Amicus Curiae Brief — Acuna v. Turkish (No. 07-1328)

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Text

es, FILED

No. 07-1328 MAY 2 { 2003

FFICe OF THF

SUPREME Co

3 Bu The

Supreme Court of the Anited States

ROSA ACUNA,

Petitioner,

SHELDON C. TURKISH, M.D., et al.,

Respondents.

On Petition For A Writ Of Certiorari

To The Supreme Court Of New Jersey

BRIEF OF SANDRA CANO, THE FORMER

“MARY DOE” OF DOE V. BOLTON; WOMEN

INJURED BY ABORTION; AND, AMERICAN

ASSOCIATION OF PRO-LIFE OBSTETRICIANS

AND GYNECOLOGISTS (AAPLOG) AS AMICI

CURIAE IN SUPPORT OF PETITIONER

LINDA BOSTON SCHLUETER

Counsel of Record

KATHLEEN CASSIDY GOODMAN

TRINITY LEGAL CENTER

11120 Wurzbach, Suite 206

San Antonio, Texas 78230

Telephone: 210-697-8202

Counsel for Amici Curiae

COCKLE LAW BRIEF PRINTING CO. (800) Zz5-5Yt

OR CALL COLLECT 402) 342-2831

TABLE OF CONTENTS

Page

TARE CF COR 8 es accor cexeesrsarnersenneiermmaienmneiions

TABLE OF AUTHORITIES

STATEMENT OF INTEREST OF THE AMICI

SUMMARY OF THE ARGUMENT

ARGUMENT :

I. THIS CASE IS CERTWORTHY BECAUSE

THE NEW JERSEY SUPREME COURT

MISINTERPRETED ROE V. WADE AND

ITS PROGENY AND ONLY THIS COURT

CAN CORRECT THE ERROR

A. The New Jersey Supreme Court Erred

Because the ‘tate Should Not Endorse

a Physician Giving Medically False

Information about the Status of a

Woman’s Unborn Child as It Interferes

with Her Constitutional Right to De-

cide Whether to Abort the Child

This Court Has Established That

There Cannot Be a Waiver of a Consti-

tutional Right Without a Full Under-

standing of That Right, and Therefore,

There Was an Infringement of Rosa

Acuna’s Right to Decide to Abort Her

TABLE OF CONTENTS -— Continued

Page

II. FAILURE TO PROPERLY INFORM A

WOMAN PUTS HER AT RISK OF

GREATER PSYCHOLOGICAL HARM,

AND THEREFORE, THIS COURT

SHOULD REQUIRE THAT ACCURATE

AND TRUTHFUL INFORMATION BE

GIVEN SO THAT SHE CAN MAKE AN

INTELLIGENT AND KNOWING DECI-

SION CONCERNING HER CONSTITU-

TIONAL RIGHTS

A. Recent State Legislative Findings

Demonstrate That There Is Serious

Physical, Emotional, and Psychological

Harm to Women Who Have an Abor-

tion, and Therefore, Women Should Be

Fully Informed

The Real Life Experiences of Post-

Abortive Women and _ Scientifically

Validated Research Demonstrate That

Abortion Hurts Women Physically and

Psychologically, and Therefore, This

Court Should Require That Full and

Accurate Information Be Given to a

Woman Prior to Exercising Her Right

to Decide

CONCLUSION

APPENDIX

Appendix A: Affidavit of Sandra Cano

Appendix B: Affidavit of Dr. Priscilla

TABLE OF AUTHORITIES

CASES

Acuna v. Turkish, 192 N.J. 399, 930 A.2d 416

(2007)

Boykin v. Alabama, 395 U.S. 238 (1969)

Doe v. Bolton, 410 U.S. 179 (1973)

Gibbons v. Ogden, 22 U.S. (9 Wheat.) 1 (1824)

Godinez v. Moran, 509 U.S. 389 (1993)........ dias cs aie 14

Gonzales v. Carhart, U.S. __, 127 S.Ct.

