Amicus Curiae Brief — Danco Laboratories, LLC, Applicant v. Louisiana, et al.
Supreme Court briefMay 4, 2026
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Nos. 25A1207 & 25A1208
In The
Supreme Court of the United States
______________________________
DANCO LABORATORIES, LLC,
Applicant,
v.
State of LOUISIANA, et al.,
Respondents.
______________________________
GENBIOPRO, INC.,
v.
Applicant,
State of LOUISIANA, et al.,
Respondents.
______________________________
BRIEF FOR STATES OF NEW YORK, ARIZONA, CALIFORNIA, COLORADO,
CONNECTICUT, DELAWARE, HAWAI‘I, ILLINOIS, MARYLAND, MASSACHUSETTS,
MICHIGAN, MINNESOTA, NEVADA, NEW JERSEY, NEW MEXICO, NORTH
CAROLINA, OREGON, RHODE ISLAND, VERMONT, VIRGINIA, WASHINGTON,
AND THE DISTRICT OF COLUMBIA, AND THE GOVERNOR OF PENNSYLVANIA
AS AMICI CURIAE IN SUPPORT OF APPLICANTS FOR A STAY
______________________________
LETITIA JAMES
Attorney General
State of New York
BARBARA D. UNDERWOOD*
Solicitor General
ESTER MURDUKHAYEVA
Deputy Solicitor General
GALEN SHERWIN
Special Counsel
28 Liberty Street
New York, New York 10005
(212) 416-8016
barbara.underwood@ag.ny.gov
*Counsel of Record
Dated: May 4, 2026
(Complete counsel listing appears on signature pages.)
TABLE OF CONTENTS
Page
TABLE OF AUTHORITIES .......................................................................................... ii
INTRODUCTION AND INTERESTS OF AMICI ........................................................ 1
ARGUMENT .................................................................................................................. 4
POINT I
MEDICATION ABORTION IS A SAFE AND EFFECTIVE METHOD FOR
TERMINATING PREGNANCIES ..................................................................................... 4
POINT II
THE ELIMINATION OF THE IN-PERSON DISPENSING REQUIREMENT IS
CLINICALLY SUPPORTED AND HAS SUBSTANTIAL BENEFITS ....................................... 7
POINT III
THE FIFTH CIRCUIT’S ORDER INTERFERES WITH AMICI STATES’ SOVEREIGN
AUTHORITY TO PROMOTE ACCESS TO REPRODUCTIVE HEALTH CARE FOR
THEIR RESIDENTS .................................................................................................... 12
CONCLUSION............................................................................................................. 17
i
TABLE OF AUTHORITIES
Cases
Page(s)
Benisek v. Lamone,
585 U.S. 155 (2018) ................................................................................................ 12
Dobbs v. Jackson Women’s Health Organization,
597 U.S. 215 (2022) ............................................................................................... 2-3
Farmland Dairies v. Barber,
65 N.Y.2d 51 (1985) ................................................................................................ 16
Purcell v. Kennedy,
No. 1:17-cv-493, 2025 WL 3101785 (D. Haw. Oct. 30, 2025) .................................. 6
Youngs Rubber Corp. v. C. I. Lee & Co.,
45 F.2d 103 (2d Cir. 1930) ...................................................................................... 10
Constitution
Cal. Const. art. I, § 1.1 ................................................................................................. 13
Laws
Federal
21 U.S.C.
§ 355-1(a)(1) ............................................................................................................ 15
§ 355-1(f)(2) ......................................................................................................... 7, 10
State (alphabetical by State)
Cal. Educ. Code § 99251 .............................................................................................. 12
Cal. Health & Safety Code § 123453 ........................................................................... 13
775 Ill. Comp. Stat. Ann. 55/1-1 et seq. ...................................................................... 13
Me. Rev. Stat. Ann. tit. 22, § 1598 .............................................................................. 13
Act of July 29, 2022, Ch. 127, 2022 Mass. Acts 740 ................................................... 13
Mass. Gen. Laws ch. 15A, § 46 .................................................................................... 12
ii
Laws
Page(s)
State (alphabetical by State)
N.J. Stat. Ann.
§ 2A:160-14.1 .......................................................................................................... 14
§ 10:7-1 .................................................................................................................... 14
N.Y. Educ. Law § 6438-b ....................................................................................... 12, 14
N.Y. Pub. Health Law § 2599-aa ................................................................................. 14
Vt. Stat. Ann. tit. 18, § 9493 et seq. ............................................................................ 14
Miscellaneous Authorities
Abigail R.A. Aiken et al., Safety and Effectiveness of Self-Managed Medication Abortion Provided Using Online Telemedicine in the United States: A
Population Based Study, 10 Lancet Reg’l Health - Americas, no. 100200
(2022), https://pmc.ncbi.nlm.nih.gov/articles/PMC9223776/pdf/main.pdf ............. 8
Advancing New Standards in Reprod. Health, Issue Brief, Availability of
Telehealth Services for Medication Abortion in the U.S., 2020-2022 (June
2023), https://www.ansirh.org/sites/default/files/202306/AFD%20Telehealth%20Issue%20Brief%206-14-23%20Final.pdf ................... 12
Amelia Thomson-DeVeaux, Virtual Abortions Surged After Roe Was
Overturned-But the Texas Ruling Could Change That, FiveThirtyEight
(Apr. 11, 2023), https://perma.cc/2Z2Z-N6PK ....................................................... 12
American Coll. of Obstetricians & Gynecologists, Early Pregnancy Loss:
Frequently Asked Questions (last updated Sept. 2024),
https://www.acog.org/womens-health/faqs/early-pregnancy-loss ........................... 4
American Coll. of Obstetricians & Gynecologists, Leading Medical
Organizations Reaffirm the Safety of Mifepristone (May 22, 2025),
https://www.acog.org/news/news-releases/2025/05/leading-medicalorganizations-reaffirm-the-safety-of-mifepristone .................................................. 6
American Coll. of Obstetricians & Gynecologists & Soc’y of Fam. Plan., Prac.
Bull. No. 225, Medication Abortion Up to 70 Days of Gestation, 136
Obstetrics & Gynecology e31 (2020, reaff’d 2023),
https://journals.lww.com/greenjournal/fulltext/2020/10000/medication_abo
rtion_up_to_70_days_of_gestation_.43.aspx? .......................................................... 9
iii
Miscellaneous Authorities
Page(s)
Angie Leventis Lourgos, Abortions in Illinois for Out-of-State Patients Have
Skyrocketed. And Some Wait Times Are Exceeding Three Weeks, Chi. Trib.
