Dobbs: The Impact Beyond the Doctor’s Office

by Jasmyn Hardin, Associate Member, University of Cincinnati Law Review Vol. 93

I. Introduction

The Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, overturning nearly 50 years of precedent set by Roe v. Wade, has proven to be a highly consequential decision for the women and children of America.[1] Among developed nations, America ranks the highest in maternal mortality, deeming it the “most dangerous place” to deliver a child.[2] Over the past decade, abortion restrictions have become increasingly constraining, erecting new barriers in society while simultaneously exacerbating systemic failures faced by historically oppressed groups.[3]

One-third of US counties are considered “maternity care deserts,” which are areas lacking access to a birthing facility or an obstetric clinician.[4] This reality is most harmful to low-income areas and communities of color with a high rate of uninsured women of reproductive age.[5] Women living in maternal care deserts are most susceptible to receiving inadequate prenatal care, elevating the risk of potential complications during and after pregnancy, the periods during which maternal mortality most often occurs.[6]

While important, the impact of restricted abortion access goes “beyond immediate reproductive care concerns” to women, as it disrupts the economy, healthcare systems, and society at large.[7] Restrictive abortion policies cost the U.S. economy billions of dollars each year as a result of reduced labor participation.[8] Decreased labor participation equates to less financial freedom for women, with restrictive abortion policies often working to “deepen and entrench poverty among women and children,” further widening equity gaps.[9] Further, following Dobbs, the healthcare system has faced a shortage of workers, most importantly, maternal healthcare providers, affecting the ability of those in hostile states to receive quality healthcare.[10]

Given the long history of “overtly oppressive” policies towards communities of color, a one-size-fits-all approach is wholly inadequate.[11] The acknowledgment of systemic barriers is crucial to the understanding that race, class, and gender collectively play a role in perpetuating health inequities.[12]

This article explores the wide-ranging and consequential societal impacts of Roe’s reversal. Part II provides background on the evolution of abortion case law and legislation in the United States. Part III discusses the impact of increasingly restrictive abortion policies on three primary areas: (1) the undue burden placed on women, (2) societal costs, and (3) the healthcare system. Finally, Part IV concludes by arguing that restrictive abortion policies are erecting new societal barriers while exacerbating systemic barriers, disproportionately worsening health disparities among groups that have historically faced years of societal oppression.

II. Background

Maternal mortality is a “marker of national health and well-being.”[13] As defined by the World Health Organization, maternal death is the “death of a woman while pregnant or within 42 days of termination of pregnancy,” excluding accidental or incidental causes.[14] As of 2022, the United States leads all high-income nations with a maternal mortality rate of 22.3 maternal deaths per 100,000.[15] Black women are the most significant outlier, with a rate of 49.5 maternal deaths per 100,000 live births, more than double the United States average rate and nearly triple the rate of White women.[16]

Since Roe was overturned, 41 states have enacted abortion bans with only limited exceptions. Restrictive abortion policies have increasingly begun to function as “structural determinants of health,” dictating who can access quality, affordable, and comprehensive healthcare.[17] Those without the resources to seek an abortion are forced to carry unwanted pregnancies to term, facing elevated risks of “negative sexual and reproductive outcomes.”[18]

A. Roe-Related Case Law

Since 1973 and until 2022, Roe v. Wade preserved a woman’s fundamental right to seek an abortion.[19] The United States Supreme Court held that a Texas law, which banned all abortions except in extreme cases to save the life of the mother, violated the Due Process Clause of the Fourteenth Amendment’s implied right of privacy to decide the outcome of their pregnancy.[20] Also decided in 1973, the Supreme Court, in Doe v. Bolton, held that a Georgia law banning abortions except to save the life of the mother, fetal abnormalities, or rape was unconstitutional.[21] The Court found this law to be unconstitutional because it placed “too many restrictions” on women, requiring all abortions be performed in accredited hospitals, required approval from three physicians and a hospital committee, and permitted relatives to challenge the abortion decision.[22]

