Amicus Curiae Brief — Danco Laboratories, LLC, Applicant v. Louisiana, et al.

Supreme Court briefMay 6, 2026

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Nos. 25A1207, 25A1208

IN THE

Supreme Court of the United States

____________________

DANCO LABORATORIES, L.L.C.,

Applicant,

v.

THE STATE OF LOUISIANA, ET AL.,

Respondents.

____________________

GENBIOPRO, INC.,

Applicant,

v.

THE STATE OF LOUISIANA, ET AL.,

Respondents.

___________________

On Emergency Applications to Vacate or Stay Order of the

United States Court of Appeals for the Fifth Circuit

____________________

BRIEF OF 163 REPRODUCTIVE HEALTH, RIGHTS, AND JUSTICE

ORGANIZATIONS AS AMICI CURIAE IN SUPPORT OF APPLICANTS

____________________

Emily Merrifield

Sara Stappert

JENNER & BLOCK LLP

353 N. Clark Street

Chicago, IL 60654

(312) 222-9350

Jessica Ring Amunson

Counsel of Record

Varsha Midha

JENNER & BLOCK LLP

1099 New York Ave NW,

Suite 900

Washington, DC 20001

(202) 639-6023

jamunson@jenner.com

TABLE OF CONTENTS

INTEREST OF AMICI CURIAE ............................................................................................1

SUMMARY OF ARGUMENT ..................................................................................................2

ARGUMENT ................................................................................................................................3

I.

Applicants Are Likely to Succeed in Showing that the FDA

Did Not Act Arbitrarily by Eliminating the In-Person

Dispensing Requirement, Which Did Not Enhance

Mifepristone's Well-Established Safety and Efficacy. ...............................................3

II.

A Stay or Vacatur Is in the Public Interest Because Forcing

Patients to Travel to a Health Center to Access Mifepristone

Endangers Patients’ Health and Autonomy. ...............................................................9

A.

Telehealth Provides Essential Access to Abortion Care. ...............................9

B.

Forcing Patients to Travel to a Health Center to Access

Mifepristone Will Impact Already Vulnerable

Communities the Most. .....................................................................................11

C.

Restricting Abortion Access Worsens Public Health Outcomes.................16

CONCLUSION ...........................................................................................................................18

APPENDIX - List of Amici Curiae ...................................................................................... A1

i

TABLE OF AUTHORITIES

Page(s)

Cases

Louisiana v. FDA,

No. 6:25-cv-01491 (W.D. La. Oct. 6, 2025) ....................................................................14, 16

Purcell v. Kennedy,

No. CV 17-00493 JAO-RT, 2025 WL 3101785 (D. Haw. Oct. 30, 2025) ...........................7

Statutes

21 U.S.C. § 355-1(f)(2)(C) ...........................................................................................................13

Other Authorities

Alexa Delbosc & Rahman Shafi, What Do We Know About Immigrants'

Travel Behaviour? A Systematic Literature Review and Proposed

Conceptual Framework, 43 Transport Revs. 914 (2023) ................................................16

Alexis A. Creanga et al., Racial and Ethnic Disparities in Severe Maternal

Morbidity: A Multistate Analysis, 2008-2010, 210 Am. J. Obstetrics &

Gynecology 435.e1 (2014) .....................................................................................................17

Alison Gemmill et al., Infant Deaths After Texas’ 2021 Ban on Abortion in

Early Pregnancy, 331 JAMA 1609 (2024) .........................................................................17

Alison Gemmill et al., US Abortion Bans and Infant Mortality, 333 JAMA

1315 (2025) ..............................................................................................................................17

Am. Coll. of Obstetricians & Gynecologists, Citizen Petition (Oct. 4, 2022),

https://emaaproject.org/wp-content/uploads/2022/10/Citizen-Petition-fromthe-American-College-of-Obstetrician-and-Gynecologists-et-al-10.3.22EMAA-website.pdf .................................................................................................................6

Am. Coll. of Obstetricians & Gynecologists et al., Leading Medical

Organizations Call for the FDA to Permanently Remove Restrictions on

Mifepristone (June 18, 2024), https://www.acog.org/news/newsreleases/2024/06/leading-medical-organizations-call-for-fda-topermanently-remove-restrictions-on-mifepristone ...................................................4, 6, 7

ii

Am. Coll. Obstetricians & Gynecologists, Medication Abortion Up to 70 Days

of Gestation, Practice Bulletin No. 225, at 35 (Oct. 2020, reaff'd 2023),

https://www.acog.org/clinical/clinical-guidance/practicebulletin/articles/2020/10/medication-abortion-up-to-70-days-of-gestation .....................7

Amanda Cleeve et al., The Use of Telemedicine Services for Medical Abortion,

6 Cochrane Database Syst. Rev. CD013764 (2025) ............................................................8

Benjamin Rader et al., Estimated Travel Time and Spatial Access to Abortion

Facilities in the US Before and After the Dobbs v. Jackson Women's

Health Decision, 328 JAMA 2041 (Nov. 1, 2022),

https://jamanetwork.com/journals/jama/fullarticle/2798215?guestAccessKe

y=70c1bc40-5cc0-4bcf-a73da5b9b26ccf01&utm_source=For_The_Media&utm_medium=

referral&utm._ campaign=ftm_links&utm_content=tfl&utm_term=110122 ..............13

Comment of The Boston University School of Law's Program on Reproductive

Justice (BUPRJ), Immigrants' Rights and Human Trafficking Program

(IRHTP), and the Racial Justice and Movement Lawyering Clinic

(RJMLC) on FDA-2025-P-3287-0001, at 9 (Oct. 11, 2025),

https://www.regulations.gov/comment/FDA-2025-P-3287-0060..............................12, 16

Comment of Legal Voice et al. on FDA-2025-P-3287 (Nov. 27, 2025),

https://www.regulations.gov/comment/FDA-2025-P-3287-0068....................................15

Courtney A. Schreiber et al., Mifepristone Pretreatment for the Medical

Management of Early Pregnancy Loss, 378 New Eng. J. Med. 2161 (2018) .................5

Daniel Grossman & Erica Chung, Evidence Supports Removing Restrictions

on Mifepristone, JAMA (June 12, 2025),

https://jamanetwork.com/journals/jama/article-abstract/2835287 ..................................7

Daniel Grossman et al., Medication Abortion With Pharmacist Dispensing of

Mifepristone 137 Obstetrics & Gynecology 613 (2021) ......................................................8

Diana Greene Foster et al., Socioeconomic Outcomes of Women Who Receive

and Women Who Are Denied Wanted Abortions in the United States, 112

Am. J. Pub. Health 1290 (2022) .....................................................................................11, 12

Elise W. Boos et al., Trends in the Use of Mifepristone for Medical

Management of Early Pregnancy Loss From 2016 to 2020, 330 JAMA 766

(2023) .....................................................................................................................................5, 6

iii

Elizabeth C. Romanis et al., Safeguarding and Teleconsultation for Abortion,

398 Lancet 555 (2021) ...........................................................................................................15

FDA Ctr. for Drug Eval. & Research, Medical Review, Application No.