(Aug. 2, 2022), https://www.chicagotribune.com/2022/08/02/abortions-inillinois-for-out-of-state-patients-have-skyrocketed-and-some-wait-timesare-exceeding-three-weeks/ .................................................................................... 13
Application of the Comstock Act to the Mailing of Prescription Drugs That
Can Be Used for Abortions, 46 Op. O.L.C. (Dec. 23, 2022),
https://www.justice.gov/olc/opinion/file/1560596/dl?inline= ................................. 10
Christine Dehlendorf et al., Disparities in Family Planning, 202 Am. J.
Obstetrics & Gynecology 214 (2010),
https://www.ajog.org/action/showPdf?pii=S0002-9378%2809%2900947-8 .......... 15
Courtney A. Schreiber et al., Mifepristone Pretreatment for the Medical
Management of Early Pregnancy Loss, 378 N. Engl. J. Med. 2161 (2018),
https://www.nejm.org/doi/pdf/10.1056/NEJMoa1715726 ........................................ 4
Courtney Kerestes et al., Person-Centered, High-Quality Care from a Distance:
A Qualitative Study of Patient Experiences of TelAbortion, a Model for
Direct-to-Patient Medication Abortion by Mail in the United States, 54
Persps. on Sexual & Reprod. Health 177 (2022),
https://pubmed.ncbi.nlm.nih.gov/36229416/............................................................ 8
Diana G. Foster, The Turnaway Study: Ten Years, a Thousand Women, and
the Consequences of Having-or Being Denied-an Abortion (2020) ........................ 14
Diana G. Foster et al., Effects of Carrying an Unwanted Pregnancy to Term
on Women’s Existing Children, 205 J. Pediatrics 183 (2019),
https://www.jpeds.com/action/showPdf?pii=S0022-3476%2818%2931297-6 ....... 14
Elizabeth Kim, NYC Will Offer Free Abortion Pills at 4 City-Run Sexual
Health Clinics, Gothamist (Jan. 17, 2023), https://gothamist.com/news/
nyc-will-offer-free-abortion-pills-at-four-city-run-sexual-health-clinics .............. 11
Heidi D. Nelson et al., Associations of Unintended Pregnancy with Maternal
and Infant Health Outcomes: A Systematic Review and Meta-Analysis, 328
JAMA 1714 (2022),
https://jamanetwork.com/journals/jama/fullarticle/2797874 ................................ 14
Jane W. Seymour et al., Potential Impact of Telemedicine for Medication
Abortion Policy and Programming Changes on Abortion Accessibility in
the United States, 112 Am. J. Pub. Health 1202 (2022),
https://pmc.ncbi.nlm.nih.gov/articles/PMC9342822/pdf/AJPH.2022.306876
.pdf ............................................................................................................................ 8
iv
Miscellaneous Authorities
Page(s)
Jenna Jerman et al., Barriers to Abortion Care and Their Consequences for
Patients Traveling for Services: Qualitative Findings from Two States, 49
Persps. on Sexual & Reprod. Health 95 (2017),
https://onlinelibrary.wiley.com/doi/epdf/10.1363/psrh.12024 ............................... 11
Jessica Beaman et al., Medication to Manage Abortion and Miscarriage, 35 J.
Gen. Internal Med. 2398 (2020), https://dx.doi.org/10.1007/s11606-02005836-9...................................................................................................................... 4
Julia Strasser et al., Penalizing Abortion Providers Will Have Ripple Effects
Across Pregnancy Care, Health Affs. (May 3, 2022),
https://healthaffairs.org/do/10.1377/forefront.20220503.129912/ ........................ 15
Justin J. Chu et al., Mifepristone and Misoprostol Versus Misoprostol Alone
for the Management of Missed Miscarriage (MifeMiso): A Randomised,
Double-Blind, Placebo-Controlled Trial, 396 Lancet 770 (2020),
https://www.pure.ed.ac.uk/ws/portalfiles/portal/171906498/1_s2.0_S01406
73620317888_main.pdf ............................................................................................ 4
Kanya D’Almeida, Telemedicine Abortion Care Is Coming to Maine, Rewire
News Grp. (Feb. 29, 2016), https://rewirenewsgroup.com/2016/02/29/
telemedicine-abortion-care-coming-maine/ ........................................................... 11
KFF, California Abortion Data (n.d.), https://www.kff.org/interactive/
womens-health-profiles/california/abortion-statistics/ ........................................... 5
Lauren J. Ralph et al., Comparison of No-Test Telehealth and In-Person
Medication Abortion, 332 JAMA 898 (2024),
https://jamanetwork.com/journals/jama/fullarticle/2820321 .................................. 8
Leah R. Koenig et al., Mailing Abortion Pills Does Not Delay Care: A Cohort
Study Comparing Mailed to In-Person Dispensing of Abortion Medications
in the United States, 121 Contraception, no. 109962 (2023),
https://www.contraceptionjournal.org/action/showPdf?pii=S00107824%2823%2900015-X ........................................................................................... 8
Letter from Ctr. for Drug Evaluation & Research, U.S. Food & Drug Admin.,
to Am. Ass’n of Pro-Life Obstetricians & Gynecologists & Am. Coll. of
Pediatricians (Dec. 16, 2021), https://downloads.regulations.gov/FDA2025-P-3288-0012/content.pdf ................................................................................. 7
Liza Fuentes, Guttmacher Inst., Inequity in US Abortion Rights and Access:
The End of Roe Is Deepening Existing Divides (Jan. 17, 2023),
https://www.guttmacher.org/2023/01/inequity-us-abortion-rights-andaccess-end-roe-deepening-existing-divides ............................................................ 15
v
Miscellaneous Authorities
Page(s)
Liza Fuentes & Jenna Jerman, Distance Traveled to Obtain Clinical Abortion
Care in the United States and Reasons for Clinic Choice, 28 J. Women’s
Health 1623 (2019),
https://pmc.ncbi.nlm.nih.gov/articles/PMC6919239/pdf/jwh.2018.7496.pdf ... 10-11
Margot Sanger-Katz et al., Interstate Abortion Travel Is Already Straining
Parts of the System, N.Y. Times (July 23, 2022),
https://www.nytimes.com/2022/07/23/upshot/abortion-interstate-travelappointments.html ................................................................................................. 13
Mary Gatter et al., Efficacy and Safety of Medical Abortion Using Mifepristone
