through the courts. (See, e.g., Jackson Women’s Health Org. v. Currier (S.D.Miss. Nov. 20, 2018, No. 3:18-CV-171-CWR-FKB) 2018 U.S.Dist.LEXIS 198937; Whole Woman’s Health v. Paxton (W.D.Tex. 2017) 280 F. Supp. 3d 938; Hopkins v. Jegley (E.D.Ark. 2017) 267 F. Supp. 3d 1024; W. Ala. Women’s Ctr. v. Miller (M.D.Ala. 2016) 217 F. Supp. 3d 1313.) Any one of these could serve as a vehicle for weakening or overturning the central holding in Roe v. Wade. State governments or the federal government would then be free to impose additional restrictions on abortion or even outlaw it entirely.

Access to abortion in California might not be immediately affected by such a ruling, since the California Supreme Court has found a right to abortion access in the state constitution’s privacy clause. (People v. Belous (1969) 71 Cal.2d 954.) If Roe v. Wade were overturned, however, the federal government could potentially seek to impose nationwide restrictions on abortion that might override the existing state protections.

3. Economic and Social Impacts of Roe v. Wade

The existence of a constitutional right to choose whether, when, with whom, and how many children to bear has had a profound impact on the lives of women in the U.S. Indeed, in upholding the fundamental conclusion of Roe v. Wade while reaching its decision in Planned Parenthood v. Casey, the Supreme Court noted that “the ability of women to participate equally in the economic and social life of the Nation has been facilitated by their ability to control their reproductive lives.” (588 U.S. 833, 856.)

In reviewing a wide selection of data in 2013, the Guttmacher Institute reached similar conclusions. “Once young women were able to satisfy their education and first full-time job aspirations with a reduced risk of unplanned interruptions, their own expectations of their career trajectories—and the expectations of employers—evolved. Many began to seek and attain jobs and professional status in fields previously dominated by men.”^[1]

4. Sources for the Statistics Cited in the Resolution

The resolution states that, prior to Roe v. Wade, illegal abortion accounted for approximately 17 percent of all reported deaths attributed to pregnancy and childbirth, a statistic that comes from the Guttmacher Institute’s 2003 special analysis of conditions prior to the decision.^[2]

The resolution next declares that, globally, 13 percent of maternal deaths each year can be attributed to unsafe abortion. That statistic appears in a Review in Obstetrics & Gynecology article on the subject.^[3] The figure is also backed by the World Health Organization’s February 2018 Fact Sheet on the subject.^[4] That Fact Sheet, citing an internal WHO study, states that: “[e]ach year between 4.7% – 13.2% of maternal deaths can be attributed to unsafe abortion.”

The resolution goes on to assert that national peer-reviewed studies show that abortion is a safe medical procedure. This was the conclusion of a National Academies of Science, Engineering, and Medicine study on the matter.^[5]

With regard to the fraction of women who will access abortion services at some point in their lifetimes, the resolution states that it is one in every four women. This statistic is drawn from research published in the American Journal of Public Health.^[6]

Finally, the resolution’s statistics regarding rising levels of violence against abortion providers is supported by data collected and published by the National Abortion Federation.^[7]

5. Arguments Supporting or Opposing the Resolution

According to the author:

The 1973 Roe v. Wade decision ensuring safe and legal access to abortion has been the cornerstone of women’s ability to control their reproductive lives and has greatly improved the health of California women and families. The Roe v. Wade decision continues to improve women’s economic and societal participation by allowing women to decide when, if and with whom to have children. As other states are passing laws that create deliberate barriers to abortion access, it is critically important that California stands strong in support of Roe v. Wade. SR 7 validates that the State of California is committed to protecting and advancing access to reproductive health.