Later, in 1992, the Supreme Court reaffirmed a woman’s constitutional right to an abortion in Planned Parenthood v. Casey.[23] In this ruling, the Court adopted the “undue burden” framework, which permitted state abortion regulation so long as it did not place a “substantial obstacle in the path of a woman seeking an abortion of a nonviable fetus.”[24] The Pennsylvania law at issue in the case required informed consent, a 24-hour waiting period, and parental/guardian consent for minors, which the Court did not find to unduly burden the right to an abortion.[25]

B. Dobbs-related Case Law

In 2018, Mississippi passed the Mississippi Gestational Act, which banned abortions after 15 weeks except for cases of medical emergencies or severe fetal abnormality.[26] This state law, challenged in Dobbs v. Jackson Women’s Health Organization, was deemed unconstitutional under Casey in both the district and appeals courts before proceeding to the United States Supreme Court, where it was later upheld.[27] The Dobbs decision, overturning nearly 50 years of precedent, held that the Constitution “does not confer a right to abortion,” returning the issue of reproductive health to the states.[28] As of current, 17 states are said to have the “most restrictive” abortion laws, altogether banning abortions with minimal exceptions.[29] A bulk of these states lie within the South and Midwest regions of the United States, where there also tends to be a higher population of women of reproductive age.[30] The South is home to the largest concentration of Black people, with 18% of the population living 125% below the poverty line.[31] The poverty rate among all families with children under 18 years is 16.9%, compared to 38.2% for female-headed households with children under 18 years.[32] The Court’s decision has proven detrimental to the women and children of America, further widening the equity gap with “adverse implications for population health and health inequities.”[33]

III. Discussion

 The systemic barriers embedded within U.S. society result from a long history of oppressive policies towards minority groups, which have continued to “shape contemporary access to health-promoting resources and opportunities.”[34] As more and more states implement restrictive abortion policies, women have faced increased difficulty in accessing quality, affordable, and culturally appropriate healthcare.[35] This Part will discuss the impact of these restrictive policies on three primary areas: (1) the undue burden placed on women, (2) societal costs, and (3) the healthcare system. These impacts, while consequential for all women, function as an added compounding factor for Black women, a group that has faced years of societal oppression.

A. Undue Burden on Women

Restrictive abortion laws negatively affect women in a variety of ways. Women in states with “hostile” abortion laws experience increased mortality, hysterectomy, and cesarean delivery compared with women in states with “supportive” abortion laws.[36] These states also face a shortage of primary care providers, putting women at risk of the “delay or omission” of treatment early in the prenatal stage or if acute complications arise.[37] Women with preexisting conditions or those who develop comorbidities experience an even greater risk of complications during pregnancy.[38] Maternal mortality most often occurs during the “fourth trimester,” which is the 12 weeks after childbirth, after Medicaid has expired.[39] This is problematic as women are often unable to afford continued postpartum care, subjecting them to significant risk of complications and, thus, death.[40]

Women denied abortions are more susceptible to poverty, weakening their personal economic status in society, and limiting their overall societal contributions.[41] In post-Dobbs America, with decreased access to abortion, women nationally are forced to travel three times longer to seek an abortion.[42] Increased travel time could pose an even greater threat to the mother and child if the mother is experiencing a medical emergency.[43] Increased travel time also means that women are losing wages due to missed work and expending money on transportation and lodging solely to receive quality healthcare.[44] These additional costs also divert funds from other necessities, such as groceries and rent.[45]

In Georgia, a 28-year-old Black woman learned she was pregnant shortly after Georgia’s six-week abortion ban went into effect, and she was just beyond the deadline.[46] She took off work to travel to a clinic in North Carolina but missed her appointment due to traffic.[47] She was given Mifepristone, an abortion pill, which she subsequently took and drove home before taking the second dose.[48] She lived four hours away from the nearest clinic, and was unable to follow-up within the recommended period, and subsequently died after developing a rare complication.[49] This is only one of many stories impacting young, otherwise healthy women in America.[50]