and Buccal Misoprostol Through 63 Days, 91 Contraception 269 (2015),
https://pmc.ncbi.nlm.nih.gov/articles/PMC4373977/pdf/nihms662931.pdf............ 6
Massachusetts Dep’t Public Health, Massachusetts Induced Termination of
Pregnancy 2023 (Nov. 2024), https://www.mass.gov/doc/massachusettsinduced-termination-of-pregnancy-2023-pdf/download .......................................... 5
Matt Bloom & Bente Berkland, Wait Times at Colorado Clinics Hit Two
Weeks as Out-of-State Patients Strain System, KSUT (July 28, 2022),
https://www.ksut.org/health-science/2022-07-28/wait-times-at-coloradoabortion-clinics-hit-2-weeks-as-out-of-state-patients-strain-system ................... 13
National Abortion Fed’n, 2024 Clinical Policy Guidelines for Abortion Care
(2024), https://nationalabortionfederation.org/wp-content/uploads/2024CPGs-FINAL-1.pdf ................................................................................................... 9
National Acads. of Scis., Eng’g & Med. (NASEM), The Safety and Quality of
Abortion Care in the United States 5 (2018),
https://www.nationalacademies.org/read/24950/chapter/1 .................................. 5-7
Oriana González & Nicole Cobler, Influx of Out-of-State Patients Causes
Abortion Delays, Axios (Sept. 12, 2022),
https://www.axios.com/local/austin/2022/09/12/texans-out-of-statepatients-abortions-delays ....................................................................................... 13
Pet. of Am. Coll. of Obstetricians & Gynecologists et al. 2 (Jan. 31, 2025),
FDA-2025-P-0377, https://www.regulations.gov/document/FDA-2025-P0377-0001 .................................................................................................................. 6
Pet. of Andrea Joy Campbell, Att’y Gen. of Mass., et al. 2 (June 5, 2025),
FDA-2025-P-1576-0001, https://www.regulations.gov/document/FDA-2025P-1576-0001/ ............................................................................................................. 6
vi
Miscellaneous Authorities
Page(s)
Pet. of Nick Brown, Att’y Gen. of Wash., et al. 2 (Aug. 20, 2025), FDA-2025-P3287-0001, https://www.regulations.gov/document/FDA-2025-P-3287-0001......... 6
Rachel K. Jones et al., Guttmacher Inst., Medication Abortion Accounted for
63% of All US Abortions in 2023—An Increase from 53% in 2020 (Mar. 19,
2024), https://www.guttmacher.org/2024/03/medication-abortionaccounted-63-all-us-abortions-2023-increase-53-2020............................................ 5
Rachel K. Jones & Jenna Jerman, Guttmacher Inst., Time to Appointment
and Delays in Accessing Care Among U.S. Abortion Patients (Aug. 2016),
https://www.guttmacher.org/sites/default/files/report_pdf/delays-inaccessing-care.pdf ................................................................................................... 11
Samantha P. Ruggiero et al., Patient and Provider Experiences Using a Siteto-Site Telehealth Model for Medication Abortion, 8 Health 32 (2022),
https://pmc.ncbi.nlm.nih.gov/articles/PMC9634192/pdf/mh-08-22-12.pdf ............. 8
Sarah Varney, Long Drives, Air Travel, Exhausting Waits: What Abortion
Requires in the South, KFF Health News (Aug. 3, 2021),
https://kffhealthnews.org/news/article/abortion-in-south-requires-travellong-waits/............................................................................................................... 11
Silpa Srinivasulu et al., Telehealth Medication Abortion in Primary Care: A
Comparison to Usual in-Clinic Care, 37 J. Am. Bd. Fam. Med. 295 (2024),
https://www.jabfm.org/content/jabfp/37/2/295.full.pdf ............................................ 9
Society of Fam. Plan., #WeCount Report, April 2022 to June 2025 (Dec. 9,
2025), https://societyfp.org/wp-content/uploads/2025/12/WeCount-Report10-June-2025-data.pdf ................................................................................... 9, 12-13
Theresa Chalhoub & Kelly Rimar, The Health Care System and Racial
Disparities in Maternal Mortality, Ctr. for Am. Progress (May 10, 2018),
https://www.americanprogress.org/article/health-care-system-racialdisparities-maternal-mortality/ ............................................................................. 15
U.S. Food & Drug Admin., Mifepristone U.S. Post-Marketing Adverse Events
Summary Through 12/31/2024 (n.d.),
https://www.fda.gov/media/185245/download ......................................................... 5
U.S. Food & Drug Admin., Information About Mifepristone for Medical
Termination of Pregnancy Through Ten Weeks Gestation (last updated
Jan. 17, 2025), https://www.fda.gov/drugs/postmarket-drug-safetyinformation-patients-and-providers/information-about-mifepristonemedical-termination-pregnancy-through-ten-weeks-gestation .............................. 4
vii
Miscellaneous Authorities
Page(s)
U.S. Food & Drug Admin., Ctr. for Drug Evaluation & Research, REMS
Modification Rationale Review (Dec. 16, 2021),
https://www.accessdata.fda.gov/drugsatfda_docs/summary_review/2023/02
0687Orig1s025SumR.pdf ......................................................................................... 7
Ushma D. Upadhyay et al., Effectiveness and Safety of Telehealth Medication
Abortion in the USA, 30 Nature Med. 1191 (2024),
https://www.nature.com/articles/s41591-024-02834-w ........................................... 9
Ushma D. Upadhyay et al., Outcomes and Safety of History-Based Screening
for Medication Abortion: A Retrospective Multicenter Cohort Study, 182
JAMA Intern. Med. 482 (2022), https://scispace.com/pdf/outcomes-andsafety-of-history-based-screening-for-2amfp0v8.pdf ............................................... 8
Ushma D. Upadhyay et al., Pricing of Medication Abortion in the United
States, 2021-2023, 56 Persps. on Sexual & Reprod. Health 282 (2024),
https://onlinelibrary.wiley.com/doi/epdf/10.1111/psrh.12280 ............................... 11
Ushma D. Upadhyay et al., Safety and Efficacy of Telehealth Medication
Abortions in the US During the COVID-19 Pandemic, 4 JAMA Netw.