1610 (2007)

Henderson v. Morgan, 426 U.S. 637 (1976)

Marone v. United States, 10 F.3d 65 (2d Cir.

Patterson v. Illinois, 487 U.S. 285 (1988)

Planned Parenthood v. Casey, 505 U.S. 833

(1992) 1, &, 9, 10, 11

Women’s Medical Center v. Bell, 248 F.3d 411

gS. SARIN a UA RRC a on aRaeD trey fe 7 0 re ed HORE" 22

STATUTES

Women’s Right to Know Act, TEX. HEALTH &

SAFETY CODE § 171.001 et seq. (2003)

TABLE OF AUTHORITIES — Continued

Page

RULES

Fed. R. Crim. P. 11

Books

Willke & Willke, ABORTION 50 (Hayes Pub. Co.

“The Aftereffects of Abortion,” www.afterabortion.

info/complic.html

Texas Department of Health, “A Woman’s Right

to Know” (2003), available at http://www.

dshs.state.tx.us/wrtk/pdf/booklet.pdf.....7, 10, 17, 18

Report of the South Dakota Task Force to Study

Abortion at 37 (December 2005), available at

http://ivotemyvalues.com/pdf/contentmgmt/Task_

Force_Report.pdf A 20, ay

STATEMENT OF INTEREST

OF THE AMICI CURIAE

Consent to file this amici curiae brief was given

by both parties. This brief supporting Petitioner was

prepared by counsel for Amici.’

This case is of great national importance and

consequence because the issue faced by Rosa Acuna is

the principal issue facing approximately one million

women each year in the United States who need and

are entitled to full, accurate, and truthful information

to exercise their constitutional right to decide

whether to abort their unborn child. Due to the well-

established physical and psychological risks and

consequences for women, this decision has far-

reaching and long-lasting implications.

The heart of this case relies on cases previously

decided by this Court in Roe v. Wade, Doe v. Bolton,

and Planned Parenthood v. Casey in which this Court

justifiably expected that there would be a normal

doctor-patient relationship and that a woman would

* The parties were notified ten days prior to the due date of

this brief of the intention to file. The parties have consented to

the filing of this brief. No counsel for a party authored this brief

in:whole or in part, and no counsel or party made a monetary

contribution intended to fund the preparation or submission of

this brief. Trinity Legal Center is a nonprofit corporation and is

supported through private contributions of donors who have

made the preparation and submission of this brief possible. No

person other than amici curiae, their counsel, or donors to

Trinity Legal Center made a monetary contribution to its

preparation or submission.

receive truthful and non-misleading information. A

woman expects to get full, accurate, and truthful

information from her doctor. Failure to give such

information prevents her from making an informed

and knowing exercise of her constitutional right to

decide whether to abort her unborn child.

Many women who have an abortion suffer from

both physical and psychological harm. Failure to

properly inform a woman with full, accurate, and

truthful information puts the woman at even greater

risk of psychological harm when she learns the truth.

This case exemplifies the problem.

Amici Sandra Cano is the “Doe” of Doe v. Bolton.

It was Doe v. Bolton which provided for the health

exception that led to abortion on demand and partial

birth abortion; however, Sandra never wanted an

abortion. She only sought legal help to get a divorce

and regain custody of her two oldest children. See

Appendix A. Years later when she realized that her

name and life were used to bring abortion on demand

and partial birth abortion, she suffered from the

devastation of being misled as to the true nature of

her case, which was in direct contradiction to her

intent, requests, and beliefs. In addition, she has

suffered the devastation of knowing that it was her

case that has been responsible for approximately 45

million abortions. Thus, she too understands the

psychological trauma that post-abortive women suffer

when they learn the truth that abortion killed their

unborn child and experience the negative physical

and psychological consequences of abortion.