Ensuring women’s access to affordable and comprehensive healthcare is imperative to improving maternal health outcomes.[51] Medicaid’s expansion to include postpartum coverage via the Affordable Care Act provided coverage to individuals up to 138% of the federal poverty line; 41 states (including DC) have adopted this expansion, and ten states have yet to adopt this change.[52] Coincidentally, the majority of states that have failed to adopt the Medicaid expansion policy are states with stricter abortion laws.[53] Women of color comprise nearly two-thirds of reproductive-age women who are ineligible for Medicaid, leaving 13% of Black women aged 15-49 without health insurance, compared to 8% of White women.[54] With 84% of maternal deaths being preventable, maximizing insurance coverage would go a long way in improving maternal health outcomes and increasing access to preventive care for the entire duration of pregnancy, ultimately reducing the overall incidence of maternal mortality.[55]

States such as Oregon and Vermont have increased abortion protections by removing gestational duration restrictions, using Medicaid funds to cover abortion, expanding those who can perform abortions, and enacting shield laws that protect providers and out-of-state residents seeking treatment.[56] States with less restrictive abortion policies have experienced “significant reduction” in the disparities between Black and White women in adverse birth outcomes and a 50% reduction in infant mortality, most notable among African American infants.[57]

B. Societal Costs

In 2023, restricted abortion access cost the United States an average of $173 billion per year, an increase from $146 billion in 2023, as a result of reduced labor force participation from women of reproductive age.[58] Abortion restrictions prevented nearly 597,000 women aged 15 to 44 from entering the labor force, with a cumulative earning potential of $4.3 billion per year lost.[59] Additionally, states with strict abortion laws are at risk of businesses leaving their state, with less restrictive states pitching them as “better alternatives for business.”[60] Some Fortune 500 companies, such as JPMorgan Chase and the Walt Disney Company, have publicly announced that they will help employees access abortion if unable to do so in their home state.[61] While there have not been any announcements of businesses canceling expansion or relocating from restrictive abortion states, this could potentially become an issue in the future.[62]

Racial, economic, and societal disparities are becoming increasingly “cumulative and compounding,” erecting barriers to healthcare that are “difficult, if not impossible, to overcome” for communities of color.[63] Restrictive abortion policies also work to impoverish women and children, deepening equitable divides.[64] Decreased abortion access elevates the number of women forced to carry unwanted pregnancies to term, placing a more significant strain on the already overburdened foster care system.[65] Post-Dobbs, there has been an 11% increase in foster care placement in states with restrictive abortion laws compared to those without.[66] Equitable access to abortion care is imperative to achieving racial, economic, and gender equity.[67]

Paid family leave could also improve birthing outcomes by removing the financial stress that accompanies a woman’s recovery time and transition post-childbirth, which is “key to maternal and infant health.”[68] The United States is one of two countries worldwide without a national paid family leave policy, which could explain why it remains a leader among high-income nations for maternal death.[69] Around the rest of the world, paid maternity leave is the norm, averaging between 18 weeks and, in some cases, extending beyond six months.[70]

C. The Healthcare System

The Dobbs decision has also had negative impacts on the healthcare system.[71] Recent medical school graduates are avoiding states with hostile abortion laws, with OB-GYN residency programs seeing a 10% decrease in 2023 alone.[72] This trend will prove to be detrimental to the healthcare worker shortage, as providers are opting not to move to states with strict abortion bans, given that their potential for criminal liability increases.[73] Less restrictive states have increasingly passed “interstate shield laws,” which protect abortion providers and out-of-state patient medical records.[74] While this helps, providers’ fear of prosecution ultimately results in lower quality healthcare for women, as providers are simply “unsure” if performing abortion services are legal, thus “muddling their ability” to use their medical judgment.[75]

