# Amicus Curiae Brief — Nat'l Inst. of Family & Life Advocates v. Becerra, 138 S. Ct. 464 (2017) (No. 16-1140)

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Amicus Curiae Brief
- **Published:** January 1, 2017

## Text

No. 16-1140

3n the Supreme Court of the Anited States

NATIONAL INSTITUTE OF FAMILY AND
LIFE ADVOCATES, dba NIFLA, et ai.,
Petitioners,
Vv.

XAVIER BECERRA,
Attorney General of California, et ai.,
Respondents.

On Writ of Certiorari to the
United States Court of Appeals for the Ninth Circuit

BRIEF OF 13 WOMEN AND THE CATHOLIC
ASSOCIATION FOUNDATION AS AMICI CURIAE
IN SUPPORT OF PETITIONERS

Andrea Picciotti-Bayer
Counsel of Record

The Catholic Association

Foundation

3220 N Street NW, Suite 126

Washington, DC 20007

(571) 201-6564

amariepicciotti@gmail.com

Counsel for Amici Curiae

Becker Gallagher - Cincinnati, OH - Washington, D.C. - 800.890.5001

TABLE OF CONTENTS

TABLE OF AUTHORITIES ................... ii
INTERESTS OF AMICI ..........---22200ee5> 1
SUMMARY OF ARGUMENT ................. 26
SET <iecoseteseeceeceseroscvevcece 29

I. PREGNANCY RESOURCE CENTERS
AND MEDICAL CLINICS ARE WARM
AND LOVING COMMUNITIES
OFFERING VALUABLE AND INFORMATIVE

Il. | PREGNANCY RESOURCE CENTERS AND
MEDICAL CLINICS PROVIDE
INVALUABLE PERSONAL AND
COMMUNITY SERVICES BEYOND
PREGNANCY COUNSELING .......... 32

Ill. PREGNANCY RESOURCE CENTERS AND
MEDICAL CLINICS SERVE ALL PEOPLE,
FREE OF CHARGE ................++: 35

DE bra decdecccececsccsecccceces 35

ii
TABLE OF AUTHORITIES

CASE

Greater Baltimore Center for Pregnancy Concerns,
Inc. v. Mayor and City Council of Baltimore,

No. 16-2325 (4th Cir. Jan. 5, 2018) .......... 28
Nifla v. Harris, No. 16-55249 (9th Cir. Oct. 14,

ee es os othe Eres Lake deen ewes 26
STATUTES
Baltimore City Council Ordinance 09-252 ....... 28

California’s Reproductive Freedom, Accountability,
Comprehensive Care, and Transparency Act

NSS va desatecunsaecdcsnaseuel 27
Rid Gbsu dW db ad cee eueaeaekeds 27
Lal Gn rend wai aehae ae ane eee ace Oe 27
California Assembly Bill No. 775 ........ 26, 27, 29
EE on vc dan cancceduscvecdos 28
Illinois Health Care Right of Conscience Act,
tne Cuban d<60ows bond diecede 28
OTHER AUTHORITIES
https://ghr.nlm.nih.gov/condition/trisomy-13 .... . 20

https://www.acog.org/~/media/departments/state%
20legislative%20activities/2015AZFactSheetM
edicationAbortionReversalfinal. pdf ......... 22

https://www.cdc.gov/reproductivehealth/data_stat
EE acdc euSeesvbbevadnaecteonss 26

https://www.fda.gov/Drugs/DrugSafety/ucm 11132

BE taaxteshserdenohinesced 606 bina avnte 21
https://www.fns.usda.gov/wic/women-infants-and-
SE bia nd eedne ou tsdeccedecdehases 3

https:/ozierinstitute.org/a-second-chance-at-life-
reversing-the-abortion-pill/ ................ 22

1

INTERESTS OF AMICI’

Amici 13 women, listed and described below,
include direct and indirect beneficiaries of the free
services provided by not-for-profit pregnancy resource
centers and medical clinics in the state of California
and across the United States. They attest to the
dignified care and hope that women and their children
receive at such centers and clinics.

Amici, The Catholic Association Foundation (TCA),
is a lay organization dedicated to being a faithful voice
for the Catholic Church in the public square. Catholics
have played a leading role in founding and running
pregnancy centers across the country. The Catholic
Church in the United States sponsors the Gabriel
Project”, a parish-based ministry that brings hope to
pregnant women in crisis, and Project Rachael’, a
diocesan-based network of specially trained priests,
religious counselors, and laypersons who respond to
and care for those who have procured an abortion.
These ministries work with the centers and clinics in

' All parties received timely notice of the intention to file this
amicus brief and consented to its filing. No counsel for a party
authored this brief in whole or in part. The Catholic Association
Foundation contributed the costs associated with the preparation
and submission of this brief. All statements made by amici 13
women are on file with counsel for amici curiae.

® For information about Gabriel Project, see
http://www.gabrielproject.us/index.htm!

* For information about Project Rachel, see http://www.usccb.org/
issues-and-action/human-life-and-dignity/abortion/project-rachel/
index.cfm and http://hopeafterabortion.com/

2

their communities to offer care and support to women
in need.

Amici strongly oppose any civil sanctions that would
impede the ability of licensed and unlicensed
pregnancy centers in the state of California to provide
free support and services to women and their children.

ANGELA JOZWICKI grew up in a household
“with a lot of screaming” and turned to drugs when she
was fourteen years old. Although she had sporadic
periods when she was “clean,” Angela was unable to
stop using for years. When she was twenty-two years
old, Angela discovered she was pregnant. “I knew in
my heart that a baby would stop me from having drugs,
but I wasn’t ready.” Angela had an abortion. “It was
June 1, 2006. I will never forget that date.” “I used
abortion to avoid getting better.”

Struggling with addiction and other health
concerns, Angela never thought that motherhood was
a possibility. “I was taught that you get married, buy
a house, and you have a baby. Because I did not see
that in my future, I never thought I would have a
baby.” In October 2015, Angela sensed something was
different about her body and bought a pregnancy test
from a dollar store. The test was positive. Because
Angela was still using drugs, she made another
appointment to have another abortion. She asked the
baby’s father to drive her to the clinic when the day for
the appointment came. When Angela called him that
morning, he did not answer his phone. Angela kept
calling, but he never answered or showed up. Angela
believes that “God showed up.” “I decided that I would
keep that baby.”