Other Amici are post-abortive women who have

suffered and attest to the fact that adverse physical

and psychological effects of abortion have negatively

affected their lives. They regret the fact that they

were never given full, accurate, and truthful informa-

tion concerning the nature and risks of abortion. All

of the women have used their full name in the origi-

nal Affidavits on file at the office of Trinity Legal

Center, but some have requested that only their

initials be used publicly to protect their privacy and

confidentiality.

Amici American Association of Pro-Life Obstetri-

cians and Gynecologists (AAPLOG) was founded in

1973 as a recognized group within the American

College of Obstetricians and Gynecologists (ACOG).

AAPLOG has approximately 2100 members, mostly

ob-gyn physicians from across the United States.

These physicians understand the importance and

value of pregnant women having full, accurate, and

truthful information to make an informed decision.

AAPLOG believes that it is the responsibility and

duty of the physician to properly advise and inform

his/her patient. They have experience with patients

who were not fully informed and who experienced

adverse physical and psychological effects of abortion.

Members of AAPLOG have served as expert wit-

nesses on the abortion issue in the courts and before

legislative bodies.

Because abortion was generally not legal or

widespread prior to the decisions in Roe v. Wade and

Doe v. Bolton, this Court made non-evidence based

assumptions concerning abortion. Now, thirty-five

years later, post-abortive women Amici provide this

Court with their real life experiences and attest that

abortion in practice hurts women’s psychological

health which is confirmed by medical research. See

Appendix B. The post-abortive women Amici are:

Tina Brock (Georgia)

Kay Lyn Carlson (Kansas)

Cynthia Carney (Oklahoma)

T. C. (North Carolina)

Karen R. Hartman (Arizona)

Sherri Hayden (Texas)

Tammy Holly (Michigan)

Dawn Jackson (Texas)

Alveda King (niece of Dr. Martin Luther King, Jr.)

(Georgia)

Kay Painter (Idaho)

Rebecca Porter (Florida)

Kathy Rutledge (Kentucky)

Caron Strong (California)

Norma Tanton (Texas)

Julie Thomas (Georgia)

Cynthia Ann Williamson (Florida)

Ann M. Younger (Texas)

Joyce Leslie Zounis (Colorado)

SUMMARY OF THE ARGUMENT

The issue in this case is whether the state inter-

fered with a woman’s constitutional right to decide to

abort her unborn child by explicitly or implicitly

endorsing the physician’s medically false information

about the status of her unborn child. While this Court

held that a woman has a right to decide whether to

have an abortion, it also expected, as with any medi-

¢al treatment, that a woman would be given truthful

and non-misleading information by her physician.

When a woman is given false or misleading informa-

tion, it impacts on her decision regarding whether to

exercise her constitutional right to decide and poten-

tially causes greater psychological harm when she

learns the truth. Therefore, this Court should require

that a physician give a woman full, accurate, and

truthful information to make an informed decision.

Rosa Acuna’s case is not an isolated incident.

State legislatures have determined that women have

a right to know certain information about the physi-

cal and psychological risks of abortion. In addition,

legislative findings demonstrate that women are not

given this information prior to an abortion. Medical

research confirms what Rosa Acuna and other post-

abortive women have experienced that abortion

places women at an increased risk for depression,

suicidal ideation, suicide, anxiety, and substance

abuse. Lack of pre-abortion counseling and informed

consent are key factors in post-abortion difficulties.

Furthermore, avoiding a discussion of fetal develop-

ment by describing a fetus in terms of “blood” or

“tissue” is not truthful and can lead to devastating

psychological consequences when a woman obtains

truthful information. Because the absence of truthful

information increases the risk of psychological prob-

lems, this Court should require that a physician

provide truthful and non-misieading information, and

therefore, this Court should grant the Petition for

Writ of Certiorari to ensure that pregnant women are

given full, accurate, and truthful information before

they exercise their constitutional right to decide.

ARGUMENT

THIS CASE IS CERTWORTHY BECAUSE

THE NEW JERSEY SUPREME COURT

MISINTERPRETED ROE V. WADE AND

ITS PROGENY AND ONLY THIS COURT

CAN CORRECT THE ERROR.