Open, no. e2122320 (2021),
https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2783451 ............ 8
World Health Org., Abortion Care Guideline (2022),
https://iris.who.int/server/api/core/bitstreams/59a704cc-4024-412a-97d955d86d139602/content ............................................................................................. 6
World Health Org., WHO Model List of Essential Medicines - 22nd List, 2021
(Sept. 30, 2021), https://www.who.int/publications/i/item/WHO-MHP-HPSEML-2021.02 ............................................................................................................ 6
viii
INTRODUCTION AND INTERESTS OF AMICI
In 2023, following extensive study, the U.S. Food and Drug Administration
(FDA) eliminated the in-person dispensing requirement for the drug mifepristone as
medically unnecessary. Several years later, plaintiffs (the State of Louisiana and a
single individual) filed this suit seeking to compel the FDA to reinstate the requirement. The U.S. District Court for the Western District of Louisiana (Joseph, J.) denied
plaintiffs’ motion for preliminary relief without prejudice, and upon the request of the
FDA and without objection from applicants, stayed the action pending resolution of
the FDA’s ongoing regulatory review of exactly the same requirement challenged in
this case. Plaintiffs appealed, and the U.S. Court of Appeals for the Fifth Circuit
issued an order “staying” the 2023 regulatory change pending appeal pursuant to
section 705 of the Administrative Procedure Act. The Fifth Circuit’s ruling is legally
erroneous, creates regulatory and administrative chaos nationwide, and undermines
the ability of millions of people to access lawful medical care.
Amici States of New York, Arizona, California, Colorado, Connecticut,
Delaware, Hawai‘i, Illinois, Maryland, Massachusetts, Michigan, Minnesota, Nevada,
New Jersey, New Mexico, North Carolina, Oregon, Rhode Island, Vermont, Virginia,
Washington, and the District of Columbia, and the Governor of Pennsylvania submit
this brief in support of applicants’ emergency requests for a stay of the Fifth Circuit’s
ruling. Mifepristone has been widely and safely used for more than two decades in
the United States and across the world for termination of early pregnancies and
management of early pregnancy loss. The regulatory removal of unnecessary restric-
tions on mifepristone, including the in-person dispensing requirement, has proven
crucial to amici in improving abortion access for their residents, particularly in lowincome, underserved, and rural communities, which experience higher rates of birthrelated mortality and morbidity, and where access to health care is generally far more
limited.
Amici States therefore have a strong interest in preserving the availability of
access to mifepristone by telemedicine (also known as telehealth) specifically, and in
ensuring high-quality, science-driven patient care within their borders more generally. Many amici operate public hospitals, clinics, and other facilities that provide
health care and pharmaceutical services and public universities that provide health
care services to their employees and students. Through their elected officials, amici
also act to protect and promote the health, safety, and welfare of their residents. The
continued availability of mifepristone, in accordance with sound medical guidelines,
is therefore critical to safeguarding amici’s important interest in protecting the
health, safety, and rights of their residents to access essential reproductive health care,
and the right of the professionals employed in their health care facilities to provide
it.
Plaintiffs’ request for preliminary relief in the Fifth Circuit was chiefly predicated
on their disagreement with the legislative and policy judgments of States that have
chosen to expand rather than to restrict access to abortion following the Supreme
Court’s decision in Dobbs v. Jackson Women’s Health Organization, 597 U.S. 215
(2022). After Dobbs, many States, including several amici, enacted constitutional and
2
statutory measures codifying the right to abortion under state law, directed funding
toward expanding capacity and upgrading facilities to meet increased demand, and
passed laws intended to support persons seeking and providing abortion care within
their jurisdictions. Several such initiatives have focused specifically on increasing
access to medication abortion, in light of its unique benefits and accessibility. The
enactment and implementation of such state laws is beyond the regulatory authority
of the FDA; by statute, the agency’s authority is limited to evaluating the safety and
efficacy of medications. The mere fact that some States have chosen to promote, rather
than to restrict, access to abortion, does not justify judicial relief against the FDA.
More fundamentally, the Fifth Circuit’s order runs roughshod over the
Supreme Court’s recognition in Dobbs that “the people of the various States may
evaluate” the interests of a woman who wants an abortion and the interests in fetal
life differently, 597 U.S. at 256, and the Court’s determination to “return the issue of
abortion to the people’s elected representatives,” id. at 232. Amici’s efforts to protect
and expand access to abortion more generally, and to medication abortion specifically,
are a result of the “constitutional processes of democratic self-government,” id. at 346
(Kavanaugh, J., concurring). Ultimately, such laws and policies represent a value
judgment that the privacy, bodily autonomy, and dignity of all pregnant people
include the ability to decide whether to continue or terminate a pregnancy free from
government interference. The Fifth Circuit has placed a federal thumb on the scale
in favor of States that have made contrary policy choices, but that is the exact
opposite of what this Court directed in Dobbs.
3
ARGUMENT
POINT I
MEDICATION ABORTION IS A SAFE AND EFFECTIVE
METHOD FOR TERMINATING PREGNANCIES
By the age of forty-five, approximately one in four women in the United States
will have had an abortion and at least as many will have had a miscarriage. 1 Mifepristone, in a regimen with misoprostol, is the standard method to terminate a pregnancy
through ten weeks’ gestation, 2 and it is commonly used by physicians to complete the
termination of a pregnancy once a miscarriage has begun. 3 Although both procedural
abortion and medication abortion are extremely safe, and individuals may choose one
or the other option for different reasons, medication abortion offers significant benefits in terms of flexibility, privacy, and accessibility. Among other benefits, medication
abortion promotes access to abortion as early as possible, when it is safest and least
1 Jessica Beaman et al., Medication to Manage Abortion and Miscarriage, 35 J.
Gen. Internal Med. 2398, 2398 (2020); see Am. Coll. of Obstetricians & Gynecologists,
Early Pregnancy Loss: Frequently Asked Questions (last updated Sept. 2024) (“How
common is early pregnancy loss?”).
2 See U.S. Food & Drug Admin., Information About Mifepristone for Medical
Termination of Pregnancy Through Ten Weeks Gestation (last updated Jan. 17, 2025).
Courtney A. Schreiber et al., Mifepristone Pretreatment for the Medical
Management of Early Pregnancy Loss, 378 N. Engl. J. Med. 2161, 2169 (2018); Justin
J. Chu et al., Mifepristone and Misoprostol Versus Misoprostol Alone for the Management of Missed Miscarriage (MifeMiso): A Randomised, Double-Blind, PlaceboControlled Trial, 396 Lancet 770, 777 (2020).