3

Because of her addiction and the circumstances of
her pregnancy, Angela felt that she could not turn to
her family for support. Angela started “calling a bunch
of numbers of places that help pregnant women.”
Soundview Pregnancy Services in Centereach, New
York, answered her call and encouraged Angela to
come in. At her first visit to the center, staff showed
Angela her growing child on an ultrasound. Every
subsequent week, Angela met with Barbara, a staff
member at the center, and the two watched videos
about pregnancy and childcare and spoke about how
Angela was doing. When it came time for Angela to
deliver, Barbara went to the hospital to be there for
Angela. “I did not think that she would come, but she
was there.”

Staff at the center helped Angela enroll in the
Women, Infant and Children supplemental nutrition
program (WIC)* and get in touch with New York’s
Department of Social Services for financial assistance
during her pregnancy and after childbirth. Angela
plans to begin working again once her son Cameryn is
old enough to start preschool. In the meantime, Angela
and her son are living with Angela’s mother. Though
Angela and her mom have had a strained relationship,
counselors at the center have met with the women and

* The United States Department of Agriculture offers a special
supplemental nutrition program for Women, Infants, and Children
(WIC) that provides federal grants to states for supplemental
foods, health care referrals, and nutrition education for low-income
pregnant, breastfeeding, and non-breastfeeding postpartum
women, and to infants and children up to age five who are found
to be at nutritional risk. See https://www.fns.usda.gov/wic/women-
infants-and-children-wic.

4

slowly helped bring the mother and daughter together
for the sake of a loving and supportive home for
Cameryn.

Angela continues to attend weekly sessions at the
center and benefits from parenting courses and
supportive counsel as she struggles with both single
parenting and staying clean. “I always thought that
people were fake, but they are genuine. This is who
they really are. They will help me to raise my son to be
genuine.” Looking forward to life now, Angela credits
the center with giving her “support so that I don’t turn
back to drugs.”

BRENDA COE and her husband were introduced
by a mutual friend to Krystal, a single mother in a
crisis pregnancy. Krystal already had a two-year-old
son and felt unable to raise another child in her
circumstances. Krystal had visited the Pregnancy Help
Center in Torrance, California, to confirm her
pregnancy, and while there, spoke with counselors
about adoption. After meeting the Coes, Krystal asked
them to adopt her baby.

The center was a resource to Krystal throughout her
pregnancy, and Brenda accompanied Krystal there
regularly. Brenda came with Krystal to ultrasounds
and helped her interview the obstetrician she
eventually selected, who also volunteered at the center.
Brenda and her husband were present at the child’s
birth. Brenda remarks that they were “overjoyed” with
the prospect of “walking with Krystal during her
pregnancy.” The staff at the pregnancy center
supported all of them throughout the pregnancy and
adoption process. Brenda and her husband stay

5

connected to Krystal by exchanging pictures and
speaking over the phone.

Brenda is grateful for the assistance Krystal
received at the center. “I think birth parents should be
encouraged to be the best God wants them to be so that
their adopted children can find them in a strong place.”
In Brenda’s experience, “women are not being forced
into not having an abortion, but are being shown that
they have options and resources to choose life. The
center removes a ‘crisis’ a woman is facing so that they
can make a positive, life-affirming choice.”

BROOKE NORTH found healing at the Hope
Pregnancy Center in Pontiac, Illinois, after decades of
trauma and abuse. At the age of eleven, Brooke was
put into the foster care system following years of
physical abuse by her father. She had been in and out
of several foster homes and endured multiple occasions
of physical, sexual, and emotional abuse during her
childhood. As an adult, Brooke suffered an even more
horrific experience: She was kidnapped and sexually
assaulted over a two-week period until her abductor
was captured and imprisoned.

When Brooke discovered in mid-2015 that she was
pregnant, she enrolled in WIC for assistance. The local
WIC agent referred Brooke to the Hope Pregnancy
Center to “get the stuff you need.” Brooke never
considered an abortion as something she wanted or
needed. “They opened up the center to help moms in
need. They do not pressure you not to get an abortion
if you want one. But t) y are there to help women
have their children.” Brox ce had two great needs when
expecting her first child: someone to listen to her and

6

infant necessities. At the center, both of Brooke’s
needs were met.

Center staff listened and lent a supportive hand. As
part of the center’s “Earn while you Learn” or “Hope
program,” Brooke received “mommy bucks” each time
she attended a counseling session or class. With her
“mommy bucks,” Brooke obtained diapers, wipes,
clothes, and even things for herself during and after
pregnancy. When she needed something but did not
have enough to buy it, she was never denied.

Brooke continued to visit the center after her son
Keetan was born in April 2016. In addition to basic
childcare items, Brooke wanted an ExerSaucer jumper
for her son as he was becoming more mobile. Although
the center did not have one when she inquired, she
received a call shortly afterwards that they had a
brand-new saucer and would hold it for her until she
could arrange to pick it up at the center.

A year later, Brooke met the man who would
become her husband. The couple married in February
2017 and were expecting a child. Brooke returned to
the center, this time with her husband. With the
center’s newly acquired ultrasound machine, Brooke
and her husband were “allowed to see their baby” at
the center. Brooke still has the ultrasound pictures
they received that day.

Becoming a new father was daunting for Brooke's
husband, but center staff encouraged him by pointing
out the “perks” of being a dad. They also explained the
different stages of Brooke’s pregnancy. Brooke notes
that “everything that I was in, he was always offered to
be a part of.” Recognizing Brooke’s husband’s desire to

7

become better informed, staff taught him how to burp
a baby and how to change a baby using a doll. They
provided him with a series of pamphlets entitled
“Beginning of Fatherhood” and encouraged him to join
Brooke in reading the “Pregnancy week by week” book
they had given the couple. After so much preparation,
Brooke remarks of her husvand, “I think that he is a

pro.

Brooke and her husband were nervous about
parenting two children so close together in age.
Christy, a client coach at the time, offered
encouragement. Of Christy’s support, Brooke says,
“She got me in a positive state where I was confident
enough to take care of both of my children.” In October
2017, Brooke had a little girl, Kathy. Not yet two,
Brooke’s son Keetan “is the best big brother ever. It is
all because Christy taught me how to make him a part
of this new baby.”