020687Orig1s020 at 5, 14-17 (Mar. 29, 2016) (“2016 FDA Approval”),

https://www.accessdata.fda.gov/drugsatfda_docs/nda/2016/020687Orig1s02

0MedR.pdf ................................................................................................................................4

Graham Gardner, The Maternal and Infant Health Consequences of

Restricted Access to Abortion in the United States, 98 J. Health Econ.

102938 (2024) ..........................................................................................................................17

Holly A. Anger & Elizabeth G. Raymond, Clinical and Service Delivery

Outcomes Following Medication Abortion Provided With or Without

Pretreatment Ultrasound or Pelvic Examination: An Updated

Comparative Analysis, 140 Contraception 1 (2024) ..........................................................8

Jason M. Lindo et al., How Far Is Too Far?: New Evidence on Abortion Clinic

Closures, Access, and Abortions, 55 J. Hum. Res. 1137 (2020) ......................................13

Jillian McKoy, Travel Times to Abortion Facilities Have Increased

Drastically in Post-Roe Era, Bos. Univ. Sch. of Pub. Health (Nov. 23,

2022) ........................................................................................................................................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) ....................................5

Katherine J. Kramer et al., Trends and Evolution in Women's Health

Workforce in the First Quarter of the 21st Century, 5 World J. Gynecology

& Women's Health 622 (2022), https://pubmed.ncbi.nlm.nih.gov/35601601/ ................11

Lauren J. Ralph et al., Comparison of No-Test Telehealth and In-Person

Medication Abortion, 332 JAMA 898, 903 (2024) ...............................................................8

Lauren Van Schilfgaarde et al., Tribal Nations and Abortion Access: A Path

Forward, 46 Harv. J.L. & Gender 1 (2023) ........................................................................13

Leah R. Koenig et al., Effectiveness and Safety of Medication Abortion With

vs Without Screening Ultrasonography or Pelvic Examination, 233 Am. J.

Obstetrics & Gynecology 453e1 (2025).................................................................................8

Leah R. Koenig et al., Patient Acceptability of Telehealth Medication

Abortion Care in the United States, 2021-2022: A Cohort Study, 114 Am. J.

Pub. Health 241 (2024) ...........................................................................................................4

iv

Leah R. Koenig et al., The Role of Telehealth in Promoting Equitable

Abortion Access in the United States: Spatial Analysis, 9 JMIR Pub.

Health & Surveillance e45671 (2023) .................................................................................10

Liza Fuentes, Inequity in US Abortion Rights and Access: The End of Roe Is

Deepening Existing Divides, Guttmacher Inst. (Jan. 2023) ...........................................11

M. Antonia Biggs et al., A Cross-Sectional Survey of U.S. Abortion Patients'

Interest in Obtaining Medication Abortion Over the Counter, 109

Contraception 25 (2022)..........................................................................................................4

M.C. Black et al., National Intimate Partner and Sexual Violence Survey:

2010 Summary Report, Ctr. for Disease Control & Prevention 48 (2011) ...................14

Maeve E. Wallace et al., States' Abortion Laws Associated with Intimate

Partner Violence-Related Homicide of Women and Girls in the US, 201420, 43 Health Aff. 682 (2024) ................................................................................................18

Mifepristone Approved List, Gynuity Health Projects (updated May 2024),

https://gynuity.org/assets/resources/mife_by_country_and_year_en.pdf .....................4

Nat'l Acads. of Sci., Eng'g. & Med., The Safety and Quality of Abortion Care

in the United States 45 (2018) ...............................................................................................5

Rachel K. Jones & Amy Friedrich-Karnik, Medication Abortion Accounted for

63% of All US Abortions in 2023-An Increase from 53% in 2020,

Guttmacher Inst. (Mar. 2024),

https://www.guttmacher.org/2024/03/medication-abortion-accounted-63-allus-abortions-2023-increase-53-2020..................................................................................4, 9

Rachel K. Jones et al., The Number of Brick-and-Mortar Abortion Clinics

Drops, as US Abortion Rate Rises: New Data Underscore the Need for

Policies that Support Providers, Guttmacher Inst. (June 2024),

https://www.guttmacher.org/report/abortion-clinics-united-states-20202024..........................................................................................................................................10

Samuel Dickman et al., Financial Hardships Caused by Out-of-Pocket

Abortion Costs in Texas, 2018, 112 Am. J. Pub. Health 758 (2022) ...............................12

Sarah Miller, Laura R. Wherry & Diana Greene Foster, The Economic

Consequences of Being Denied an Abortion, 15 Am. Econ. J.: Econ. Pol'y

394 (2023) ................................................................................................................................12

v

Selena Simmons-Duffin & Shelly Cheng, How Many Miles Do You Have to

Travel to Get Abortion Care? One Professor Maps It, NPR (June 21, 2023),

https://www.npr.org/sections/health-shots/2023/06/21/1183248911/abortionaccess-distance-to-care-travel-miles#

:~:text=Just%20a%20year%20ago%2C%20%22less,large%20cities%20in%2

0the%20South ........................................................................................................................10

Sherajum Monira Farin et al., The Impact of Legal Abortion on Maternal

Mortality, 16 Am. Econ. J.: Econ. Pol'y 174 (2022),

https://www.aeaweb.org/articles?id=10.1257/pol.20220208 ............................................17

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) ..................8

Soc'y of Family Planning, #WeCount Report, April 2022 to December 2024

(June 23, 2025), https://societyfp.org/research/wecount/wecount-december2024-data/ .................................................................................................................................9

Study: FDA Regulation of Abortion Drug Mifepristone from 2011 to 2023

Shaped by Evidence and Caution, Johns Hopkins Bloomberg Sch. Pub.

Health (Jan. 12, 2026), https://publichealth.jhu.edu/2026/study-fdaregulation-of-abortion-drug-mifepristone-from-2011-to-2023-shaped-byevidence-and-caution ..............................................................................................................4

U.S. Food & Drug Admin., NDA 020687 & ANDA 091178, Mifepristone U.S.