A. The New Jersey Supreme Court Erred

Because the State Should Not Endorse

a Physician Giving Medically False

Information about the Status of a

Woman’s Unborn Child as It Interferes

with Her Constitutional Right to De-

cide Whether to Abort the Child.

Because this Court constitutionalized the abor-

tion issue in Roe v. Wade’ and Doe v. Bolton,’ only this

Court can correct the lower court’s errors in interpre-

tation and application. The New Jersey Supreme

' 410 U.S. 113 (1973)

’ 410 U.S. 179 (1973)

Court, relying on Roe v. Wade, allowed the physician

to give Rosa Acuna false information.‘

When Rosa Acuna specifically asked her physi-

cian if her eight-week-old unborn child was a baby, he

said “Don’t be stupid, it’s only blood.” It cannot be

disputed that this information — that her eight-week-

old unborn child was merely “blood” — was clearly

false.” After being taken to the emergency room

because of massive hemorrhaging, she was told that

because of an incomplete abortion parts of the baby

were left inside her.’ Upon doing research, she

learned the truth about the gestational development

of her baby which led to psychological problems and a

diagnosis of post-traumatic stress syndrome."

The question posed in this case is whether the

state interfered with a woman’s constitutional right

te decide to abort her child, by explicitly or implicitly

* See Acuna v. Turkish, 192 N.J. 399, 930 A.2d 416, 426

(2007).

* Id. at 419.

* For example, the Texas “Woman’s Right to Know” booklet

describes an eight-week-old unborn child as having all essential

organs beginning to form; elbows and toes are visible; the

fingers have grown to the first joint; facial features — the eyes,

nose, lips, and tongue — continue to develop; the outer ears begin

to take shape; organs begin to be controlled by the brain, and

the baby’s length is about 1/2 to 3/4 inch. “A Woman’s Right to

Know” by the Texas Department of Health (2003), available at

http://www.dshs.state.tx.us/wrtk/pdf/booklet. pdf.

Acuna v. Turkish, 192 N.J. 399, 930 A.2d 416, 419 (2007).

* Id

endorsing the physician’s medically false information

about the status of her unborn child.

In Roe v. Wade’ and its progeny,” this Court held

that a woman has a right to decide whether to have

an abortion. Amici believe that Roe was incorrectly

decided and should be overruled; however, because

Roe and its progeny are the law, it is clear that Rosa

Acuna’s constitutional right to decide whether to have

an abortion was significantly infringed upon by the

state court in rejecting her claims. This Court af-

forded a woman’s right to decide constitutional pro-

tection as a part of her substantive liberties as an

individual.'’ A woman’s right to make this decision in

a fully-informed manner is critical because, as this

Court recognized, abortion

is an act fraught with consequences for oth-

ers; for the woman who must live with the

implications of her decision; for the persons

who perform and assist in the procedure; for

the spouse, family, and society which must

confront the knowledge that these proce-

dures exist, procedures some deem nothing

short of an act of violence against innocent

human life; and depending on one’s beliefs,

for the life or potential life that is aborted.”

* 410 U.S. 113 (1973).

' Planned Parenthood v. Casey, 505 U.S. 833 (1992)

Id. at 852-53.

* Td. at 852.

Living with the consequences and implications of

that decision is exactly what Rosa Acuna suffered as

well as the post-abortive Amici and other post-

abortive women who suffer from the psychological

consequences of abortion.” This Court also recognized

that women can suffer from depression, regret, guilt,

and a loss of self-esteem following an abortion.“

The assumption in Roe v. Wade and its progeny is

that a woman’s decision to have an abortion would be

made after consulting with her physician.” The

assumption presumes that the advice and counsel of

the physician will be based on sound medical advice

concerning the gestational age of the unborn child,

the health risks associated with an abortion, and the

nature of the medical procedure.” This Court ex-

pected that the physician would give “truthful, non-

misleading information.”” Rosa Acuna was given

false information about the characteristics and

development of her eight-week-old unborn child.