The center offered so much more than information
about pregnancy and motherhood to Brooke; staff
offered genuine friendship. “When I told them that I
got a job or was expecting another baby, they were
excited.” Brooke says matter-of-factly:

There should be more of them across the
country. There are so many people struggling
and the center is the one place that is the ‘go to’
to guarantee success as a parent. They help
with referrals, vouchers. I would like pregnancy
centers to be all over the place. It is not just for
the parents, but the kids. The people who
donate their time and money help not just
women but their children. The people at the

8

center are the sweetest, most caring, full-of-
energy people.

Brooke credits the Hope Pregnancy Center in Pontiac,
[liinois, for helping her to overcome her traumatic

childhood and to grow as a strong woman, wife, and
mother.

CRISTINA HURTADO was a teenager who
could not afford a pregnancy test when she found the
Care Pregnancy Resource Center in Visalia, California,
nine years ago. She was relieved to find a place that
offered free and confidential tests as she was afraid to
take one by herself. As she waited, a staff member at
the center sat with Cristina, and the two discussed
what Cristina would do if the test were positive.
Cristina was nervous, but having someone by her side
helped. The test was negative, but Cristina continued
to visit the center for its other programs.

Years later, when Cristina discovered that she was
pregnant, she was not as scared. She knew that the
center would be there for her and that she could “take
advantage of their support.” Cristina took parenting
classes at the center and received individual counseling
on preparing for motherhood with Vera, one of the
center’s staff. “Vera was always friendly to me. I knew
that she would not judge me and I felt comfortable with
her. The pregnancy and parenting classes helped
answer all of my questions.”

When it was time for her baby to be born, Cristina
asked Vera to accompany her during labor. It was a
natural thing to have Vera there along with Cristina’s
godmother and the baby’s father. Vera was family.
The center also made things easier by providing

9

Cristina with a diaper bag, diapers, wipes, shampoo,
formula, and strollers. “Pretty much everything that I
did not have access to I got from them.” Staff at the
center and even other clients provided “so much
information” to Cristina about her pregnancy and her
baby’s development. Cristina credits these connections
with helping her “to be a good mother.”

Cristina recently saw a friend at the center who was
pregnant and considering having an abortion. “I knew
she was in great hands.” After learning about the
resources available throughout her pregnancy and
beyond, Cristina’s friend decided against the abortion.
According to Cristina, “the more [my friend] learned
and became educated, the more she was committed to
having her child.”

Cristina credits the center with having an
incredibly positive presence in her life. “I think that if
I would not have found the center, my life would have
been a disaster. I came to the center looking for a
pregnancy test and I found so much more. If you look
at who I was when I first went to the center and now,
I am a totally different person.”

EBONY HARRIS was a bright and vivacious 26-
year-old when she suddenly faced the most troubling
and confusing news of her life: She was unexpectedly
pregnant. Gripped by anxiety and uncertainty, Ebony
resolved that her own future well-being mandated
quick and decisive action. She would have an abortion;
nobody had to know. Ebony scheduled the abortion at
a clinic but left with an uneasy feeling. The clinic’s
staff was cold and harsh, offering no counsel and no
information about the procedure apart from its price —
just pressure. One staff member told Ebony, “The cost

10

of raising the child will be far more expensive than the
cost of an abortion.” Ebony did not meet with a doctor
or nurse and was not informed of any other option.

After hearing about the Greater Baltimore Center
for Pregnancy Concerns through the radio, Ebony met
with Linda, one of its coordinators. Ebony was
surprised when the first thing Linda did was hug her.
This was the first time anyone had shown Ebony any
compassion or support while she faced this situation.
Linda advised Ebony that the center did not perform or
refer for abortions, but offered many other services, all
free of charge, including sonograms, pregnancy tests,
prenatal classes, post-natal classes, and material
support such as diapers, formula, clothes, and toys.
According to Ebony, “Linda was warm, gentle, and
supportive.” Ebony was also surprised to see jars of
baby food, diapers, and baby formula sitting on a table.
Ebony requested a sonogram, saw and heard her child’s
heartbeat for the first time, and received information
about the development of her child. Ebony referred to
this meeting as:

... educational and very informative, something
the clinic did not do. I am not pro-life and I am
not pro-choice. I am pro-information. People
should be properly educated before making a
decision. The abortion clinic did not offer any
education, counseling, or support. The clinic had
a cold attitude. It felt like someone was trying
to make a sale.

After Ebony left the center, she still leaned toward
having an abortion. Linda unequivocally stated that
“either way, the center will be there for her.” After
much deliberation, Ebony decided to give birth to her

11

son, and Linda kept her promise. Center staff visited
Ebony at her house and brought baby clothes, diapers,
wipes, food, toys, and even a stroller. The staff helped
her beyond merely caring for her baby. When Ebony
had to move to a new apartment, she had no curtains,
and even if she could have afforded them, she “would
not have been able to hang them herself.” Staff took
Ebony to the store, bought her the curtains, carried a
ladder up three flights of steps, and installed them for
her.

Ebony spoke in no uncertain terms: “[The center]
has only been a help to me. I have taken and referred
other people, and they have been helped too. [The
center] has been a blessing.” Today, Ebony flourishes
not just as a mother, but as an author, speaker,
workshop instructor, home educator, and publisher.
She credits the center with giving her an authentic and
informed choice during a desperate moment in her life
and for helping her to grow into an accomplished and
empowered woman.

JUDITH DOWNES is a 70-year-old woman and a
committed pro-lifer. Since 1984, Judith has
volunteered at Alternatives Pregnancy Center in
Denver, Colorado. The center took on a more profound
role in Judith’s life five years ago when she began post-
abortion counseling for an abortion she had undergone
over 40 years earlier.

Judith was living in Virginia in the mid-1970s and
thought her life was perfect: She had been married for
six and a half years and had a beautiful two-and-a-half-
year-old. She anxiously anticipated welcoming another
child to the family. But one day, Judith’s husband
came home from a business trip and told her that he

12

did not want to be married anymore. Judith was
eleven weeks pregnant. “As far as I knew at that time,
there was no one I could consult with on how I should
make a decision.” Concerned about being a single
mother with “no safety net” and “no one to turn to,”
Judith called her doctor’s office. The office offered
Judith no information about her options or the support
available to her during her pregnancy or as a single
mother. They simply referred Judith to a nearby
abortion clinic. Judith felt confused and hopeless, and
pressured by her husband, who brought her to the
abortion clinic. Judith recounts that after her abortion
she was left with “confusion” and “crippling shame and
grief” that affected every area of her life.