Post-Marketing Adverse Events Study through 12/31/2024 (2025),

https://www.fda.gov/media/185245/download .....................................................................6

U.S. Food & Drug Admin., REMS Modification Rationale Review, NDA

020687 & 91178, at 39 (Dec. 16, 2021) ...................................................................................7

Ushma D. Upadhyay et al., Sociodemographic Characteristics of Women Able

to Obtain Medication Abortion Before and After Ohio's Law Requiring

Use of the Food and Drug Administration Protocol, 2 Health Equity 122

(2018) .......................................................................................................................................15

Ushma Upadhyay et al., Abortion-Related Emergency Department Visits in

the United States: An Analysis of a National Emergency Department

Sample, 16 BMC Med. 1, 7-10 (2018) ....................................................................................5

Ushma Upadhyay et al., Effectiveness and safety of telehealth medication

abortion in the USA, 30 Nature Med. 1191 (2024) .........................................................5, 8

vi

Ushma Upadhyay et al., Outcomes and Safety of History-Based Screening for

Medication Abortion: A Retrospective Multicenter Cohort Study, 182

JAMA INTERNAL MED. 482 (2022) .......................................................................................8

World Health Organization, Abortion Care Guideline (Mar. 8, 2022),

https://www.who.int/publications/i/item/9789240039483 ..................................................7

Yvonne Lindgren, The Doctor Requirement: Griswold, Privacy, and At-Home

Reproductive Care, 32 Const. Comment. 341 (2017) ........................................................14

vii

INTEREST OF AMICI CURIAE1

Amici are over 160 reproductive health, rights, and justice organizations, as well

as other organizations with a strong interest in access to reproductive care. Amici

include, inter alia, healthcare organizations that prescribe mifepristone and are directly

impacted by an order requiring mifepristone to be picked up in person at a health center;

research organizations with specialized expertise in the safety of mifepristone and the

harms caused by abortion restrictions; organizations that work directly with people

seeking abortion care and witness firsthand the enormous challenges they face when

forced to travel for care; and organizations that advocate on behalf of people who need

abortions and the clinicians who care for them. A complete list of amici is in the Appendix.

Amici have seen the importance of medication abortion to individuals’ health and

bodily autonomy, as well as mifepristone’s efficacy and safety as a tool for achieving those

goals. Amici also have a unique window into the benefits that mifepristone provides—

including when prescribed via telehealth2 and dispensed by mail or pharmacies—and the

immense harms of restricting such access. Amici urge this Court to grant the emergency

applications and stay or vacate the decision of the Fifth Circuit.

1

Pursuant to Supreme Court Rule 37.6, counsel for amici certify that this brief was not authored in whole

or in part by counsel for any party and that no person or entity other than amici, their members, or their

counsel has made a monetary contribution intended to fund the preparation or submission of this brief.

2

In using the term “prescribed via telehealth” in this brief, amici refer to patients who are prescribed

mifepristone by a healthcare provider using telehealth and then receive their prescription either by mail

or at a pharmacy.

1

SUMMARY OF ARGUMENT

Amici write to emphasize the overwhelming consensus of the scientific and

medical community that medication abortion using mifepristone—including when

prescribed via telehealth—is safe, effective, and medically necessary. The evidence

confirming mifepristone’s safety and efficacy has only grown more compelling since the

Food and Drug Administration (“FDA”) first approved it in 2000. Since then, more than

7.5 million people have safely used the medication, and hundreds of high-quality studies

and the experience of millions of patients have confirmed mifepristone’s exceptional

safety record, whether dispensed in person or through telehealth. There is no medical

justification for a nationwide requirement that patients across the country travel to a

healthcare provider for the sole purpose of picking up medication that they can later take

at home.

Amici also write to explain what is at stake. Barring patients from obtaining

mifepristone by mail and at pharmacies imposes devastating and medically unjustified

burdens on patients’ access to mifepristone. Preserving patients’ ability to obtain care

through telehealth is critically important, particularly for people in rural areas, lowincome communities, communities of color, and survivors of intimate partner violence,

who already face the steepest barriers to in-person care. Reinstating the in-person

dispensing requirement undermines access to abortion and miscarriage care—and

patients’ health and autonomy—nationwide. If the Court does not step in to block this

request by a single state, it will impact people across the country. Indeed, if forced to

2

travel to a healthcare provider to pick up mifepristone, many people in states where

abortion remains legally protected will be unable to obtain mifepristone in a timely

fashion, and others will be unable to access this essential medication at all. Neither

science nor law supports upending the safe and effective ways this medication has been

delivered for the past five years, and certainly nothing supports doing so on an emergency

basis and without the benefit of the full administrative record. This Court should

therefore stay or vacate the Fifth Circuit’s decision.

ARGUMENT

I.

Applicants Are Likely to Succeed in Showing that the FDA Did Not Act

Arbitrarily by Eliminating the In-Person Dispensing Requirement, Which Did

Not Enhance Mifepristone's Well-Established Safety and Efficacy.

Applicants are likely to succeed in showing that the FDA did not act arbitrarily

by eliminating the in-person dispensing requirement for mifepristone, including when

dispensed by mail or through pharmacies. Decades of scientific evidence and real-world

use by millions demonstrate that using mifepristone for medication abortion is

exceptionally safe and effective, including when the medication is dispensed by mail and

at pharmacies after receiving care through telehealth. Indeed, mifepristone’s safety is

endorsed by—and restrictions on telehealth access to mifepristone are overwhelmingly

opposed by—major medical associations such as the American Medical Association,

American College of Obstetricians and Gynecologists, American Academy of Pediatrics,

Society for Academic Specialists in General Obstetrics and Gynecology, Society of Family

Planning, Society for Maternal-Fetal Medicine, and Society of General Internal

3

Medicine.3 Consistent with this scientific consensus, between 2011 and 2023, the FDA

repeatedly affirmed mifepristone’s exceptional safety and efficacy record.4

Mifepristone is central to reproductive healthcare today. Medication abortion

using mifepristone is the most common method of abortion in the United States, both

because of its safety and efficacy and because many patients prefer it.5 Medication

abortion is approved in more than 100 countries and accounts for half of all abortions in

most high-income nations.6 In 2023, mifepristone was used in 63% of all abortions in the

United States.7

The FDA approved mifepristone in 2000 after a thorough, nearly five-year

scientific review determined it was safe for widespread use. Hundreds of high-quality

studies conducted since that initial approval confirm mifepristone’s safety. Indeed,

3

See Am. Coll. of Obstetricians & Gynecologists et al., Leading Medical Organizations Call for the FDA to

Permanently Remove Restrictions on Mifepristone (June 18, 2024), https://www.acog.org/news/newsreleases/2024/06/leading-medical-organizations-call-for-fda-to-permanently-remove-restrictions-onmifepristone.