3
4
expensive, and has contributed to an increase in the proportion of pregnancy terminations taking place earlier than six weeks gestation. 4
Since its approval in 2000, an estimated 7.5 million people in the U.S. have used
mifepristone to terminate a pregnancy, 5 and medication abortion now accounts for
63% of all abortions performed in the formal U.S. health system nationwide. 6 In many
States, including in several amici States, the use of medication abortion is even
higher. For instance, in 2023, approximately 64% of the abortions performed in Massachusetts and 71% of the abortions performed in California were done by medication. 7
The extensive experience of many of the amici States confirms what numerous
scientific studies have demonstrated: mifepristone is extraordinarily safe and effective
and an integral component of reproductive health care. A comprehensive survey of
abortion care in the U.S. by the National Academies of Sciences, Engineering, and
Medicine in 2018 concluded that medication abortion involving mifepristone is 96.7%
effective and that complications are rare, i.e., “occurring in no more than a fraction of
4 See Nat’l Acads. of Scis., Eng’g & Med. (NASEM), The Safety and Quality of
Abortion Care in the United States 5, 28-29 (2018).
5 See U.S. Food & Drug Admin., Mifepristone U.S. Post-Marketing Adverse
Events Summary Through 12/31/2024 (n.d.).
6 Rachel K. Jones et al., Guttmacher Inst., Medication Abortion Accounted for
63% of All US Abortions in 2023—An Increase from 53% in 2020 (Mar. 19, 2024).
See Mass. Dep’t Public Health, Massachusetts Induced Termination of
Pregnancy 2023, at 5 (Nov. 2024); KFF, California Abortion Data (n.d.).
7
5
a percent of patients.” 8 The World Health Organization includes the mifepristone/misoprostol regimen in its guidelines for abortion care, 9 and has long included
the combination regimen in its Model List of Essential Medicines—i.e., those medicines “that satisfy the priority health care needs of a population” and “are intended
to be available in functioning health systems at all times.” 10
Mifepristone’s safety record is so conclusive that leading medical associations,
as well as several amici, have advocated that the FDA’s Risk Evaluation and
Mitigation Strategy (REMS) designation for the drug be eliminated altogether,
viewing it as outdated and medically unjustified. 11 And in October 2025, a federal
district court in Hawai‘i held that the FDA’s decision to retain certain prescribing
and dispensation restrictions on mifepristone was arbitrary and capricious because
of the overwhelming record of the drug’s safety and efficacy, and remanded to the
agency without vacatur for a new analysis. See Purcell v. Kennedy, No. 1:17-cv-493,
2025 WL 3101785, at *2 (D. Haw. Oct. 30, 2025).
8 See NASEM, supra, at 53, 55; accord Mary Gatter et al., Efficacy and Safety
of Medical Abortion Using Mifepristone and Buccal Misoprostol Through 63 Days, 91
Contraception 269, 270 (2015).
9 See World Health Org., Abortion Care Guideline xxix, 16-17, 67-68 (2022).
10 World Health Org., WHO Model List of Essential Medicines - 22nd List, 2021
(Sept. 30, 2021).
11 See, e.g., Pet. of Am. Coll. of Obstetricians & Gynecologists et al. 2 (Jan. 31,
2025), FDA-2025-P-0377; Pet. of Andrea Joy Campbell, Att’y Gen. of Mass., et al. 2
(June 5, 2025), FDA-2025-P-1576-0001; Pet. of Nick Brown, Att’y Gen. of Wash., et
al. 2 (Aug. 20, 2025), FDA-2025-P-3287-0001; see also Am. Coll. of Obstetricians &
Gynecologists, Leading Medical Organizations Reaffirm the Safety of Mifepristone
(May 22, 2025).
6
Years of clinical use have also shown that mifepristone can safely be provided
in a variety of contexts and practice areas, including, for example, in a private physician’s office, an obstetrician-gynecologist or family practice setting, or at home under
appropriate medical supervision, offering added flexibility, privacy, and security for
both patients and providers. 12 As the FDA observed, mifepristone’s safety record is
“well-characterized” and “has not changed over the period of surveillance.” 13
POINT II
THE ELIMINATION OF THE IN-PERSON DISPENSING REQUIREMENT
IS CLINICALLY SUPPORTED AND HAS SUBSTANTIAL BENEFITS
The FDA’s decision to remove the in-person dispensing requirement was amply
supported by scientific data and consistent with the agency’s statutory obligation to
remove unnecessary barriers to medication access. See 21 U.S.C. § 355-1(f)(2). The
decision was backed by an extensive literature review, 14 as well as mifepristone’s
stable safety record during the COVID-19 pandemic when the agency forbore from
enforcing the in-person dispensing requirement. Subsequent research has shown no
change in mifepristone’s safety profile following changes to mifepristone’s labeling,
12 See NASEM, supra, at 10, 58.
13 U.S. Food & Drug Admin., Ctr. for Drug Evaluation & Research, REMS
Modification Rationale Review 15 (Dec. 16, 2021); see also Letter from Ctr. for Drug
Evaluation & Research, U.S. Food & Drug Admin., to Am. Ass’n of Pro-Life Obstetricians & Gynecologists & Am. Coll. of Pediatricians at 20 (Dec. 16, 2021).
14 U.S. Food & Drug Admin., REMS Modification Rationale Review, supra, at
24-36 (discussing studies).
7
prescribing, and dispensing requirements, including the elimination of the in-person
dispensing requirement.
Indeed, numerous studies have further confirmed that medication abortion
care provided by telehealth is highly safe and effective, 15 and that patients are highly
satisfied with telehealth medication abortion care. 16 For example, one study of nearly
3,800 patients who received medication abortion either in-person or through
telehealth “found high effectiveness and safety rates” overall, with “similarly high
effectiveness and safety rates comparing patients who received medications in-person
vs by mail.” 17 Another study of over 6,000 patients who obtained medication abortion
via telehealth between April 2021 to January 2022 found an overall effectiveness rate
See, e.g., Jane W. Seymour et al., Potential Impact of Telemedicine for
Medication Abortion Policy and Programming Changes on Abortion Accessibility in
the United States, 112 Am. J. Pub. Health 1202 (2022); Samantha P. Ruggiero et al.,
Patient and Provider Experiences Using a Site-to-Site Telehealth Model for Medication Abortion, 8 Health 32 (2022); Abigail R.A. Aiken et al., Safety and Effectiveness
of Self-Managed Medication Abortion Provided Using Online Telemedicine in the
United States: A Population Based Study, 10 Lancet Reg’l Health - Americas, no.