Motivated by her own horrible experience with
abortion, Judith got involved with Alternatives as a
volunteer. But she didn’t realize how much she still
suffered from her own abortion. Despite having seen
counselors and psychologists throughout her adult life,
it was not until she met with her friend Maureen,
executive director at Alternatives, that Judith saw the
role her abortion had played in her life. “I still recall
when Maureen said so simply, ‘Judy, abortion is rc ally
hard on women.”

At Maureen’s suggestion, Judith set up an
appointment to meet with Nicole, the post-abortion
counselor at the center. At first, Judith was doubtful.
“I was very put off because she was so young. I needed
someone who was an expert.” But as the two spoke,
Judith found Nicole to be “the kindest, most patient
person in my life.” Judith and Nicole met individually
for an hour every week for many months. Through
counsel with Nicole, Judith finally began to “connect

13

the dots.” “I suffered with abusive relationships as a

form of punishing myself, thinking that it was
something I deserved for having aborted that child.”

Trained now as a post-abortion group leader, Judith
has led groups of women of all ages, including specific
groups of women between the ages of 55 and 65 who
have procured abortions. During the 13-week long
sessions, Judith has seen women “come in struggling,
broken and confused and then move into freedom,
acceptance and peace.” Women are able to “share with
each other, hear each other’s stories, cry with each
other and be there for each other.” Judith feels very
strongly that “I would not have been able to come to
this level of healing without Alternatives. Alternatives
is motivated toward good and healing, based in love
and concern.” Judith would love to “shout from the
rooftops” that there are places for women who have
chosen an abortion to go to in order to confront their
grief and “come out of the darkness.”

LAURA WU thought she had met her soul mate.
While working as a full-time teacher and studying at
night for a master’s degree, Laura and her boyfriend
spoke about marriage and the names of their future
children. But when Laura told her boyfriend that she
was pregnant, he was angry. “He told me, ‘It is either
me or this child. If you chose this child, you will do it
alone. You won’t have your parents to support you.
What kind of mother would you be to bring a child into
this world if his father did not want him?” Laura
initially agreed to abort their child, but quickly
changed her mind. An aunt of Laura’s volunteered at
Boro Pregnancy Crisis Center in Queens, New York,
and encouraged Laura to call for an appointment.

14

At Laura’s initial appointment, she went through
the center’s “options counseling” where Laura received
information about adoption, abortion education, and
single parenthood. Laura chose to continue with her
pregnancy.

Although staff at the center told her about
assistance through WIC, Laura was deemed ineligible
because of her teaching salary. The expense of
welcoming her daughter, however, was significant. For
each appointment Laura attended at the center, she
was awarded “points” which she could trade in for
material help such as a bassinet or a car seat. “For me
that was hope. Just knowing that they were there if I
needed them was a big, big help.”

Laura’s parents and faith community offered great
support during the pregnancy. Another important
presence in her life was Vince, a New York Police
Department officer and Laura’s high school sweetheart.
After Laura’s baby Hannah was born, Laura and Vince
got married. Two years later, Vince formally adopted
Hannah. The center continued to play a significant
role in Laura’s life, helping her grieve the end of her
relationship with her daughter’s father, the death of
Laura’s own father, and the challenges of marriage and
parenting. “All of my healing, just feeling that I could
do this is because of [the center]. Had they referred me
to an abortion clinic, I don’t know how I would have
reacted. [They] gave me the hope I needed to know
that I could do this alone. And they did not make me
feel alone. Instead they gave me counsel for four years
at no cost.”

When her family moved from Queens to Long
Island, Laura visited a local church that was running

15

a “diaper drive” for a local pregnancy resource center
that was opening. Laura contacted the center’s
executive director to inquire about volunteering. Laura
was “hired on the spot” to be a receptionist at
Soundview Pregnancy Services and later was trained
as a counselor.

“I was initially intimidated in sharing my story.”
Undaunted, she has been the first point of contact for
women who call the center concerned about whether
they can handle the responsibility of motherhood. “It
helps to see someone who has had the same experience
and connection there from the beginning. It is such a
blessing to give back.” Laura also gives talks to youth
groups and local colleges about boundaries in dating
and to “let them know that there is someplace other
than Planned Parenthood that is there to help.”

LINDSEY SAMELSON was pursuing a successful
career in real estate and home construction when she
discovered she was pregnant. A relationship with a
tattoo-covered welder whom she met and supervised on
worksites was certainly unexpected. Despite his
checkered past, Lindsey was drawn to the love and
affection he showed his nieces and nephews and
dreamed of parenting with him.

Lindsey was excited at the pregnancy, but also
scared. How was she was going to tell her parents?
Before she did so, Lindsey wanted to confirm her
pregnancy in a medical setting. Unsure about whether
her health insurance would cover the cost of an early
stage ultrasound, Lindsey googled “free ultrasounds.”
The search turned up a pregnancy resource center in
town.

16

The baby’s father accompanied Lindsey to the
appointment, where he was made to feel welcome. “It
didn’t have that sterile hospital feel. It was warm,
inviting.” A receptionist handed Lindsey an intake
form with questions about the pregnancy. Filling out
the questionnaire, Lindsey “never felt pressured. It
never felt like they were invading.” After Lindsey’s
pregnancy was confirmed, she was given a “goodie bag”
with prenatal vitamins and a folder of information

about pregnancy.

Lindsey had a baby girl. The couple eventually wed
and shortly thereafter learned that they were expecting
another child. The joy of a second baby was magnified
by the couple’s reconciliation with Lindsey’s parents.
They are now expecting their third.

For her second pregnancy, Lindsey chose a midwife
who performed routine ultrasound exams only after 12
weeks of gestation. Anxious to know that her baby was
developing well, Lindsey again set up an appointment
for a free ultrasound. She and her husband went
together to the Colorado Springs Pregnancy Center for
the exam.

Staff stayed in touch and called her shortly after
she gave birth both times to make sure that Lindsey
had all she needed. Lindsey observes, “The centers are
trying to create a space that is joyful for what is a crisis
for so many people. It did not feel sterile. The people
there were happy to see my baby. They did not treat
me like I was a burden. They truly and deeply cared
that we were there.”

Lindsey’s career in real estate and construction is
flourishing. She is currently seeking out opportunities

17

to volunteer in pro-life causes, citing her positive
experience with the pregnancy centers as an impetus.