4

See Study: FDA Regulation of Abortion Drug Mifepristone from 2011 to 2023 Shaped by Evidence and

Caution,

Johns

Hopkins

Bloomberg

Sch.

Pub.

Health

(Jan.

12,

2026),

https://publichealth.jhu.edu/2026/study-fda-regulation-of-abortion-drug-mifepristone-from-2011-to-2023shaped-by-evidence-and-caution; FDA Ctr. for Drug Eval. & Research, Medical Review, Application No.

020687Orig1s020 at 5, 14-17 (Mar. 29, 2016) [hereinafter “2016 FDA Approval”],

https://www.accessdata.fda.gov/drugsatfda_docs/nda/2016/020687Orig1s020MedR.pdf.

5

See generally, e.g., M. Antonia Biggs et al., A Cross-Sectional Survey of U.S. Abortion Patients’ Interest

in Obtaining Medication Abortion Over the Counter, 109 Contraception 25 (2022); Leah R. Koenig et al.,

Patient Acceptability of Telehealth Medication Abortion Care in the United States, 2021–2022: A Cohort

Study, 114 Am. J. Pub. Health 241 (2024).

6

Mifepristone Approved List, Gynuity Health Projects (updated May 2024),

https://gynuity.org/assets/resources/mife_by_country_and_year_en.pdf.

7

See Rachel K. Jones & Amy Friedrich-Karnik, Medication Abortion Accounted for 63% of All US

Abortions in 2023—An Increase from 53% in 2020, Guttmacher Inst. (Mar. 2024),

https://www.guttmacher.org/2024/03/medication-abortion-accounted-63-all-us-abortions-2023-increase-532020.

4

mifepristone has been part of over 600 published clinical trials and discussed in over 900

medical reviews.8 Mifepristone has an exceedingly low rate of serious adverse events.9

The National Academies of Sciences, Engineering, and Medicine (“National Academies”),

a highly respected nonpartisan advisory institution, concluded that the risks of

medication abortion involving mifepristone are “similar in magnitude to the reported

risks of serious adverse effects of commonly used prescription and over-the-counter

medications.”10 Beyond abortion, mifepristone is regularly prescribed for the

management and treatment of miscarriages, which can be life-threatening without

adequate treatment.11

In 2016, the FDA modified mifepristone’s Risk Evaluation and Mitigation

Strategies (“REMS”) and labeling based on evolutions in evidence-based practice. These

changes included allowing prescription by a broader set of qualified healthcare providers

and updating the labeling to reflect use at a wider range of gestational durations and to

remove references to multiple in-person clinic visits, consistent with the evidence-based

8

Based on a review of publications on PubMed.

9

2016 FDA Approval, supra note 4, at 14-17; Ushma Upadhyay et al., Effectiveness and safety of

telehealth medication abortion in the USA, 30 Nature Med. 1191, 1197 (2024) [hereinafter Effectiveness

and Safety of TMAB]; Ushma Upadhyay et al., Abortion-Related Emergency Department Visits in the

United States: An Analysis of a National Emergency Department Sample, 16 BMC Med. 1, 7-10 (2018).

10

Nat’l Acads. of Sci., Eng’g. & Med., The Safety and Quality of Abortion Care in the United States 45, 5668, 79 (2018).

11

See, e.g., Elise W. Boos et al., Trends in the Use of Mifepristone for Medical Management of Early

Pregnancy

Loss

From

2016

to

2020,

330

JAMA

766

(2023),

https://jamanetwork.com/journals/jama/fullarticle/2807775; Courtney A. Schreiber et al., Mifepristone

Pretreatment for the Medical Management of Early Pregnancy Loss, 378 New Eng. J. Med. 2161 (2018);

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).

5

standard of care. In support of its decision, the FDA relied on a wealth of updated data,

including more than eighty high-quality studies analyzing outcomes for hundreds of

thousands of patients, as well as years of real-world evidence underscoring mifepristone’s

safety without these impediments.12 The FDA’s 2016 decision cited a host of studies

showing that the rate of major adverse events was roughly 0.3%.13 Recent peer-reviewed

research confirms that serious complications among mifepristone users remain extremely

rare, and FDA data from more than two decades of mandatory reporting of any

potentially associated fatalities show that the number of deaths associated with

mifepristone use remains infinitesimally low (fewer than forty recorded deaths out of

more than 7.5 million uses since mifepristone’s approval, or 0.00048%—and none of those

deaths can be causally attributed to mifepristone).14

Given its exceptional safety record, leading medical associations have long called

on the FDA to lift all of its medically unnecessary restrictions on mifepristone, including

its in-person dispensing requirement, and instead regulate mifepristone like other

prescription drugs.15 After extensive review of real-world data and peer-reviewed

studies, the FDA found in 2021 that mifepristone would “remain safe and effective for

12

See generally 2016 FDA Approval, supra note 4.

13

Id. at 56.

14

U.S. Food & Drug Admin., NDA 020687 & ANDA 091178, Mifepristone U.S. Post-Marketing Adverse

Events Study through 12/31/2024 (2025), https://www.fda.gov/media/185245/download; Am. Coll. of

Obstetricians & Gynecologists, Citizen Petition (Oct. 4, 2022), https://emaaproject.org/wpcontent/uploads/2022/10/Citizen-Petition-from-the-American-College-of-Obstetrician-and-Gynecologistset-al-10.3.22-EMAA-website.pdf.

15

Am. Coll. of Obstetricians & Gynecologists et al., supra note 3; Am. Coll. Of Obstetricians &

Gynecologists, supra note 14.

6

medication abortion if the in-person dispensing requirement is removed.”16 In 2023, the

FDA formalized its 2021 conclusion, permanently removing this requirement. Removal

of the in-person dispensing requirement meaningfully increased access to mifepristone

without compromising the safety or efficacy of this important medication. However,

despite this change, the FDA continues to unnecessarily restrict mifepristone more

stringently than other drugs with similarly low risks, and in 2023 maintained all of its

restrictions on mifepristone other than the in-person dispensing requirement.17

Telehealth, an increasingly common method of healthcare delivery across all areas

of medicine, is now a standard method of care for medication abortion in the United States

and around the world.18 Unlike the in-person dispensing requirement, which forced every

patient to travel to a health center just to pick up their mifepristone prescription, even

when there was no clinical need for any in-person care, telehealth care is individually

tailored to each patient’s circumstances, with in-person testing or examination ordered

when appropriate based on individualized patient screening. Rigorous studies from the

16

U.S. Food & Drug Admin., REMS Modification Rationale Review, NDA 020687 & 91178, at 39 (Dec. 16,

2021).