Along with abortion access, it is imperative to provide high-quality maternity care that “acknowledges and respects the cultural experiences and contexts in which women live.”[76] Women of all backgrounds should have access to culturally competent healthcare providers who recognize the “potential impact of cultural differences…and adapt services to meet culturally unique needs.”[77] Historically, the pain of Black women is “systematically undertreated” compared to White women.[78] Research shows that White medical students and residents hold false perceptions about Black people and even go so far as to believe that the “Black body is biologically different and, in many cases, stronger” than the White body.[79] Black women are fighting just to get their foot in the door, only to be subjected to implicit biases when they get there, merely because of their skin color. Pain does not discriminate; humans do. Racial biases have penetrated the healthcare system, requiring a holistic and comprehensive approach to address years of systemic oppression.[80] Cultural competency within the healthcare system is essential to addressing disproportionate health disparities faced by communities of color.[81]

 IV. Conclusion

The impact of restrictive abortion policies not only places an undue burden on women but has a broader impact on the healthcare system, the economy, and society as a whole.[82] The culmination of systemic racial, economic, and societal disparities, along with increasingly restrictive barriers to access quality maternal healthcare, have proven to be “difficult, if not impossible, to overcome” for historically oppressed groups.[83] Restrictive abortion policies are worsening elevated poverty rates among women and children, further widening equity gaps.[84]

With restrictive abortion policies, governments are practically forcing women to carry unwanted pregnancies to term.[85] Women may decide to terminate their pregnancies for a variety of reasons. A non-relevant party should not restrict them in making a personal decision that ultimately impacts them most. Women with less access and minimal resources are left to carry an unintended pregnancy to term or seek out riskier measures and potentially face criminal liability.[86] Assuming a woman lives through childbirth and survives the crucial postpartum window, she is highly susceptible to a life of poverty, with little to no help from the same government that forced her to carry the child initially.[87] Restrictive abortion policies are proving to do more harm than good, implementing new societal barriers while exacerbating systemic ones that have functioned to disproportionately worsen health disparities among groups that have faced years of societal oppression.

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[1] Dobbs v. Jackson Women’s Health Org., 597 U.S. 215 (2022); Roe v. Wade, 410 U.S. 113 (1973); Kelly Baden, et al., Clear and Growing Evidence That Dobbs Is Harming Reproductive Health and Freedom, Guttmacher (May 31, 2024), https://www.guttmacher.org/2024/05/clear-and-growing-evidence-dobbs-harming-reproductive-health-and-freedom.

[2] Ognjen Š. Miljanić, America is the most dangerous place to give birth in the developed world – it’s only getting worse, The Hill (Sept. 20, 2022, 10:30 AM), https://thehill.com/opinion/healthcare/3650993-america-is-the-most-dangerous-place-to-give-birth-in-the-developed-world-its-only-getting-worse/.

[3] Sara K. Redd et al., Variation in Restrictive Abortion Policies and Adverse Birth Outcomes in the United States from 2005 to 2015, 32 Women’s Health Issues, 103, 109 (2022).

[4] Nowhere to Go: Maternity Deserts Across the US, 2024 Report, March of Dimes, https://www.marchofdimes.org/maternity-care-deserts-report (last visited Oct. 12, 2024).

[5] Id.

[6] Id.

[7] Claire D. Brindis et al., Societal Implications of the Dobbs v. Jackson Women’s Health Organization Decision, 403 Lancet, 2751, 2751 (2024).

[8] Abortion Bans Harm Women’s Reproductive Freedom and Cost our Economy Billions of Dollars, U.S. Congress Joint Economic Comm. Democrats (July 9, 2024) [hereinafter Abortion Bans], https://www.jec.senate.gov/public/index.cfm/democrats/2024/7/abortion-bans-harm-women-s-reproductive-freedom-and-cost-our-economy-billions-of-dollars [https://perma.cc/U9X6-KYTU].