Furthermore, if it were just “blood,” she would not

expect the risk of being rushed to the emergency room

‘“ Dr. Coleman discusses the psychological problems post-

abortive women can have including depression, thoughts of

suicide, anxiety, feelings of regret, shame, guilt, bereave-

ment/loss, and lowered self-esteem. See Affidavit of Dr. Priscilla

Coleman, Appendix B.

‘ Gonzales v. Carhart, ___: U.S. __,, 127 S. Ct. 1610, 1634

(2007).

* Roe v. Wade, 410 U.S. 113, 163 (1973).

‘ Planned Parenthood v. Casey, 505 U.S. 833, 882 (1992)

due to an incomplete abortion with “parts of the baby

left in” her. This Court expected that truthful, non-

misleading information would be given; now, to

protect the right to decide, it should require that

women, like Rosa Acuna, are given accurate and

truthful information.

Roe v. Wade recognized that at a minimum a

pregnancy evidences potential life’ — something more

than simply a collection of cells, blood, tissue, or body

fluids. Thirty-five years after Roe, through the ad-

vancement of medical technology, it is well-recognized

that life begins at fertilization.” The New Jersey

Supreme Court erred in relying o; thirty-five-year-

old science to justify Rosa Acuna’s physician giving

her false information.”

Roe v. Wade” and its progeny” also recognized

the state’s interest in promoting life. The state has an

obligation to avoid placing an undue burden on a

woman’s decision; but, it has an equally compelling

obligation to ensure that the information given to a

woman comports with sound medical judgment,

Roe v. Wade, 410 U.S. 113, 163 (1973).

‘* For example, see “A Woman’s Right to Know” by the Texas

Department of Health (2003), available at http://www.dshs.state.

tx.us/wrtk/pdf/booklet. pdf.

* See Acuna v. Turkish, 192 N.J. 399, 930 A.2d 416, 426

(2007).

” Roe v. Wade, 410 U.S. 113 (1973).

“ Planned Parenthood v. Casey, 505 U.S. 833 (1992).

advice, and current medical knowledge to ensure a

° ° . 23

woman’s decision is informed.

False or misleading information impacts a

woman’s decision on how to exercise her constitu-

tional right to decide. If the state explicitly or implic-

itly minimizes the dangers and thereby impacts the

woman’s decision, it is significantly interfering with

the woman’s decision regarding the life within her.

This is certainly true in this case where Rosa Acuna

specifically asked if the life within her was a baby

because the question was the ultimate factor in her

decision-making process. This Court recognized that

the impact on the fetus would be “relevant, if not

dispositive” for most women.”

Furthermore, Rosa Acuna’s experience is not an

isolated event.” Abortionists are not giving women full,

accurate, and truthful information as anticipated by

Roe and Casey. For example, in the largest government

~ Id. at 878 (stating “to promote the State’s profound interest

in; potential life, throughout pregnancy the State may take

measures to ensure that the woman’s choice is informed...”).

* Id. at 882.

* For example, the post-abortive women Amici were asked

on the affidavit: When and how did you learn it was a baby? The

following are typical examples: Tina Brock (Georgia) — “When I

became pregnant with my daughter and had an ultrasound.”

Cynthia Carney (Oklahoma) — “22 years later someone gave me

a pamphle’ on the development of a preborn.” T.C. (North

Carolina) — I realized the truth right after the abortion.” Norma

Tanton (Texas) — “2 years later when Time Magazine came out

with an article and photos of how life began.”

study since Roe, the South Dakota Task Force con-

cluded that “virtually all of the credible objective

evidence” compelled the conclusion that abortions in

South Dakota were not informed.” The Report stated

that the record reflects the following concerning

informed consent: (a) The abortion providers fail to

disclose the essential nature of the procedure — that it

terminates the life of the woman’s existing child; (b)

When they do discuss the procedure, they provide

misleading information in misleading terms; (c) The

abortion providers give misleading information about

the psychological and physical risks to the mother,

and do not disclose the direct injury to the child that

leads to its death; (d) The abortion providers assume

the women have made their decisions before they

reach the facility; and, (e) The abortion providers

place the burden upon the mothers to discover mate-

rial facts on their own.”