17

In October 2025, a federal court found that the FDA has failed to justify its current overly restrictive

regulation of mifepristone compared to other prescription drugs under the governing statute. See Purcell

v. Kennedy, No. CV 17-00493 JAO-RT, 2025 WL 3101785, at *2, *18 (D. Haw. Oct. 30, 2025). See also Am.

Coll. of Obstetricians & Gynecologists et al., supra note 3 (preeminent medical associations calling on the

FDA to lift its special restrictions on mifepristone altogether given mifepristone’s strong safety profile);

Daniel Grossman & Erica Chung, Evidence Supports Removing Restrictions on Mifepristone, JAMA (June

12, 2025), https://jamanetwork.com/journals/jama/article-abstract/2835287 (discussing the REMS

modifications for flibanserin and PrEP regimens, sexual and reproductive health medications with similar

or higher risks and incidence of adverse events).

18

Am. Coll. Obstetricians & Gynecologists, Medication Abortion Up to 70 Days of Gestation, Practice

Bulletin No. 225, at 35 (Oct. 2020, reaff’d 2023), https://www.acog.org/clinical/clinical-guidance/practicebulletin/articles/2020/10/medication-abortion-up-to-70-days-of-gestation; World Health Organization,

Abortion Care Guideline, at 95 (Mar. 8, 2022), https://www.who.int/publications/i/item/9789240039483.

7

past several years resoundingly reinforce that patients can be screened and counseled for

medication abortion via telehealth as safely and effectively as in-person screening and

dispensing.19 For instance, a study of over 6,000 telehealth patients demonstrated that

telehealth-prescribed medication abortion provides statistically equivalent safe and

effective results as in-person care.20 Numerous other studies and systematic reviews

reached the same conclusion, further supporting that access to mifepristone via

telehealth provides necessary care with the same safety levels and effective outcomes.21

Given the extensive safety data and the millions of safe outcomes for people across

the country, Applicants are likely to succeed in showing that the FDA’s decision to lift

the in-person dispensing requirement was not arbitrary or capricious.

19

See, e.g., Daniel Grossman et al., Medication Abortion With Pharmacist Dispensing of Mifepristone 137

Obstetrics & Gynecology 613 (2021); Ushma Upadhyay et al., Outcomes and Safety of History-Based

Screening for Medication Abortion: A Retrospective Multicenter Cohort Study, 182 JAMA Internal Med.

482 (2022); Leah R. Koenig et al., Effectiveness and Safety of Medication Abortion With vs Without

Screening Ultrasonography or Pelvic Examination, 233 Am. J. Obstetrics & Gynecology 453e1 (2025);

Silpa Srinivasulu et al., Telehealth Medication Abortion in Primary Care: A Comparison to Usual inClinic Care, 37 J. Am. Bd. Fam. Med. 295 (2024); Ushma Upadhyay et al., Effectiveness and Safety of

TMAB, supra note 9.

20

Ushma Upadhyay et al., Effectiveness and Safety of TMAB, supra note 9.

21

See, e.g., Lauren J. Ralph et al., Comparison of No-Test Telehealth and In-Person Medication Abortion,

332 JAMA 898, 903 (2024); Holly A. Anger & Elizabeth G. Raymond, Clinical and Service Delivery

Outcomes Following Medication Abortion Provided With or Without Pretreatment Ultrasound or Pelvic

Examination: An Updated Comparative Analysis, 140 Contraception 1 (2024); see also Amanda Cleeve et

al., The Use of Telemedicine Services for Medical Abortion, 6 Cochrane Database Syst. Rev. CD013764

(2025) (finding that “the use of telemedicine for medical abortion in early pregnancy is generally safe,

effective, and acceptable;” noting that the review’s findings were “consistent with the conclusions of

previous work on the topic”; and reaffirming that “serious adverse events are rare”).

8

II.

A Stay or Vacatur Is in the Public Interest Because Forcing Patients to Travel

to a Health Center to Access Mifepristone Endangers Patients’ Health and

Autonomy.

Requiring that mifepristone be dispensed in person at a health center will result

in immediate and irreparable harm to patients across the country. The ability to fill a

prescription for mifepristone through the mail or at a local pharmacy after consultation

with a healthcare provider is critical for patients needing abortion and miscarriage care,

particularly for populations most in need of access to medication abortion for their health

and autonomy. Shuttering this essential avenue of healthcare puts people’s health at risk

nationwide; in the face of such unprecedented disruption and irreparable harm, a stay or

vacatur of the Fifth Circuit’s decision is in the public interest.

A.

Telehealth Provides Essential Access to Abortion Care.

Telehealth is indispensable to legal abortion care. Medication abortion now

accounts for 63% of all abortions in the United States, and more than one in four abortions

is obtained via telehealth services.22 In certain states, the reliance on telehealth is even

more pronounced. For example, in 2024, 40% of abortions in Delaware and 34% of

abortions in Nevada were obtained through telehealth.23 Telehealth is not a peripheral

convenience; it is essential for many patients to access the care they need. Disrupting this

key component of the nation’s healthcare infrastructure reduces access, particularly for

populations who have difficulty traveling to an abortion provider.

22

Jones & Friedrich-Karnik, supra note 7; Soc’y of Family Planning, #WeCount Report, April 2022 to

December 2024 (June 23, 2025), https://societyfp.org/research/wecount/wecount-december-2024-data/.

23

Soc’y of Family Planning, supra note 22.

9

Telehealth has also been essential for meeting dramatically increased demand in

states where abortion is legal.24 Abortion bans have placed extraordinary strain on the

remaining brick-and-mortar providers in states with legal protections for abortion, who

face an influx of appointments from patients who must travel across state lines for care.

Telehealth enables providers in states where abortion is legal to absorb this surge in

patients and helps mitigate long appointment wait times that would otherwise delay

care.25

Even setting aside the increased demand from out-of-state patients traveling for

care, telehealth is crucial in states that protect abortion access to overcome the significant

geographic barriers that can make it difficult to serve residents in need of medical care.

The average American now lives 86 miles from an abortion provider, making in-person

access to time-sensitive care logistically difficult or impossible for many patients.26

Telehealth plays a key role in promoting equitable access by reaching patients who might

otherwise be unable to travel to a clinic in time to access care.27 And mounting concerns

around a national shortage of obstetrician-gynecologists and rising rates of maternal

24

Leah R. Koenig et al., The Role of Telehealth in Promoting Equitable Abortion Access in the United

States: Spatial Analysis, 9 JMIR Pub. Health & Surveillance e45671 (2023).

25

Rachel K. Jones et al., The Number of Brick-and-Mortar Abortion Clinics Drops, as US Abortion Rate

Rises: New Data Underscore the Need for Policies that Support Providers, Guttmacher Inst. (June 2024),

https://www.guttmacher.org/report/abortion-clinics-united-states-2020-2024.