[9] Restricted Access to Abortion Violates Human Rights, Precludes Reproductive Justice, and Demands Public Health Intervention, American Public Health Association (Nov. 3, 2015) [hereinafter Restricted Access], https://www.apha.org/policies-and-advocacy/public-health-policy-statements/policy-database/2016/01/04/11/24/restricted-access-to-abortion-violates-human-rights [https://perma.cc/LTK6-JASD].

[10] Redd et al., supra note 3, at 104.

[11] Joia Crear-Perry et al., Social and Structural Determinants of Health Inequities in Maternal Health, 30 J. Women’s Health, 230, 231 (2021).

[12] Id. at 234.

[13] Id. at 230.

[14] Donna L. Hoyert, Maternal Mortality Rates in the United States, 2022, Nat’l Ctr. for Health Stat. (May 2024), https://www.cdc.gov/nchs/data/hestat/maternal-mortality/2022/maternal-mortality-rates-2022.pdf.

[15] Id.

[16] Id.

[17] Redd et al., supra note 3, at 104.

[18] Restricted Access, supra note 9.

[19] The Economic Impacts of Restricted Abortion Access in Ohio, Women’s Fund (Nov. 2023), https://www.gcfdn.org/wp-content/uploads/2023/12/02.-Economic-Impacts-of-Restricted-Abortion-Access-in-Ohio_Concise.pdf.

[20] Id.

[21] Id.

[22] Id.

[23] Id.

[24] Id.

[25] Id.

[26] Id.

[27] Id.

[28] Id.

[29] Abortion Bans, supra note 8; see also Interactive Map: US Abortion Policies and Access After Roe, Guttmacher (last updated Oct. 7, 2024) [hereinafter Interactive Map], https://states.guttmacher.org/policies/ [https://perma.cc/BEE2-ENFZ].

[30] Interactive Map, supra note 29; see also Population – Women – Ages 18-44 in United States, Am. Health Rankings (2021), https://www.americashealthrankings.org/explore/measures/pct_female_18-44 (last visited Oct. 12, 2024) [https://perma.cc/LE8T-SRSK]; Erica Hensley & Jessica Washington, How major abortion laws compare, state by state (Oct. 9, 2024), https://fullerproject.org/story/how-major-abortion-laws-compare-state-by-state-map/ [https://perma.cc/47VJ-NHVB].

[31] Tracey Farrigan, Highest U.S. poverty rates are in the South, with over 20 percent poor in its rural areas, USDA, https://www.ers.usda.gov/data-products/chart-gallery/gallery/chart-detail/?chartId=98028#:~:text=Highest%20U.S.%20poverty%20rates%20are,%2Dbeing%2C%20updated%20February%202020 [https://perma.cc/5SZP-LD25]; The Justice Gap: The South, Legal Serv. Corp. (last updated 2021), https://justicegap.lsc.gov/resource/south/ [https://perma.cc/DUA4-MDK7].

[32] Marybeth J. Mattingly & Catherine Turcotte-Seabury, Understanding very high rates of young child poverty in the south, 21 Carsey Sch. Pub. Pol’y 2 (2010).

[33] Crear-Perry et al., supra note 11, at 231.

[34] Id.

[35] Redd et al., supra note 3, at 232.

[36] Lea Nehme, Decision and Economic Analysis of Hostile Abortion Laws Compared with Supportive Abortion Laws, 5 Am. J. Obstetrics & Gynecology 1, 9 (2023), https://doi.org/10.1016/j.ajogmf.2023.101019.

[37] Crear-Perry et al., supra note 11, at 231.

[38] Id. at 232.

[39] Id. at 233.

[40] Id.

[41] Sarah Miller et al., The Economic Consequences of Being Denied an Abortion, Nat’l Bureau Econ. Rsch. (last updated May 8, 2024), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3611484 [https://perma.cc/9Y66-4GVP]; Restricted Access, supra note 9.