100200 (2022); Ushma D. Upadhyay et al., Outcomes and Safety of History-Based
Screening for Medication Abortion: A Retrospective Multicenter Cohort Study, 182
JAMA Intern. Med. 482, 488-89 (2022); Ushma D. Upadhyay et al., Safety and
Efficacy of Telehealth Medication Abortions in the US During the COVID-19
Pandemic, 4 JAMA Netw. Open, no. e2122320, at 1-2 (2021).
15
16 See, e.g., Courtney Kerestes et al., Person-Centered, High-Quality Care from
a Distance: A Qualitative Study of Patient Experiences of TelAbortion, a Model for
Direct-to-Patient Medication Abortion by Mail in the United States, 54 Persps. on
Sexual & Reprod. Health 177 (2022); Leah R. Koenig et al., Mailing Abortion Pills
Does Not Delay Care: A Cohort Study Comparing Mailed to In-Person Dispensing of
Abortion Medications in the United States, 121 Contraception, no. 109962 (2023).
17 Upadhyay et al., Outcomes and Safety of History-Based Screening for Medica-
tion Abortion, supra, at 488-89; see also Lauren J. Ralph et al., Comparison of NoTest Telehealth and In-Person Medication Abortion, 332 JAMA 898 (2024).
8
of 97.7% and an overall safety rate of 99.7%. 18 A 2024 study likewise concluded that
telehealth medication abortion is “as effective, timelier, and potentially more
accessible than in-clinic care.” 19 Given this overwhelming weight of evidence,
numerous medical organizations including the National Abortion Federation, the
American College of Obstetricians and Gynecologists, and the Society of Family
Planning have issued clinical practice guidelines supporting the provision of
telehealth medication abortion care. 20 While a majority of abortions in the U.S. health
system still occur in person, a growing number—27% in 2025 as compared to 5% in
2022—now take place via telemedicine. 21
The FDA’s elimination of the in-person dispensing requirement was also
consistent with the agency’s statutory obligation to ensure that any restrictions on
approved medications impose minimal burdens on access, particularly for those
patients “who have difficulty accessing health care (such as patients in rural or
18 Ushma D. Upadhyay et al., Effectiveness and Safety of Telehealth Medication
Abortion in the USA, 30 Nature Med. 1191 (2024).
19 Silpa Srinivasulu et al., Telehealth Medication Abortion in Primary Care: A
Comparison to Usual in-Clinic Care, 37 J. Am. Bd. Fam. Med. 295, 299 (2024).
20 Nat’l Abortion Fed’n, 2024 Clinical Policy Guidelines for Abortion Care 1
(2024) (explaining that “[t]elemedicine can be safely used to provide abortion care,
including medication abortion provision, informed consent, and follow-up”); Am. Coll.
of Obstetricians & Gynecologists & Soc’y of Fam. Plan., Prac. Bull. No. 225, Medication Abortion Up to 70 Days of Gestation, 136 Obstetrics & Gynecology e31, e35 (2020,
reaff’d 2023) (“Medication abortion can be provided safely and effectively by telemedicine with a high level of patient satisfaction, and telemedicine improves access
to early abortion care, particularly in areas that lack a health care practitioner.”).
2025).
21 Soc’y of Fam. Plan., #WeCount Report, April 2022 to June 2025, at 1 (Dec. 9,
9
medically underserved areas),” and on the health care delivery system as a whole.
See 21 U.S.C. § 355-1(f)(2). Removal of the requirement has allowed clinicians to offer
medication abortion services remotely, where otherwise lawful, by conducting patient
intake, examination, and follow-up via telephone or videoconference and enabling
patients to obtain the medication through certified mail-order or certified retail pharmacies. 22 Elimination of the in-person dispensing requirement has also enabled clinicians in brick-and-mortar clinics to prescribe the medication to patients in person for
pick-up by the patient at a pharmacy, eliminating the need for health care providers
to keep a supply of the medications on-site.
These changes have been critical to extending access for amici’s residents in rural
and underserved communities where barriers to abortion and other forms of health care
are most acute. 23 The availability of abortion care by telehealth has reduced the impact
of many practical and cost barriers that can make it difficult for many people to obtain
an abortion—including childcare needs, missed work and resulting lost income, lack
Plaintiffs asserted below that the federal Comstock Act prohibits the
distribution of mifepristone by mail. See Pls.’ Mem. of Law in Support of Mot. for
Prelim. Relief at 13-14 (W.D. La. Dec. 17, 2025), ECF No. 20-26. Although a discussion of the Comstock Act is beyond the scope of this brief, amici States note that
plaintiffs’ interpretation of the Comstock Act has been expressly rejected as having
potentially boundless effects on medical care delivery, ostensibly preventing distribution of a host of devices, surgical instruments, and equipment used in obstetrics and
gynecology and beyond, as well as numerous drugs routinely used to treat countless
diseases and conditions. See, e.g., Youngs Rubber Corp. v. C. I. Lee & Co., 45 F.2d 103,
108 (2d Cir. 1930); Application of the Comstock Act to the Mailing of Prescription
Drugs That Can Be Used for Abortions, 46 Op. O.L.C. (Dec. 23, 2022) (slip op. at 1-2).
22
23 Liza Fuentes & Jenna Jerman, Distance Traveled to Obtain Clinical Abor-
tion Care in the United States and Reasons for Clinic Choice, 28 J. Women’s Health
1623, 1627 (2019).
10
of insurance coverage, and travel costs and logistics. 24 Telehealth is also generally less
expensive than in-person care. As one study found, “[t]he median cost of a medication
abortion offered in-person increased from $580 in 2021 to $600 by 2023,” while “[t]he
median price of a medication abortion offered by virtual clinics decreased from $239
in 2021 to $150 in 2023.” 25
Many state and local governments, including in many amici States, have
expended substantial resources to increase access to mifepristone, both through inperson care and via telemedicine. In Maine, which has among the highest rates of
rural residents in the U.S., a major clinic network has made medication abortion
available at its health centers via telemedicine. 26 New York City offers free medication
abortion at several public health clinics serving primarily low-income New Yorkers. 27
And several amici States, including Massachusetts, New York, and California, have
taken steps to extend access to public university students by making medication
24 See id. at 1623-24; Sarah Varney, Long Drives, Air Travel, Exhausting Waits:
What Abortion Requires in the South, KFF Health News (Aug. 3, 2021); Jenna Jerman
et al., Barriers to Abortion Care and Their Consequences for Patients Traveling for
Services: Qualitative Findings from Two States, 49 Persps. on Sexual & Reprod.