26

Selena Simmons-Duffin & Shelly Cheng, How Many Miles Do You Have to Travel to Get Abortion Care?

One

Professor

Maps

It,

NPR

(June

21,

2023),

https://www.npr.org/sections/healthshots/2023/06/21/1183248911/abortion-access-distance-to-care-travel-miles#

:~:text=Just%20a%20year%20ago%2C%20%22less,large%20cities%20in%20the%20South.

27

Leah R. Koenig et al., The Role of Telehealth in Promoting Equitable Abortion Access in the United

States: Spatial Analysis, 9 JMIR Pub. Health & Surveillance e45671 (2023).

10

healthcare deserts further emphasize the importance of telehealth as a means of ensuring

that patients can access reproductive healthcare when and where they need it.28

B.

Forcing Patients to Travel to a Health Center to Access Mifepristone

Will Impact Already Vulnerable Communities the Most.

Telehealth is especially crucial to protect abortion access for vulnerable

communities, including people living in poverty, people living in rural areas, people

subject to intimate partner violence, people who cannot get time off from work or find

childcare, and people of color. When patients can no longer access mifepristone via

telehealth, people in these already marginalized groups are the most likely to suffer.

Abortion patients are disproportionately poor: nearly half of all abortion patients

live below the federal poverty line.29 When abortion restrictions prevent patients from

being able to access the care they seek, a variety of harms ensues. For patients living in

or near poverty, being denied an abortion deepens the very economic hardship that

already constrains their access to care. Women denied abortions are nearly four times

more likely to be living in poverty six months after being denied care than women who

were able to access abortions.30 They also have more than three times greater odds of

being unemployed and are more likely to be enrolled in public safety net programs than

28

Katherine J. Kramer et al., Trends and Evolution in Women’s Health Workforce in the First Quarter of

the

21st

Century,

5

World

J.

Gynecology

&

Women’s

Health

622

(2022),

https://pubmed.ncbi.nlm.nih.gov/35601601/.

29

Liza Fuentes, Inequity in US Abortion Rights and Access: The End of Roe Is Deepening Existing

Divides, Guttmacher Inst. (Jan. 2023).

30

Diana Greene Foster et al., Socioeconomic Outcomes of Women Who Receive and Women Who Are

Denied Wanted Abortions in the United States, 112 Am. J. Pub. Health 1290 (2022).

11

women who were able to access abortion care.31 Being denied an abortion also increases

women’s debt and negative public financial records, including bankruptcies and

evictions.32

Telehealth is uniquely positioned to prevent these outcomes because it directly

addresses many of the barriers to healthcare that poverty creates. Nearly 20% of

abortion patients report postponing purchasing food to cover costs associated with their

abortion—costs that include not only the cost of the abortion itself but also

transportation, missed wages, and childcare.33 Households below 200% of the federal

poverty line are far more likely to lack vehicle access, making travel to a clinic logistically

impossible for many.34 Telehealth eliminates or reduces these secondary costs by allowing

patients to seek care without traveling, missing work, or securing childcare.35 Research

confirms that telehealth reduces missed appointments and improves continuity of care—

outcomes that are particularly vital for working-class and low-income patients whose

access to paid leave, reliable transportation, and flexible schedules is limited.36

31

Id.

32

Sarah Miller, Laura R. Wherry & Diana Greene Foster, The Economic Consequences of Being Denied

an Abortion, 15 Am. Econ. J.: Econ. Pol’y 394 (2023).

33

Samuel Dickman et al., Financial Hardships Caused by Out-of-Pocket Abortion Costs in Texas, 2018,

112 Am. J. Pub. Health 758, 759 (2022).

34

See Comment of The Boston University School of Law’s Program on Reproductive Justice (BUPRJ),

Immigrants’ Rights and Human Trafficking Program (IRHTP), and the Racial Justice and Movement

Lawyering

Clinic

(RJMLC)

on

FDA-2025-P-3287-0001,

at

9

(Oct.

11,

2025),

https://www.regulations.gov/comment/FDA-2025-P-3287-0060.

35

See id. at 8.

36

Id.

12

Restricting telehealth also disproportionately harms rural and geographically

isolated communities. More than one-third of women of reproductive age live more than

an hour away from their nearest abortion facility.37 Research confirms the concrete

consequences of these distance barriers: an increase in travel distance from 0–50 miles to

50–100 miles has been found to reduce abortion rates by 16%.38 And telehealth is

particularly vital for Indigenous communities, who face severe barriers due to federal

law restrictions on Indian Health Service facilities and geographic isolation on Tribal

lands.39

Congress expressly limited the FDA’s authority to impose REMS restrictions that

result in these kinds of harms. The REMS statute requires that FDA-imposed

restrictions on approved drugs shall “not be unduly burdensome on patient access to the

drug, considering in particular . . . patients who have difficulty accessing healthcare (such

as patients in rural or medically underserved areas).”40 Requiring every mifepristone

patient in the country to travel in person to a hospital, clinic, or medical office just to pick

up their prescription imposes exactly this kind of unlawful burden.

37

Benjamin Rader et al., Estimated Travel Time and Spatial Access to Abortion Facilities in the US Before

and After the Dobbs v. Jackson Women’s Health Decision, 328 JAMA 2041 (Nov. 1, 2022),

https://jamanetwork.com/journals/jama/fullarticle/2798215?guestAccessKey=70c1bc40-5cc0-4bcf-a73da5b9b26ccf01&utm_source=For_The_Media&utm_medium=referral&utm._

campaign=ftm_links&utm_content=tfl&utm_term=110122.

38

Jason M. Lindo et al., How Far Is Too Far?: New Evidence on Abortion Clinic Closures, Access, and

Abortions, 55 J. Hum. Res. 1137 (2020).

39

Lauren Van Schilfgaarde et al., Tribal Nations and Abortion Access: A Path Forward, 46 Harv. J.L. &

Gender 1 (2023).

40

21 U.S.C. § 355-1(f)(2)(C).

13

While Respondents claimed below that restricting access to mifepristone helps

survivors of intimate partner violence,41 the evidence overwhelmingly demonstrates the

opposite: cutting off telehealth access to mifepristone places survivors of intimate partner

violence at much higher risk. Nearly half of women in the United States have been

affected by intimate partner violence, and women of color, women living in rural areas,

women in poverty, and noncitizens are disproportionately impacted.42 Abusers often

exert coercive control over survivors’ reproductive choices, including through birth

control sabotage and forced pregnancies. Research from the Centers for Disease Control

(“CDC”) shows that nearly 10.3 million women have experienced a partner trying to force

pregnancy or refusing to use contraception, and survivors of intimate partner violence

are nearly three times more likely to conceal an abortion from their partners due to safety

concerns.43 For these survivors, the ability to access abortion care discreetly, without an

abuser’s knowledge, is a lifeline.