[42] Abortion Bans, supra note 8.

[43] Anne K. Örtqvist et al., Association between travel time to delivery unit and unplanned out-of-hospital birth, infant morbidity and mortality: A population-based cohort study, 100 Acta Obstet. Gynecol. Scand. 1478 (2021).

[44] Abortion Bans, supra note 8.

[45] Id.

[46] Kavitha Surana, Abortion Bans Have Delayed Emergency Medical Care, Experts Say This Mother’s Death Was Preventable, Probublica (Sept. 16, 2024, 5:00 AM), https://www.propublica.org/article/georgia-abortion-ban-amber-thurman-death [https://perma.cc/E9L2-WNDT].

[47] Id.

[48] Id.

[49] Id.

[50] Id.; Abigail Abrams, ‘Never-Ending Nightmare.’ An Ohio Woman was Forced to Travel Out of State for an Abortion, Time (Aug. 29, 2022, 7:00 AM), https://time.com/6208860/ohio-woman-forced-travel-abortion [https://perma.cc/J3SD-479S]; Mary Tuma, Texas woman denied abortions for ectopic pregnancies demand federal investigation, The Guardian (Aug. 13, 2024, 9:21 AM), https://www.theguardian.com/world/article/2024/aug/13/texas-abortion-ectopic-pregnancy-investigation [https://perma.cc/X56T-6L7G].

[51] Crear-Perry et al., supra note 11, at 233.

[52] Status of State Medicaid Expansion Decisions: Interactive Map, KFF (May 8, 2024), https://www.kff.org/affordable-care-act/issue-brief/status-of-state-medicaid-expansion-decisions-interactive-map [https://perma.cc/8B24-88W3].

[53] Study Finds Higher Maternal Mortality Rates in States with More Abortion Restrictions, Tulane Univ. Sch. Pub. Health & Tropical Medicine, https://sph.tulane.edu/study-finds-higher-maternal-mortality-rates-states-more-abortion-restrictions [https://perma.cc/46NF-VDXC].

[54] Liza Fuentes, Inequity in US Abortion Rights and Access: The End of Roe is Deepening Existing Divides, Guttmacher (Jan. 2023), https://www.guttmacher.org/2023/01/inequity-us-abortion-rights-and-access-end-roe-deepening-existing-divides [https://perma.cc/E9GF-DUFX].

[55] Crear-Perry et al., supra note 11, at 233; April Dembosky, Health department medical detectives find 84% of U.S. maternal deaths are preventable, NPR (Oct. 21, 2022, 5:00 AM), https://www.npr.org/sections/health-shots/2022/10/21/1129115162/maternal-mortality-childbirth-deaths-prevention [https://perma.cc/X6CU-QSKV].

[56] Interactive Map, supra note 29.

[57] Id.

[58] Christine Clark et al., Updated Analysis of the Cost of Abortion Restrictions to States, Inst. Women’s Pol’y Rsch. (Jan. 18, 2024), https://iwpr.org/updated-analysis-of-the-cost-of-abortion-restrictions-to-states [https://perma.cc/B6TW-P4QP].

[59] Id.

[60] Alexander Burns, States with Abortion Bans Risk Losing Their Economic Edge, N.Y. Times (July 11, 2022), https://www.nytimes.com/2022/07/11/us/politics/abortion-ban-states-businesses.html [https://perma.cc/P3KN-2ZKE].

[61] Id.

[62] Id.

[63] The Cumulative Costs of Barriers to Abortion Care, Nat’l P’ship for Women & Fam. (June 2024) [hereinafter Cumulative Costs], https://nationalpartnership.org/wp-content/uploads/cumulative-costs-barriers-abortion-care.pdf.

[64] Restricted Access, supra note 9.