MELISSA LEACH walked into Hope Pregnancy
Center in Pontiac, Illinois, to confirm a suspected
pregnancy. Sure enough, Melissa was pregnant. The
real surprise was that she was nineteen weeks along.
The advanced stage of the pregnancy, plus the fact that
Melissa was an older mother at thirty-five, made her
visit to the center critically timely. While Melissa’s
doctor performed a range of tests to confirm her
pregnancy was advancing well, the center offered a
network of support.

Melissa never considered terminating her
pregnancy, but did have serious financial concerns.
Jayna Vromen, program coordinator at the center,
offered suggestions and resources to address these
worries during Melissa’s very first visit to the center.
Melissa also began parenting classes where she
discussed parenting her new baby as well as her two
older, out-of-state children.

Only nine weeks after her first visit to the center,
Melissa went into labor, just short of twenty-nine
weeks pregnant. She gave birth by an emergency c-
section. Her son was immediately transferred to a
nearby hospital’s neonatal intensive care unit, while
Melissa tried to recover quickly. Melissa returned to
the center a few days after her son’s birth for a
previously scheduled appointment with the news of her
son’s premature birth. Jayna and Sarah Brummitt,
the center’s director, immediately went to work. They
loaded a diaper bag with preemie clothes, diapers,
wipes, and sensitive-skin laundry detergent. Sarah
filled Mellissa’s gas tank so that Mellissa would not

18

have to worry about the cost of driving back and forth
to the hospital to see her son.

Since his birth, Melissa’s son has undergone several
surgeries and is steadily growing. His doctors believe
that he will soon be ready to go home. Meiissa has
already set up a “pack and play” crib she got using her
credits from “Earn while you Learn” classes from the
Hope Program at the center. The only thing she lacks
is a car seat. Although the center did not have one
available when Melissa last stopped by, Sarah said
“she would put the word out to get one.” Melissa is
confident that Sarah will follow through; “I believe
that she will because she has always kept her word.”

More valuable than the classes and material items
Melissa has received from the center is the friendship
and family she has found. “It never felt like they were
put out. I don’t feel like they gave me special
treatment. I feel like every woman who walks through
those doors gets the same treatment — open, loving,
very warm — especially if you don’t have any other
supports. You just have to be willing to walk through
those doors.”

NICOLE HOWARD’s pregnancy was acrisis. She
had four teenage children and was uninsured. Nicole
and her husband were not seeking an abortion, but
faced high medical costs if Nicole proceeded with the
pregnancy and even greater expenses after the baby’s
birth. Terrified at that prospect, Nicole recalled,
“Everyone knows where to get an abortion. Not
everyone knows where to get help with being a
mother.” A friend referred her to the Greater
Baltimore Center for Pregnancy Concerns, where

19

Nicole participated in “Earn as you Learn” classes
every other Saturday. Nicole asserted:

I could not have done it without them. It had
been such a long time since I had a newborn. |
could go and earn points by taking classes to get
wipes, diapers, clothing, lotions . . . I really
depended on those items. I could get them every
other Saturday. Otherwise, the center does give
them away for free every quarter, but I could not
wait that long.

Some of the other classes Nicole attended were
“Common Care for Infants,” “Emotionally Safe Houses
for Children,” “Advanced Care for Toddlers,” and “Safe
Sleeping.” Nicole still attends classes every other
Saturday and has referred others who have also

benefitted from them.

Nicole recalled one winter when she ran out of
diapers and a snowstorm trapped her at home. She
called the center, and staff arranged for diapers to be
delivered to her. She states:

The center is not only instrumental in giving
items to support kids, but it supports
comradeship. It is a family. Even when women
come and go, the center still reaches out to them.
We have parties at the center, bring food, bring
our children. We get to see each other’s children
grow up. It also gives our children the
opportunity to participate in community service.
They can volunteer and give back.

SHALANE TEHOTU and her husband discovered

during their second ultrasound that they were
expecting a boy. But their excitement was

20

overshadowed by the worried look on the doctor’s face.
He said he had found some abnormalities and ordered
further studies. Their boy was later diagnosed with
Trisomy 13.° Doctors encouraged Shalane and her
husband to abort.

The couple contacted A Place for Women in Waipio
on the island of Oahu, Hawaii. They immediately
found counsel and support for their decision to carry
their child to term. Dr. Vivien, the center’s doctor,
helped them to understand their son’s medical report,
comforted them with her counsel, and took the time to
answer all of their questions. The center also
introduced them to a family that had gone through the
same thing with their baby girl.

Shalane’s son, Giovanni, lived for three hours. He
was “surrounded by family and friends celebrating him
with pictures, hugs, gifts, and love.” Giovanni's
parents have no regrets that his life was so short. “We
have only special memories we will hold in our hearts
until we see him again. We went into A Place for
Women broken and scared, but we left with life and
courage and we are forever thankful.”

SHANELLE FELDER knew how her baby’s father
“would react and how he would want to handle it”
before she even told him the news. He told Shanelle,

° Trisomy 13, also called Patau syndrome, is “a chromosomal
condition associated with severe intellectual disability and
physical abnormalities in many parts of the body . . . Due to the
presence of several life-threatening medical problems, many
infants with Trisomy 13 die within their first days or weeks of life.
Only five percent to ten percent of children with this condition live
past their first year.” https://ghr.nlm.nih.gov/condition/triso™ v-13

21

“We are going to take the abortion pill.” Shanelle did
not even know that there was such a thing as a medical
abortion.® Despite Shanelle’s very strong Christian
beliefs and opposition to abortion, she felt pressured to
go along. Shanelle thought she had no other option.

The baby’s father brought Shanelle to a Planned
Parenthood clinic in Denver to get the abortion pill.
For Shanelle, that day was “really scary and hurtful.”
After they performed an ultrasound to determine the
gestational age, Shanelle brought the pictures to the
baby’s father in the waiting room. She hoped that he
would be moved to reconsider. He was not. Planned
Parenthood staff led Shanelle to another consultation
room. Shanelle tried to tell the staff person that she
was having doubts, “but things just kept progressing.”
She remembers “how quick it went with the doctor”
when he handed her the pills. He ordered her to take
them in front of him. “I had no chance to plead with
him.” Feeling pressured, Shanelle “was looking for any
way out, but [was] unable to stand up for myself.” She
took the pills and “felt doomed.”