Telehealth serves that function precisely because it offers survivors privacy,

autonomy, and a means of accessing care outside the surveillance of an abuser.

Restricting telehealth access to mifepristone forces survivors to navigate barriers that

abusers exploit: the need to travel to a clinic, arrange childcare, take time off work, and

explain absences to a controlling partner. Research has found that the privacy afforded

41

See Compl. ¶¶ 150–158, Louisiana v. FDA, No. 6:25-cv-01491 (W.D. La. Oct. 6, 2025), ECF No. 1.

42

M.C. Black et al., National Intimate Partner and Sexual Violence Survey: 2010 Summary Report, Ctr.

for Disease Control & Prevention 48 (2011).

43

Yvonne Lindgren, The Doctor Requirement: Griswold, Privacy, and At-Home Reproductive Care, 32

Const. Comment. 341, 373 (2017).

14

by telehealth may better facilitate patients’ disclosure of coercion, enabling survivors to

speak more openly with providers about their experiences in settings where an abusive

partner is less likely to monitor or control the interaction.44 As advocates have warned,

restricting access to mifepristone limits survivors’ ability to access abortion care, thus

increasing their risk of health complications, violence, and homicide.45 These harms fall

hardest on survivors in marginalized communities who already face the steepest barriers

to in-person care.

Along with the myriad harms discussed above, restricting telehealth access to

mifepristone will disproportionately harm people of color and immigrant communities

who already face greater barriers to accessing healthcare, including abortion. Women of

color account for a majority of those seeking abortion care.46 Factors such as time, travel,

and the general costs associated with accessing abortion care already prohibit many

women of color from accessing mifepristone in a timely manner.47 Telehealth addresses

many of these barriers by eliminating the need for long-distance travel and reducing the

secondary costs—missed wages, childcare, transportation—that fall most heavily on

communities of color.

44

Elizabeth C. Romanis et al., Safeguarding and Teleconsultation for Abortion, 398 Lancet 555, 556 (2021).

45

See Comment of Legal Voice et al. on FDA-2025-P-3287 (Nov. 27, 2025),

https://www.regulations.gov/comment/FDA-2025-P-3287-0068.

46

Jillian McKoy, Travel Times to Abortion Facilities Have Increased Drastically in Post-Roe Era, Bos.

Univ. Sch. of Pub. Health (Nov. 23, 2022).

47

Ushma D. Upadhyay et al., Sociodemographic Characteristics of Women Able to Obtain Medication

Abortion Before and After Ohio’s Law Requiring Use of the Food and Drug Administration Protocol, 2

Health Equity 122 (2018).

15

The same is true for immigrant communities. Immigrants are generally less likely

to drive than their native-born counterparts, making travel to in-person appointments

particularly difficult.48 And telehealth addresses not only logistical barriers but also

linguistic ones: approximately 20% of patients who are asylum applicants do not pursue

medical care due to fear of miscommunication or not understanding their provider.49

Telehealth can help bridge this gap by connecting patients with language-concordant

providers who may not be available in their immediate geographic area. For communities

already navigating the intersection of immigration status, poverty, and limited English

proficiency, telehealth is often the only realistic path to timely reproductive care.

Eliminating it risks leaving these patients with nowhere to turn.

C.

Restricting Abortion Access Worsens Public Health Outcomes.

Telehealth for abortion, like abortion more generally, is essential to public health.

Contrary to Respondents’ claims below that restricting mifepristone access would save

women from harm,50 it is the restriction of abortion access—not its availability—that

endangers patients’ health and lives. Access to safe abortion is a critical component of the

broader healthcare system; curtailing it through telehealth restrictions produces the

very harms Respondents claim to oppose.

48

Alexa Delbosc & Rahman Shafi, What Do We Know About Immigrants’ Travel Behaviour? A Systematic

Literature Review and Proposed Conceptual Framework, 43 Transport Revs. 914 (2023).

49

See Comment of The Boston University School of Law’s Program on Reproductive Justice (BUPRJ),

supra note 34.

50

See Compl. ¶¶ 120–131, Louisiana v. FDA, No. 6:25-cv-01491 (W.D. La. Oct. 6, 2025), ECF No. 1

(asserting quasi-sovereign harms to Louisiana women from mifepristone); Pls.’ Mem. in Supp. of § 705 Stay

at 15, ECF No. 20-26 (arguing that “the public interest is disserved by a drug that does not afford adequate

protections to its users” (quotation marks omitted)).

16

The historical record is unambiguous on this point. The gradual legalization of

abortion in the years leading up to Roe v. Wade reduced maternal mortality among people

of color by 30–40%.51 Research since Dobbs confirms that this pattern is now reversing.

The racial dimensions of these harms are particularly stark. Black women are already

two to four times more likely than white women to experience maternal mortality or

morbidity.52 Abortion bans in thirteen states have also increased infant mortality, with an

estimated 478 additional infant deaths above what would have been expected.53 Research

following Texas’s 2021 abortion ban estimated a 6–13% increase in infant mortality.54

Black infants have been hit hardest, dying at a rate 11% higher than expected following

abortion bans.55 These are not abstract projections. They are documented consequences

of restricting access to care.

Abortion restrictions have also been shown to increase disparities in premature

birth and low birthweight between Black and white infants by 3–6%.56 And state-level

abortion restrictions enacted prior to 2022 were associated with increases in intimate

51

Sherajum Monira Farin et al., The Impact of Legal Abortion on Maternal Mortality, 16 Am. Econ. J.:

Econ. Pol’y 174 (2022), https://www.aeaweb.org/articles?id=10.1257/pol.20220208.

52

Alexis A. Creanga et al., Racial and Ethnic Disparities in Severe Maternal Morbidity: A Multistate

Analysis, 2008–2010, 210 Am. J. Obstetrics & Gynecology 435.e1 (2014).

53

Alison Gemmill et al., US Abortion Bans and Infant Mortality, 333 JAMA 1315 (2025).

54

Alison Gemmill et al., Infant Deaths After Texas’ 2021 Ban on Abortion in Early Pregnancy, 331 JAMA

1609 (2024).

55

Id.

56

Graham Gardner, The Maternal and Infant Health Consequences of Restricted Access to Abortion in the

United States, 98 J. Health Econ. 102938 (2024).