In summary, the New Jersey Supreme Court

erred in its endorsement of a physician providing

medically false information which interfered with

Rosa Acuna’s constitutionally protected right to

decide. The answer to the specific question that

she asked was crucial to her decision to abort her

unborn child. At a minimum, this Court should

require that a woman be given full, accurate, and

* Report of the South Dakota Task Force to Study Abortion

at 37 (December 2005), available at http://ivotemyvalues.com/

pdf/contentmgymt/Task_Force_Report. pdf.

~ Id.

truthful information as it expected in Casey. Other-

wise, a woman’s constitutionally protected right to

decide to abort ner child is meaningless.

B. This Court Has Established That

There Cannot Be a Waiver of a Consti-

tutional Right Without a Full Under-

standing of That Right, and Therefore,

There Was an Infringement of Rosa

Acuna’s Right to Decide to Abort Her

Child.

As with other constitutional nghts, a person can

waive or invoke the right. In other contexts, however,

this Court has recognized that certain constitutional

rights are so important, and the concomitant risks so

high, that the government must ensure that those

rights are exercised or waived only after receiving

competent advice, including a warning about poten-

tial negative effects. For example, Miranda” warn-

ings are designed to ensure that a suspect’s privilege

against self-incrimination is protected. Similarly,

there is a range of decisions that the defendant must

make in a criminal trial including the assistance of

counsel in deciding whether to exercise, for example,

the decision to speak to the police, take the stand,

waive a jury trial, or plead guilty.”

** Miranda v. Arizona, 384 U.S. 436 (1966).

* See, e.g., Miranda v. Arizona, 384 U.S. 436 (1966) (rights

warnings to insure protections associated with Fifth Amendment

(Continued on following page)

The decision on whether to have an abortion has

physical and psychological risks and negative effects

for the mother and is an issue of life or death for the

unborn child. These factors are certainly as important

as to whether to speak to the police, waive a jury

trial, or plead guilty.

The same approach should apply in the context of

a woman’s decision to bear or not bear a child. The

role of the physician, who is in the position to give

sound medical advice to the woman, is to provide

her with accurate medical facts. The New Jersey

Supreme Court, however, impermissibly shifted the

right from the woman to make an informed decision

to the physician’s right of conscience. Thus, the court

allowed the physician to not disclose accurate and

truthful information instead of enforcing the right of

a woman to have accurate and truthful information to

privilege against self-incrimination); Boykin v. Alabama, 395

U.S. 238 (1969) (valid guilty plea requires an intentional

relinquishment or abandonment of a known right or privilege);

Henderson v. Morgan, 426 U.S. 637 (1976) (guilty plea is not

valid unless the defendant knows the nature of the offense to

which he or she pleads); Patterson v. Illinois, 487 U.S. 285

(1988) (Miranda warnings sufficient to apprise defendant of

Sixth Amendment right to counsel before post-indictment

interrogation); Godinez v. Moran, 509 U.S. 389 (1993) (judge

must be satisfied that defendant’s waiver of his constitutional

right to assistance of counsel at trial is knowing and voluntary);

Marone v. United States, 10 F.3d 65 (2d Cir. 1993) (setting out

procedures for trial judges to use in accepting waiver of jury

trial in federal courts); see also Fed. R. Crim. P. 11 (providing

detailed guidelines for judges conducting plea inquiries before

accepting a guilty plea from a defendant).

decide whether to abort her unborn child. This Court

has never recognized the right of any physician in

any context to falsify critical, factual information

involving the patient’s medical procedure.