In support of the resolution, Planned Parenthood Affiliates of California writes:

Abortion accessibility has had a profound impact on the lives of women and families, giving all people the ability to control their reproductive decision and ensures their right to decide if, and when, to have children. With one in four women obtaining an abortion in their lifetime, the 46th anniversary of Roe V. Wade is a significant historical reminder of the importance of safe and medically accurate reproductive and sexual health care.

The Committee received no written opposition to the resolution.

Support: Planned Parenthood Affiliates of California

Opposition: None received

HISTORY

Related Pending Legislation: SB 24 (Leyva) requires each student health care services clinic on a California State University or University of California campus to offer abortion by medication techniques, as specified, beginning in 2023.

Prior Legislation:

SR 72 (Leyva, 2018) was substantially similar to SR 7.

SR 12 (Atkins, 2017) was substantially similar to SR 7.

HR 32 (Atkins, 2016) was substantially similar to SR 7.

SJR 19 (Jackson, Res. Ch. 52, Stats. 2016) was substantially similar to SR 7.

SR 55 (Jackson, 2014) urged the U.S. Senate to reconsider and approve SB 2578, the “Not My Boss’s Business Act,” which sought to prevent employers from denying coverage of contraceptives regardless of their religious views.

SR 10 (Jackson, 2013) recognized, on the 40th anniversary of Roe v. Wade, the critical importance of continued access to safe and legal abortion. SR 10 also made a series of California Senate findings regarding the effect of Roe v. Wade on the ability of women to exercise their full rights under federal and state law. Finally, SR 10 urged the U.S. President and Congress to protect and uphold the intent and substance of Roe v. Wade’s holding.

SJR 19 (Alquist, 2005) was similar to SR 10. SJR 19 was referred to this Committee but not set for hearing.

AJR 3 (Cohn, Res. Ch. 83, Stats. 2005) was nearly identical to SJR 19

AJR 57 (Jackson, Res. Ch. 50, Stats. 2004) was nearly identical to AJR 3.

AJR 2 (Jackson, Res. Ch. 63, Stats. 2003) was nearly identical to AJR 57.

SJR 3 (Karnette, Res. Ch. 112, Stats. 2001) was substantially similar to AJR 2.

**************

1. Sonfield et al, The Social and Economic Benefits of Women’s Ability to Determine Whether and When to Have Children, (March 2013) Guttmacher Institute <https://www.guttmacher.org/sites/default/files/

   report_pdf/social-economic-benefits.pdf> p. 11 (as of Jan. 10, 2019). ↑

2. Gold, Lessons from Before Roe: Will Past Be Prologue? (March 2003) Guttmacher Institute Policy Review <https://www.guttmacher.org/gpr/2003/03/lessons-roe-will-past-be-prologue> (as of Jan. 10, 2019). ↑

3. Haddad and Nour. Rev Obstet Gynecol. 2009 Spring; 2(2): 122–126. (“Some 68,000 women die of unsafe abortion annually, making it one of the leading causes of maternal mortality (13%).”) ↑

4. Preventing Unsafe Abortion (February 2018) World Health Organization <https://www.who.int/en/news-room/fact-sheets/detail/preventing-unsafe-abortion> (as of Jan. 10, 2019). ↑

5. The Safety and Quality of Abortion Care in the United States (March 2018) National Academies of Science, Engineering, and Medicine <https://www.nap.edu/resource/24950/

   03162018AbortionCarehighlights.pdf> (as of Jan. 10, 2019). (“Legal abortions in the United States—whether by medication, aspiration, D&E, or induction—are safe and effective.”) ↑

6. Rachel K. Jones, Jenna Jerman, “Population Group Abortion Rates and Lifetime Incidence of Abortion: United States, 2008–2014”, American Journal of Public Health 107, no. 12 (December 1, 2017): pp. 1904-1909. ↑

7. 2017 Violence and Disruption Statistics. National Abortion Federation <https://prochoice.org/wp-content/uploads/2017-NAF-Violence-and-Disruption-Statistics.pdf> (as of Jan. 10, 2019). ↑