In a recovery room, Shanelle was given more pills to
take the next day. As she left the Planned Parenthood
clinic, Shanelle remembers “feeling super
uncomfortable” and “hard on myself” for letting
someone else dictate her actions. As Shanelle
struggled later that day with what to do next, a friend

* The FDA currently approves a regimen for chemical abortions
through 70 days gestation. The regimen involves the pregnant
woman taking 200 mg of mifeprex and 800 mcg of misoprostol 24
to 48 hours later. See https://www.fda.gov/Drugs/DrugSafety/ucm
111323.htm

22

called her out of the blue. Shanelle confided in her
friend what had happened and her overwhelming
feeling of helplessness and despair. Her friend sent
Shanelle a link that identified doctors who could
reverse the effects of the abortion pill.’ Shanelle was
astounded. The staff at Planned Parenthood had
presented the abortion pill as something permanent.

Inspired by this “second chance,” Shanelle called a
nurse in the area who set up an appointment with a
local doctor later that evening. The doctor gave
Shanelle progesterone injections as part of the reversal
procedure.” When Shanelle returned for a second
injection, she brought the bag of pills given to her in
the Planned Parenthood recovery room. This doctor
then referred Shanelle to Alternatives Pregnancy
Center in Denver, Colorado, to schedule an ultrasound.
Shanelle anxiously called the center to set up the
ultrasound appointment. “I had to see if my baby was
still alive.” She expected to be called in just for an
ultrasound exam, but received “much mere than I could
ever ask for.” As she waited for her ultrasound,
Shanelle was able to talk and pray with «ater staff.

’ A 24-hour nurse hotline for referrals to physicians specializing in
abortion pill reversal is promoted on www.abortionpillreversal.com

* The American Congress of Obstetricians and Gynecologists has
no guidelines for the use of progesterone injections to reverse the
effects of mifeprex, citing the absence of a “body of scientific
evidence,” see https://www.acog.org/~/media/departments/state®
20legislative%20activities/20 15AZF actSheet MedicationAbortion
Reversalfinal.pdf. But a growing number of doctors have adopted
a medical protocol for reversal established by Abortion Pill
Reversal (APR). See e.g., https://lozierinstitute.org/a-second-
chance-at-life-reversing-the-abortion-pill/

23

Shanelle described Whitney, the first Alternatives staff
member she met:

. . . 80 warm, loving and embracing and was
there for me emotionally. She cared enough to
cry for me and with me. She was there and
talked me through the details of what to do next.
She spoke to me about how I felt about the
pregnancy. I was on the fence about things.
How would I tell [the baby’s father] about
reversing things? I know we prayed. She asked
if I wanted her to be there with me during the
ultrasound. I felt that she was my only friend at
the time.

Upon seeing her daughter's heartbeat on the
ultrasound screen, Shanelle recalls the sensation of
“knowing wha: love is,” and the “euphoria of knowing
that my child is still alive.” Although she was still
anxious, it was “amazing to see this baby that still
survived.”

In subsequent visits to the center, Whitney helped
Shanelle garner the courage to tell her parents that she
was pregnant. After sharing the news with them,
Shanelle “knew that it was ok because it was less of a
secret.” Shanelle eventually moved from Denver to live
with her parents in Florida. Despite having the
support of her parents, Shanelle was depressed that
her pregnancy was not under more joyful
circumstances. Consolation came in the mail.

Because I was not able to have a baby shower in
Denver, [the center] sent me a box with a ‘baby
shower inside. I was really depressed, but it
touched me. The box had toys, a book, and a

24

very nice quilt that we still have to this day —
the most thoughtful thing ever — cute burp
cloths, and diaper cream. I was overjoyed to get
a box.

“My case is a little different in that I did not want an
abortion. I was running from an abortion, trying to get
away from it.” The support Shanelle found at the
center gave her the confidence to see that “all of these
fears looming over me were all lies.”

Two years after her daughter Lillian was born,
Shanelle returned the Denver area. One of their first
outings was to visit the center.

STEPHANIE KAMANAWA remembers “feeling so
offended” as the pastor spoke about abortion healing
while she sat as a fairly new member of his church in
Oahu, Hawaii. “How dare he talk about that in
church.” When the sermon was over, however, she
walked right up to the pastor’s wife and confessed: “I
have had two abortions.”

Stephanie’s first abortion occurred in 1996 when
she was only twenty-one years old, living in Maryland.
Stephanie was in an abusive marriage. “There was no
way that I could support a baby in an abusive
marriage. I did not know that keeping my baby at the
time was an option. I was trying to solve a problem,
but it made more problems. The depth of pain was so
deep that I did not have hope. I had no support.” In
2001, only five years later, Stephanie again turned to
abortion as she discovered she was expecting a baby
from a short-lived relationship.

25

Although now a mother to a beautiful son and
married to a loving man, Stephanie continued to feel
guilt and emptiness. The pastor’s wife referred
Stephanie to A Place for Women in Waipio on the
island of Oahu, Hawaii. When Stephanie walked into
the center, she was taken aback. “It rocked my world
that there were people who would not judge me.”
“Confidential, safe, beautiful, and friendly,” the center
offered Stephanie, through post-abortion healing
sessions, a chance to start anew. “I love to sing and
worship God through song. A Place for Women gave
me a new voice. After the abortions, I lacked hope to
sing.”

Today, Stephanie has rediscovered her singing voice
and speaks with other women about her abortion
“freely, with no shame, no guilt, and no heaviness
hanging over me.” In the center, Stephanie found
incredible support and was able to confront her prior
decisions.

My own personal experience is that they are the
real deal. Every step along the way. The
women who work there have strong bonds and
run with integrity, honesty, love, nurturing, and
care. They make sure that there is a comfortable
setting. They are confidential and upfront with
women who are there. They feel so strongly
about telling the truth. It is such a raw and real
experience for me. People can always come
against them and lie, but I want people to know
that the center wants to help, not to hurt.

Stephanie has also connected with her community.
Initially, she volunteered at the center, cleaning it once
a week. She now works as a youth group director in

26

her church. “As director of our youth group, I adopted
fifty kids to replace the two that I lost.”

SUMMARY OF ARGUMENT

Americans respond generously and without fanfare
to their neighbors’ sudden needs and crises. One
crisis that exists each day across the country is the
challenge of an unexpected pregnancy. The solution
most commonly offered is abortion.’ While abortion is
sold as a quick and easy fix, for many women, it is not
the solution they seek. What they want instead is to
welcome their child into the world.