The New Jersey Supreme Court also tried to

justify giving false information by stating that a

doctor is not compelled to give the information when

he has “a different scientific, moral, or philosophical

viewpoint.”” Even assuming arguendo that the

physician’s moral or philosophical viewpoint was

different from current medical science, he could have

provided known medical facts, such as the physical

characteristics of an eight-week-old unborn child. In

other words, he would not have to violate his beliefs

while still providing her with medically sound infor-

mation. She could then decide for herself if the hu-

man life within her is in fact a “baby.”

The New Jersey Supreme Court in this case

ignored these fundamental principles and relied on

this Court’s decision in Roe to justify the doctor’s

advice that the child growing within the woman was

only “blood” — a grossly misleading characterization

which reduced the woman’s decision to nothing more

significant than giving a blood sample or losing blood.

Therefore, the New Jersey Supreme Court erred.

As Justice Ginsburg wrote, “The Court is surely

correct that, for most women, abortion is a painfully

* Acuna v. Turkish, 192 N.J. 399, 930 A.2d 416, 428 (2007).

difficult decision.”” At this most difficult time in a

woman’s life, she should have full, accurate, and

truthful information before exercising her constitu-

tional right to decide whether to abort her unborn

child.

Il. FAILURE TO PROPERLY INFORM A

WOMAN PUTS HER AT RISK OF GREATER

PSYCHOLOGICAL HARM, AND THERE-

FORE, THIS COURT SHOULD REQUIRE

THAT ACCURATE AND TRUTHFUL IN-

FORMATION BE GIVEN TO A WOMAN SO

THAT SHE CAN MAKE AN INTELLIGENT

AND KNOWING DECISION CONCERNING

HER CONSTITUTIONAL RIGHTS.

A. Recent State Legislative Findings Dem-

onstrate That There Is Serious Physi-

cal, Emotional, and Psychological Harm

to Women Who Have an Abortion, and

Therefore, Women Should Be Fully In-

formed.

As this Court recognized, “whether to have an

abortion requires a difficult and painful moral deci-

sion” and is “fraught with emotional consequence.””

** Gonzales v. Carhart, __ U.S. ___, 127 S. Ct. 1610, 1648

n.7 (2007) (Ginsburg, J., dissenting).

* Gonzales v. Carhart, __ U.S. __, 127 S. Ct. 1610, 1634

(2007).

This Court also noted that “severe depression and

loss of esteem can follow” an abortion.”

Prior to Roe v. Wade” and Doe v. Bolton,” health

issues like abortion were decided by the states”

where hearings could be held to determine whether

the medical and scientific knowledge are more ad-

vanced to warrant a different legal conclusion. In the

thirty-five years since Roe and Doe, legislatures have

determined that there are physical and psychological

health risks from abortion and that women should be

provided with this information prior to an abortion.

For example, the Texas Legislature passed the

“Women’s Right to Know” Act” in 2003. As a result,

the medical board of the Texas Department of Health

held hearings and ultimately produced a _ booklet

entitled “A Woman’s Right to Know” which is to be

distributed to women who are considering an abor-

tion.” The booklet provides information concerning

ai”

* 410 U.S. 113 (1973).

*® 410 U.S. 179 (1973).

* Gibbons v. Ogden, 22 U.S. (9 Wheat.) 1, 204 (1824)

recognized that under what was later called the state’s “police

power” the states could regulate “health laws of every descrip-

tion.”

*’ Women’s Right to Know Act, Tex. HEALTH & SAFETY CODE

§ 171.001 et seq. (2003).

'* The booklet is available through the Texas Department

of Health or on its website at www.dshs.state.tx.us/wrtp/pdf/

booklet. pdf.

the baby’s unique DNA,” calls the baby an “unborn

child,” shows the growth and development from four

to thirty-eight weeks gestation,” describes the abor-

tion procedure,” and explains the physical, emotional,

and psychological risks to women.”