Health 95, 98 (2017); Rachel K. Jones & Jenna Jerman, Guttmacher Inst., Time to
Appointment and Delays in Accessing Care Among U.S. Abortion Patients (Aug.
2016).
25 Ushma D. Upadhyay et al., Pricing of Medication Abortion in the United
States, 2021-2023, 56 Persps. on Sexual & Reprod. Health 282, 282 (2024).
See Kanya D’Almeida, Telemedicine Abortion Care Is Coming to Maine,
Rewire News Grp. (Feb. 29, 2016).
26
27 See Elizabeth Kim, NYC Will Offer Free Abortion Pills at 4 City-Run Sexual
Health Clinics, Gothamist (Jan. 17, 2023).
11
abortion available through campus health centers. 28 In addition, nearly seventy
virtual clinics in twenty-three States and the District of Columbia currently offer
medication abortion via telemedicine. 29 Reinstating the in-person dispensing requirement for mifepristone would undermine the significant efforts to promote access
within those States.
POINT III
THE FIFTH CIRCUIT’S ORDER INTERFERES WITH AMICI STATES’
SOVEREIGN AUTHORITY TO PROMOTE ACCESS TO REPRODUCTIVE
HEALTH CARE FOR THEIR RESIDENTS
Absent immediate relief from this Court, the Fifth Circuit’s nationwide “stay”
of the FDA’s elimination of an in-person dispensing requirement that has not been
enforced since 2021 will have a “needlessly chaotic and disruptive effect,” Benisek v.
Lamone, 585 U.S. 155, 161 (2018) (quotation marks omitted), especially in amici
States.
As explained above, over a quarter of abortions in the United States currently
take place via telemedicine, 30 and many States and private providers have invested
resources and established infrastructure to offer medication abortion via telemedi-
28 See N.Y. Educ. Law § 6438-b; Mass. Gen. Laws ch. 15A, § 46; Cal. Educ. Code
§ 99251.
29 See Advancing New Standards in Reprod. Health (ANSIRH), Issue Brief,
Availability of Telehealth Services for Medication Abortion in the U.S., 2020-2022, at
2 (June 2023).
See Amelia Thomson-DeVeaux, Virtual Abortions Surged After Roe Was
Overturned—But the Texas Ruling Could Change That, FiveThirtyEight (Apr. 11,
2023); Soc’y of Fam. Plan., #WeCount Report, supra, at 1; ANSIRH, supra, at 1-2.
30
12
cine. Reinstating the requirements of in-person dispensing for mifepristone would
severely interfere with access to this crucial medication via telemedicine, reimposing
unnecessary travel-related costs and delays on amici’s residents forced to seek care
in person. These burdens are especially notable for amici States, many of whom have
experienced a steep rise in demand at clinics from out-of-state patients after Dobbs. 31
While providers have endeavored to meet the increased demand, the influx has
stretched clinics past their already-strained capacity and has dramatically increased
wait times for patients from both within and outside of their States. 32 Restricting
access to medication abortion via telemedicine would hinder amici States’ efforts to
meet this demand.
To be sure, there have long been practical and financial obstacles to obtaining
abortion care. But the threats to and ultimate loss of a federal constitutional right to
abortion brought those inequities into sharper relief, leading many amici States to
reaffirm their commitments not only to safeguarding the right to abortion, but also
to dismantling barriers to accessing essential reproductive health care. 33 Denial of
31 See Soc’y of Fam. Plan., #WeCount Report, supra, at 3-4.
See Margot Sanger-Katz et al., Interstate Abortion Travel Is Already
Straining Parts of the System, N.Y. Times (July 23, 2022); Angie Leventis Lourgos,
Abortions in Illinois for Out-of-State Patients Have Skyrocketed. And Some Wait
Times Are Exceeding Three Weeks, Chi. Trib. (Aug. 2, 2022); Oriana González & Nicole
Cobler, Influx of Out-of-State Patients Causes Abortion Delays, Axios (Sept. 12, 2022);
Matt Bloom & Bente Berkland, Wait Times at Colorado Clinics Hit Two Weeks as
Out-of-State Patients Strain System, KSUT (July 28, 2022).
32
33 See, e.g., Cal. Const. art. I, § 1.1; Cal. Health & Safety Code § 123453; 775
Ill. Comp. Stat. Ann. 55/1-1 et seq.; Me. Rev. Stat. Ann. tit. 22, § 1598; Act of July 29,
(continued on the next page)
13
abortion care is associated with numerous harms, including poor birthing and infant
health outcomes, higher rates of poverty, and lower educational attainment for both
parents and children. 34 Allowing an unnecessary obstacle to medication abortion to
once again take effect will frustrate amici States’ efforts to prevent these harms, allowing them to proliferate even in States where abortion remains lawful and protected.
Reinstating an in-person dispensing requirement for mifepristone would also
impede provision of other forms of critical health care in amici States. The same facilities that provide abortion care often offer other essential services, such as pre- and
postnatal care, family planning, cancer screening, testing and treatment for sexually
transmitted infections and HIV, and other forms of necessary preventative health
care. Increased demand for in-person appointments for medication abortion and an
increase in procedural abortions will likely delay access to all forms of care offered at
those facilities, inevitably resulting in higher rates of unintended pregnancy and
sexually transmitted infections, barriers to early detection and treatment for breast,
ovarian, and testicular cancers and chronic diseases, and worsened overall health
2022, Ch. 127, 2022 Mass. Acts 740; N.J. Stat. Ann. § 10:7-1; id. § 2A:160-14.1; N.Y.
Pub. Health Law § 2599-aa; N.Y. Educ. Law § 6438-b; Vt. Stat. Ann. tit. 18, § 9493 et
seq.
34 See, e.g., Diana G. Foster, The Turnaway Study: Ten Years, a Thousand
Women, and the Consequences of Having—or Being Denied—an Abortion (2020);
Diana G. Foster et al., Effects of Carrying an Unwanted Pregnancy to Term on
Women’s Existing Children, 205 J. Pediatrics 183, 187-88 (2019); Heidi D. Nelson et
al., Associations of Unintended Pregnancy with Maternal and Infant Health Outcomes: A Systematic Review and Meta-Analysis, 328 JAMA 1714, 1727-29 (2022).