Responding to the desire of these women, countless
volunteers come to the rescue. Staffed predominantly
by women, over two thousand pregnancy resource
centers and pregnency medical clinics across the
United States offer alternatives to abortion and post-
abortion counseling.”’ In the state of California alone,
there are an estimated two hundred such centers and
clinics.’ These centers and clinics offer free services
such as pregnancy testing, classes in prenatal
development, assistance in enrolling in WIC, Medicaid
for pregnancy and delivery care, parenting and spousal

* 652,639 legal, induced abortions were reported in 2014 to the
Center for Disease Control from its 49 reporting areas. The
abortion rate for that year was 12.1 abortions per 1,000 women
aged 15-44 years. See https://www.cdc.gov/reproductivehealth/da
ta_stats/abortion.htm.

'° See http://studentsforlife.org/prolifefacts/cpes/.
" Nifla v. Harris, No. 16-55249 (9th Cir. Oct. 14, 2016), Slip op. at

7 (citing Assem. Comm. on Health, Analysis of Assembly Bill No.
775 at 3).

27

classes, and training in basic skills in addition to free
essentials like diapers, baby food, formula, and
strollers. Radiologists provide ultrasounds, free of
cost. Women are offered an authentic choice and the
chance to flourish and thrive as mothers, despite their
circumstances.

Rather than supporting and promoting these
“neighbor-helping-neighbor” efforts, the state of
California has enacted a law that purposefully targets
pregnancy centers with burdensome requirements that
go directly against their mission. California’s
Reproductive Freedom, Accountability, Comprehensive
Care, and Transparency Act (the FACT Act)”
requires a pregnancy medical clinic qualifying as a
“licensed covered facility” to hand out a notice that
immediate and free or low-cost abortions are available
through public programs. Id § 123472(a)(1). The
FACT Act also obliges pregnancy resource centers not
meeting this definition to notify women that they are
not “licensed as a medical facility by the State of
California” and that they have “no licensed medical
provider who provides or directly supervises the
provision of services.” Id. § 123472(b). Refusal to
comply with these requirements subjects centers and
clinics to civil penalties. Id. § 123473.

California’s FACT Act is just one example of a
troubling trend of states and cities attacking pregnancy
resource centers and medical clinics. The state of
Hawaii, for example, recently passed a law requiring
medical and nonmedical pregnancy centers to post a
disclaimer that Hawaii has free or low-cost “family

" See California Assembly Bill No. 775

28

planning” programs, including abortion.'* Under this
new law, centers in Hawaii must, at a minimum, notify
women who enter their centers of these programs and
direct them to the state’s website for more information.
In Illinois, doctors and nurses working at pregnancy
centers are required to promote abortion to their
pregnant patients.'* And the city of Baltimore adopted
an ordinance that requires pregnancy centers to post
signs stating they do not perform abortions.”’ All of
these laws are or have been subject to scrutiny in
federal courts.”®

Amici 13 women have voluntarily come forward to
publicly share a delicate and private part of their lives
regarding the real and lasting support that pregnancy
resource centers and medical clinics throughout the
country offer women and their families. Amici feel as
though these centers and clinics are important places
that offer women the chance to make an informed
choice and improve the circumstances of their lives and
the lives of their children.

“ See Hawaii Senate Bill 501 of the 2017 Hawaii legislative
session.

“ See Illinois Health Care Right of Conscience Act, 745 ILCS 70.
° See Baltimore City Council Ordinance 09-252.

© The Fourth Circuit recently struck down the Baltimore
ordinance as violating the First Amendment. See Greater

Baltimore Center for Pregnancy Concerns, Inc. v. Mayor and City
Council of Baltimore, No. 16-2325 (4th Cir. Jan. 5, 2018).

29

ARGUMENT

1. PREGNANCY RESOURCE CENTERS AND
MEDICAL CLINICS ARE WARM AND
LOVING COMMUNITIES OFFERING
VALUABLE AND INFORMATIVE CARE

Amici wish to come ‘vrward in response to
allegations by the state of California that pregnancy
resource centers and medical clinics employ
“intentionally deceptive advertising and counseling
practices [that] often confuse, misinform, and even
intimidate women from making fully-informed, time-
sensitive decisions about critical health care.”"’
Contrary to the state’s unsupported allegations, amici
experienced valuable and informative care.

Amicus Angela Jozwicki abandoned a life of
dependence on drugs after she chose to become a
mother. The constant presence of staff at a center in
Centereach, New York, strengthens Angela’s resolve in
ways that she was not able to do on her own.

Amicus Brooke North and her husband were able to
see their child for the first time thanks to an
ultrasound administered at a center in Illinois. Both
young parents received tools to grow as a couple during
Brooke’s pregnancy and to prepare themselves for
welcoming another child into their home.

Amicus Cristina Hurtado received support and
counsel at a pregnancy resource center in California
that included “so much information” that she was able

" See Assem. Comm. on Health, Analysis of Assembly Bill No. 775
at 3.

30

to “answer all of her questions.” She would be
“speechless” in response to any claim that centers like
the one she attends are “deceptive” and has “never
heard anyone say anything negative” about their
experiences there.

Amicus Ebony Harris found the center she
encountered in Baltimore, Maryland, to be “educational
and very informative.” In contrast, the abortion clinic
she visited first “did not offer any education,
counseling, or support.” Ebony never felt misinformed
or intimidated as the center was clear with Ebony that
it did not perform or refer for abortions, though it
offered many other services. Even when Ebony was
strongly considering an abortion, the center coordinator
unequivocally stated that the center would be there for
her regardless of her decision.

Amicus Judith Downes, through post-abortion
counseling, “connected the dots” between her abortion
forty years prior to her tendency to seek abusive
relationships. No longer punishing herself, Judith
confidently helps other older women who struggle with
similar difficulties years after having an abortion.

Amicus Laura Wu participated in “options
counseling” at a center in Queens, New York, where
she was informed about the choices available to
pregnant women. Unlike the pressure to abort from
her baby’s father, Laura’s decision to continue her
pregnancy after visiting the center was fully informed
and freely made.