[65] Redd et al., supra note 3, at 109; Savannah Adkins et al., Association Between Restricted Abortion Access and Child Entries Into the Foster Care System, 178 JAMA Pediatrics 37 (2024).

[66] Adkins et al., supra note 66.

[67] Priya Pandey, A Year After Dobbs: People with Low Incomes and Communities of Color Disproportionately Harmed, The Ctr. for L. and Soc. Pol’y (June 23, 2023), https://www.clasp.org/blog/a-year-after-dobbs-people-with-low-incomes-and-communities-of-color-disproportionately-harmed [https://perma.cc/7WQS-MTW8].

[68] Id.

[69] Crear-Perry et al., supra note 11, at 233.

[70] Id.

[71] Abortion Bans, supra note 8.

[72] Brendan Murphy, After Dobbs, M4s face stark reality when applying for residency, Am. Med. Ass’n (July 31, 2023), https://www.ama-assn.org/medical-students/preparing-residency/after-dobbs-m4s-face-stark-reality-when-applying-residency [https://perma.cc/VDQ3-B6VK].

[73] Emily Baumgaertner, Doctors in abortion-ban states fear prosecution for treating patients with life-threatening pregnancies, L.A. Times (July 29, 2022, 2:00 AM), https://www.latimes.com/world-nation/story/2022-07-29/fearful-of-prosecution-doctors-debate-how-to-treat-pregnant-patients [https://perma.cc/YNH8-9WMS].

[74] Interstate Shield Laws, Ctr. for Reprod. Rts. (June 26, 2024), https://reproductiverights.org/interstate-shield-laws [https://perma.cc/ER4R-R9LV].

[75] Baumgaertner, supra note 73; see also, e.g., State v. Zurawski, 690 S.W.3d 644 (Tex. Sup. Ct. 2024).

[76] Id.

[77] Becoming a Culturally Competent Health Care Organization, Am. Hosp. Ass’n., https://www.aha.org/ahahret-guides/2013-06-18-becoming-culturally-competent-health-care-organization [https://perma.cc/7NVJ-AKTK] (last visited Oct. 2, 2024).

[78] Kelly M. Hoffman et al., Racial bias in pain assessment and treatment recommendations, and false beliefs about biological differences between blacks and whites, 113 Proc. of the Nat’l Acad. of Sci. of the U.S.A. 4296, 4296 (2016).

[79] Id.

[80] Cumulative Costs, supra note 63.

[81] Crear-Perry et al., supra note 11, at 234.

[82] Brindis et al., supra note 7, at 2751.

[83] Cumulative Costs, supra note 63.

[84] Restricted Access, supra note 9.

[85] Redd et al., supra note 3, at 104.

[86] Fernando Alfonso III, The abortion underground and what lessons can be learned from the Jane Collective, NPR (May 4, 2022, 12:30 PM), https://www.npr.org/2022/05/04/1096149129/abortion-underground-jane-collective-heather-booth-scotus-roe-wade [https://perma.cc/27KX-2GC7]; Jessica Bruder, The Future of Abortion in a Post-Roe America, The Atlantic (Apr. 5, 2022, 9:22 AM), https://www.theatlantic.com/magazine/archive/2022/05/roe-v-wade-overturn-abortion-rights/629366 [https://perma.cc/E83Q-FHSA]; Jolynn Dellinger & Stephanie K. Pell, The criminalization of abortion and surveillance of women in a post-Dobbs world, Brookings (Apr. 182024), https://www.brookings.edu/articles/the-criminalization-of-abortion-and-surveillance-of-women-in-a-post-dobbs-world [https://perma.cc/8GCK-5CLA].

[87] Restricted Access, supra note 9; Judith Solomon, Closing the Coverage Gap Would Improve Black Maternal Health, Ctr. on Budget & Pol’y Priorities (July 26, 2021), https://www.cbpp.org/sites/default/files/7-26-21health.pdf.

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Cover Photo by Diane Greene Lent on Flickr.