17

partner violence–related homicides of women and girls.57 Restricting telehealth access to

mifepristone compounds each of these outcomes by erecting additional barriers to

reproductive healthcare for communities that already bear the greatest burdens.

Restricting mifepristone access will cause profound harm. Abortion access saves

lives, reduces maternal and infant mortality, narrows racial health disparities, and

protects survivors of violence. Telehealth is the mechanism through which hundreds of

thousands of patients access that care. A stay or vacatur is in the public interest because

the Fifth Circuit’s order will cause the gravest harm to those who can least afford it.

CONCLUSION

For the foregoing reasons, amici respectfully urge this Court to grant the

applications and stay or vacate the Fifth’s Circuit’s decision.

Respectfully submitted,

Jessica Ring Amunson

Counsel of Record

Varsha Midha

JENNER & BLOCK LLP

1099 New York Ave NW, Suite 900

Washington, DC 20001

(202) 639-6023

jamunson@jenner.com

Shoba Pillay

Emily Merrifield

Sara Stappert

JENNER & BLOCK LLP

353 N. Clark Street

Chicago, IL 60654

(312) 222-9350

57

Maeve E. Wallace et al., States’ Abortion Laws Associated with Intimate Partner Violence–Related

Homicide of Women and Girls in the US, 2014–20, 43 Health Aff. 682 (2024).

18

APPENDIX

List of Amici Curiae

10,000 Women Louisiana

2+ Abortions Worldwide

A Woman’s Choice Clinics: Jacksonville, FL; Charlotte, NC; Raleigh, NC; Danville, VA

Abortion Access Front

Abortion Action Missouri

Abortion Care Network

Abortion Coalition for Telemedicine

Abortion Forward (f/k/a Pro-Choice Ohio)

Abortion Freedom Fund

Access Health Center Ltd

ACCESS REPRODUCTIVE JUSTICE

Advocates for Youth

Alamo Women’s Clinic of Albuquerque

Alamo Women’s Clinic of Illinois

All Families Healthcare

Alyssa Rodriguez Center for Gender Justice

American Civil Liberties Union Foundation

American College of Nurse-Midwives, Oregon Affiliate

American Society for Emergency Contraception

Americans United for Separation of Church and State

A1

Ancient Song, Inc.

Avow Texas

AWAKE Tennessee

Blue Mountain Clinic

Bread and Roses/Gainesville Woman Care

Brevard NOW

Bristol Women’s Health Clinic

California Women Lawyers

Cambridge Reproductive Health Consultants

CARE Colorado

Carolina Abortion Fund

CE Repro Fund

Cedar River Clinics

Center for Reproductive Rights

Center for Women’s Health

Chicago Abortion Fund

CHOICES Center for Reproductive Health

Coalition of Labor Union Women, AFL-CIO

Cobalt Advocates

Collective Power for Reproductive Justice

Colorado Organization for Latina Opportunity & Reproductive Rights (COLOR)

Columbia NOW (Columbia, SC)

A2

Desert Star Institute for Family Planning

Desiree Alliance

Doctors for America

El Pueblo

Emergent Transformative Justice

Endora

Equal Rights Advocates

Essential Access Health

Every Mother Counts

Faith Choice Ohio

Faith Roots Reproductive Action

Family Planning Associates Medical Group

FemHealth USA d/b/a carafem

Feminist Center for Reproductive Liberation

FL National Organization for Women

Forward Midwifery

Frontera Fund

Full Circle Health Center

Fund Texas Choice

Gender Justice

Gender Justice League

Greater Orlando National Organization for Women

A3

Greenville Women’s Clinic PA

Guttmacher Institute

Health Imperatives Inc.

Hydra Fund

Ibis Reproductive Health

Idaho Abortion Rights

If/When/How: Lawyering for Reproductive Justice

Indigenous Women Rising

International Action Network for Gender Equality & Law

(IANGEL) International Medical Consulting

Ipas US

Jane’s Due Process

Juniper Midwifery

Just The Pill

JustChoice

Justice and Joy National Collaborative

Lambda Legal Defense and Education Fund, Inc.

Lawyering Project

Legal Momentum, The Women’s Legal Defense and Education Fund

Lift Louisiana

Luna Flow Health

A4

Mabel Wadsworth Center

Maine Family Planning

Metro Area Advanced Practice Healthcare

Michigan Chamber for Reproductive Justice

Michigan Voices

Middle Georgia 4 Choice

Midwest Access Coalition

Miscarriage and Abortion Hotline

MomsRising

My Sunny Health

National Abortion Federation

National Asian Pacific American Women’s Forum

National Family Planning & Reproductive Health Association

National Health Law Program

National Network of Abortion Funds

National Organization for Women Foundation

National Organization for Women, Jacksonville Chapter

National Perinatal Association

National Women’s Law Center

National Women’s Liberation

National Women’s Political Caucus

New York Abortion Access Fund (NYAAF)

A5

New York Midwives

NOISE FOR NOW

North Seattle Progressives (NSP)

Northland Family Planning Centers

Northwest Health Law Advocates

National Association of Nurse Practitioners in Women’s Health (NPWH)

Nurses for Sexual Reproductive Health

Oklahoma Call for Reproductive Justice

Partners in Abortion Care

Pasco County National Organization for Women, Inc.

People For the American Way

People Power United

Physicians for Human Rights

Pinellas County National Organization for Women

Plan C

Planned Parenthood Federation of America

Power to Decide

Pregnancy Justice

Pro-Choice North Carolina

Protect Our Care, a fiscally sponsored project of New Venture Fund Reclaim, Inc.

PUSH for Empowered Pregnancy

Red River Women’s Clinic

A6

REPRO Rising Virginia

Reproaction

Reproductive Equity Now Foundation

Reproductive Freedom for All

Reproductive Freedom Fund of New Hampshire

Reproductive Futures

Reproductive Health Access Project

Rhia Ventures

Robbinsdale Clinic, PA

Rocky Mountain Equality

Roxy Clinic

Service Employees International Union

SHERo Mississippi

SisterLove, Inc.

SisterSong National Women of Color Reproductive Justice Collective

Southwestern Women’s Options

State Innovation Exchange

Stigma Relief Fund

Tennessee Freedom Circle

Texas Equal Access Fund

The Brigid Alliance

The Jane Network

A7

The National Partnership for Women & Families

Truth Pregnancy Resource Center

Ubuntu Black Family Wellness Collective

URGE: Unite for Reproductive & Gender Equality

Virginia Affiliate of the American College of Nurse-Midwives

Wavelength Psychological Services

Whole Woman’s Health

Whole Woman’s Health Alliance

Wild West Access Fund

Women Lawyers On Guard Inc.

Women’s Health Specialists

Women’s Law Project

A8

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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