14
outcomes. 35 Underserved groups, including women of color, low-income women,
people with disabilities, and LGBTQ+ individuals, will be hardest hit. 36
The Fifth Circuit was mistaken for several reasons in asserting that
reinstatement of the in-person dispensing requirement is necessary to protect the
sovereign interests of States that have decided to restrict access to abortion (see CA5
Order at 14, 16). First, the FDA’s role in determining whether and what REMS are
appropriate is limited to whether a restriction “is necessary to ensure that the
benefits of the drug outweigh the risks of the drug.” 21 U.S.C. § 355-1(a)(1). The FDA
decision to impose or eliminate an in-person dispensing requirement does not address
the question of whether individual States may impose their own additional regulatory
restrictions; the FDA REMS do not legalize or prohibit abortion in any jurisdiction.
Second, there is no indication that the FDA eliminated the in-person dispensing
requirement for the purpose of frustrating state abortion prohibitions. The in-person
dispensing requirement was first suspended by court order in 2020 during the
COVID-19 pandemic and then through enforcement forbearance starting in 2021—
all before Dobbs and before state abortion bans took effect. The FDA’s 2021 review of
mifepristone’s REMS was likewise initiated prior to Dobbs, and there is no indication
35 See Julia Strasser et al., Penalizing Abortion Providers Will Have Ripple
Effects Across Pregnancy Care, Health Affs. (May 3, 2022).
See Liza Fuentes, Guttmacher Inst., Inequity in US Abortion Rights and
Access: The End of Roe Is Deepening Existing Divides (Jan. 17, 2023); Theresa
Chalhoub & Kelly Rimar, The Health Care System and Racial Disparities in Maternal
Mortality, Ctr. for Am. Progress (May 10, 2018); Christine Dehlendorf et al.,
Disparities in Family Planning, 202 Am. J. Obstetrics & Gynecology 214, 215 (2010).
36
15
in the 2023 culmination of that review that the agency’s evaluation of the in-person
dispensing requirement was related to any state abortion bans.
Third, and most fundamentally, state laws protecting access to abortion in
other States in no way preclude Louisiana or other similarly situated States from
enforcing their own abortion laws. Plaintiffs chiefly complain about laws passed by
certain States that prohibit state and local government officials and courts from
enforcing out-of-state judgments for abortion care administered lawfully in the home
State. Louisiana cannot complain that coequal sovereign States have declined to use
their resources to facilitate the enforcement of Louisiana’s abortion bans, because
“each sovereignty is free to determine what conduct shall be proscribed within its
jurisdiction,” and “the wrong committed by violating such proscription” does not
automatically cross state lines. Farmland Dairies v. Barber, 65 N.Y.2d 51, 56-57
(1985). In finding that nationwide preliminary relief was in the public interest, the
Fifth Circuit improperly elevated the policy preferences of States that have banned
or restricted abortion over the preferences of other States that have made the
different but equally sovereign determinations to promote access to abortion care.
16
CONCLUSION
This Court should grant the applications for a stay.
Dated:
New York, New York
May 4, 2026
Respectfully submitted,
LETITIA JAMES
Attorney General
State of New York
By:. /s/ Barbara D. Underwood .
BARBARA D. UNDERWOOD*
Solicitor General
ESTER MURDUKHAYEVA
Deputy Solicitor General
GALEN SHERWIN
Special Counsel
for Reproductive Justice
28 Liberty Street
New York, New York 10006
(212) 416-8016
barbara.underwood@ag.ny.gov
*Counsel of Record
(Counsel listing continues on next page.)
17
KRISTIN K. MAYES
Attorney General
State of Arizona
2005 North Central Avenue
Phoenix, AZ 85004
ANTHONY G. BROWN
Attorney General
State of Maryland
200 Saint Paul Place
Baltimore, MD 21202
ROB BONTA
Attorney General
State of California
1300 I Street
Sacramento, CA 95814
ANDREA JOY CAMPBELL
Attorney General
Commonwealth of Massachusetts
One Ashburton Place
Boston, MA 02108
PHILIP J. WEISER
Attorney General
State of Colorado
1300 Broadway, 10th Floor
Denver, CO 80203
DANA NESSEL
Attorney General
State of Michigan
525 West Ottawa Street
Lansing, MI 48909
WILLIAM TONG
Attorney General
State of Connecticut
165 Capitol Avenue
Hartford, CT 06106
KEITH ELLISON
Attorney General
State of Minnesota
102 State Capitol
75 Rev. Dr. Martin Luther King Jr. Blvd.
St. Paul, MN 55155
KATHLEEN JENNINGS
Attorney General
State of Delaware
820 N. French Street
Wilmington, DE 19801
AARON D. FORD
Attorney General
State of Nevada
100 North Carson Street
Carson City, NV 89701
ANNE E. LOPEZ
Attorney General
State of Hawai‘i
425 Queen Street
Honolulu, HI 96813
JENNIFER DAVENPORT
Attorney General
State of New Jersey
Richard J. Hughes Justice Complex
25 Market Street
Trenton, NJ 08625
KWAME RAOUL
Attorney General
State of Illinois
115 South LaSalle Street
Chicago, IL 60603
RAÚL TORREZ
Attorney General
State of New Mexico
408 Galisteo Street
P.O. Drawer 1508
Santa Fe, NM 87504
18
JEFF JACKSON
Attorney General
State of North Carolina
114 West Edenton Street
Raleigh, NC 27603
JAY JONES
Attorney General
Commonwealth of Virginia
202 North Ninth Street
Richmond, VA 23219
DAN RAYFIELD
Attorney General
State of Oregon
1162 Court Street NE
Salem, OR 97301
NICHOLAS W. BROWN
Attorney General
State of Washington
P.O. Box 40100
Olympia, WA 98504
PETER F. NERONHA
Attorney General
State of Rhode Island
150 South Main Street
Providence, RI 02903
BRIAN L. SCHWALB
Attorney General
District of Columbia
400 6th Street NW
Washington, D.C. 20001
CHARITY R. CLARK
Attorney General
State of Vermont
109 State Street
Montpelier, VT 05609
JOSH SHAPIRO
Governor
Commonwealth of Pennsylvania
501 North 3rd Street
508 Main Capitol Building
Harrisburg, PA 17120
19
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