Amicus Lindsey Samelson confirmed two
pregnancies with free ultrasounds offered at centers in
Colorado Springs, Colorado. Although she was

31

anxious, the centers gave her a strong start to her
pregnancies and the confidence to balance motherhood
and her professional goals.

Amicus Melissa Leach was able to confirm her
advanced pregnancy and receive all of the support she
needed in facing the challenges of having a premature
baby. When asked to respond to the charge that
pregnancy resource centers are deceptive, Melissa
flatly retorted that such a claim is “bogus.”

Amicus Nicole Howard similarly found her classes
at the center in Baltimore extremely informative.
Nicole asserts of her pregnancy and motherhood that
she “could not have done it without them.”

Amicus Shalane Tehotu and her husband were full
of anxiety and questions about trisomy 13, the malady
afflicting their developing child. When doctors
pressured them to abort, the pregnancy resource center
in Oahu patiently answered all their questions,
provided emotional support, and introduced the couple
to another family who had first-hand experience with
a pregnancy like theirs.

Amicus Shanelle Felder thought that a chemical
abortion could not be reversed once initiated. The
Planned Parenthood that gave her the abortion pills
failed to provide her with the complete medical picture.
At acenter in Denver, Shanelle’s ultrasound confirmed
the success of having progesterone injections to reverse
the chemical abortion shortly after taking mifeprex at
the Planned Parenthood clinic. Shanelle later
benefitted from the emotional support she received at
the center as staff helped her to abandon her fears and
courageously assume maternity.

32

Because of her abortions, amicus Stephanie
Kamanawa felt “disconnected.” Through the post-
abortion classes offered at the pregnancy resource
center in Oahu, Hawaii, Stephanie learned how “to
nurture” and “become a better wife and mother” as well
as to reconnect with her artistic passion as a singer.

II. PREGNANCY RESOURCE CENTERS AND
MEDICAL CLINICS PROVIDE
INVALUABLE PERSONAL AND
COMMUNITY SERVICES BEYOND
PREGNANCY COUNSELING

Pregnancy resource centers and medical clinics in
California and throughout the country provide
invaluable supports and services beyond pregnancy
counseling to women. These life-affirming supports
enable women to recognize their worth and dignity as
well as empower them to make significant
contributions to their communities.

Amicus Angela Jozwicki was able to reestablish a
relationship and home with her mother after both
women received counseling at the center in Centereach,
New York. They both now provide love and support for
Angela’s child, Cameryn.

Amicus Brenda Coe and her husband welcomed a
child into their home after his birth mother received
adoption counseling at a pregnancy resource center in
California. The birth mother of their child maintains
contact with her son. Her and the Coe family’s special
connection is testament to the generosity of both
biological and adoptive parents for the well being of
adopted children.

33

Amicus Brooke North received needed items from a
center in Illinois such as diapers and wipes for her
newborns using her “mommy bucks.” The center even
found an ExerSaucer jumper for her baby. In addition
to these tangible supports, center staff gave friendship
and genuine support. Brooke is so grateful, she has
encouraged other friends to seek the center’s help and
the staff's kindness.

Amicus Ebony Harris describes how volunteers from
the center in Baltimore brought baby clothes, diapers,
wipes, food, toys, and a stroller to her house. Staff
even bought her curtains and installed them for her
when she was forced to move to a new apartment.

Amicus Judith Downes received post-abortion
counseling and support at a center in the Denver area.
Judith, along with other women, were able to meet in
a group where they could “share,” “hear,” and “cry”
with one another. Judith credits the center with
helping her “get out of the darkness” she experienced
as a result of having had an abortion decades ago.

For amicus Laura Wu, the decision to reject having
an abortion was life-altering, “like a domino effect.”
Laura reconnected with a loving and supportive man
who has since become her spouse and adopted her
daughter. “If I had chosen an abortion, I know that I
would have been a shell of a person today. I don’t think
I would ever been able to forgive myself had I given
[my daughter’s father] what he wanted.”

Amicus Melissa Leach received parenting courses
and counseling not just to help her with her developing
baby, but also to help her better parent her older
children. Center staff are providing emotional and

34

financial assistance to Melissa as she attends to the
medical needs of her son who is hospitalized for being
born prematurely.

Amicus Nicole Howard experienced material
support from the center in Baltimore including mid-
snowstorm diaper delivery, post-pregnancy education,
and much needed “comradeship” in the early, hard
days. She recalls attending parties at the center,
bringing food, celebrating, and getting to see her fellow
beneficiaries’ children grow up. Nicole and her
children now participate as volunteers with the center
and find joy in serving their local community.

Amicus Shalane Tehotu and her husband celebrated
the birth of their son and his short life alongside family
and friends thanks to the encouragement they received
at a center in Oahu, Hawaii.

Amicus Shanelle Felder not only received a “baby
shower in the mail” from the staff at the center in
Denver, but the encouragement she needed to reach
out to others for help and support so that she “could
stand up for myself.” Whitney, a center staff member,
continues to provide support and counsel to Shanelle as
she co-parents with her daughter’s father.

Filled with joy and hope, amicus Stephanie
Kamanawa recovered her singing voice after
benefitting from the supports she received at the
center. Stronger and filled with a sense of purpose,
Stephanie also now leads a youth group for children in
her community.

35

Ill, PREGNANCY RESOURCE CENTERS AND
MEDICAL CLINICS SERVE ALL PEOPLE,
FREE OF CHARGE

Amici 13 women have each described their
experiences with centers as “free of charge.” Many of
the women who come to centers are without sufficient
resources to get access to basic prenatal care and infant
necessities. These centers and clinics offer a loving and
generous environment that not only helps to meet the
material needs of these women, but also their
emotional and spiritual need to feel connected to a
community and part of a family.

CONCLUSION

This Court can keep the free and life-enhancing
resources of pregnancy resource centers and medical
clinics available to women and their families in the
state of California and across the country. These
centers are an essential resource for women seeking
basic information and authentic choice in their
moments of need. For this reason, and for those
expressed in Petitioners’ Brief on the Merits, amici
request this Court to reverse the Ninth Circuit’s refusal
to enjoin California’s FACT Act.

Respectfully Submitted,
Andrea Picciotti-Bayer

Counsel of Record
The Catholic Association Foundation
3220 N Street NW, Suite 126
Washington, DC 20007
(571) 201-6564
amariepicciotti@gmail.com
Counsel for Amici Curiae

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385016_0737%3A60. Public record. Not legal advice.