The Texas Department of Health’s booklet warns

of the “emotional side of an abortion.” It states:

Some women may feel guilty, sad, or empty,

while others may feel relief that the proce-

dure is over. Some women have reported

serious psychological effects after their abor-

tion, including depression, grief, anxiety,

lowered self-esteem, regret, suicidal thoughts

and behavior, sexual dysfunction, avoidance

of emotional attachment, flashbacks, and

substance abuse. These emotions may ap-

pear immediately after an abortion, or

gradually over a longer period of time. These

feelings may recur or be felt stronger at the

time of another abortion, or a normal birth,

or on the anniversary of the abortion.”

Currently, a number of state legislatures are

considering removing or in some other way limiting

* “Women’s Right to Know” booklet at 2.

” Id.

* Id. at 3-8.

“ Id. at 14-15.

“Id. at 15-17.

“ Id. at 16.

* Id.

the health exception.” A notable example is South

Dakota which has made substantial and detailed

findings after extensive hearings that led to a ban on

abortion except to save the life of the mother.”

After hearing all of the evidence from experts and

post-abortive women, the Task Force stated:

Further, the Task Force finds that the pre-

abortion counseling provided often does not

prepare women who have abortions for the

psychological outcomes they may experience

after their abortions. In addition, women

who receive little or no information about

possible emotional health risks of this proce-

dure may significantly compromise their

mental health and the quality of their lives

for years to come. Due to the very limited in-

formation disclosed by abortion providers,

women are not fully aware that abortion car-

ries with it the potential to damage their

physical, emotional, interpersonal, and spiri-

tual well-being.”

The Task Force also addressed the issue of the

psychological consequences of terminating the life of

the child. The Task Force stated:

“For example, Alabama, Indiana, Georgia, Kentucky,

Louisiana, Missouri, Michigan, Mississippi, Ohio, Oklahoma,

Tennessee, and West Virginia.

* Report of the South Dakota Task Force to Study Abortion

(December 2005), available at http://ivotemyvalues.com/pdf/

contentmgmt/Task_Force_Report.pdf.

* Id. at 47.

Perhaps worse, the pregnant mother is not

told prior to her abortion that the procedure

will terminate the life of a human being. The

psychological consequences can be devastat-

ing when that woman learns, subsequent to

the abortion, that this information was

withheld — information that would have re-

sulted in her declining to submit to an abor-

tion. Her anger at being deceived and being

prevented from making an informed decision

for herself is exacerbated by her realization

that she was implicated in the killing of her

own child in utero. Aside from the injustice of

her being deprived of making her own in-

formed decision (see Section [1-D), the psy-

chological harm of knowing she killed her

child is often devastating.”

In addition, the Task Force found that:

..it is simply unrealistic to expect that a

pregnant mother is capable of being involved

in the termination of the life of her own child

without risk of suffering significant psycho-

logical trauma and distress. To do so is be-

yond the normal, natural, and healthy

capability of a woman whose natural in-

stincts are to protect and nurture her child.”

The Task Force heard testimony from Dr. Vincent

Rue, Ph.D., who is a psychotherapist and a professor,

and was special consultant to then-U.S. Surgeon

" id.

” Id. at 47-48.

General Dr. C. Everett Koop on abortion morbidity.

Dr. Rue provided the first clinical evidence of post-

abortion trauma in 1981 and identified this psycho-

logical condition as ‘Post-Abortion Syndrome’ in

testimony before the U.S. Congress.”” The Task Force

heard evidence that individuals with Post-Abortion

Syndrome “experience symptoms of avoidance (efforts

to escape from reminders of the event), intrusion

(unwanted thoughts, nightmares, and flashbacks

related to the event), and arousal (exaggerated startle

reflex, sleep disturbance, irritability) for a month or

more following exposure to a traumatic event.””

Although for some women, the initial response is one

of relief, many women later avoid the problem

through repression and denial, usually for years — “5

years is common, 10 or 20 is not unusual.”

Abortion hurts women emotionally and psycho-

logically, and therefore, this Court should grant the

Petition for Writ of Certiorari to ensure that women

are entitled to full, accurate, and truthful information

before they exercise their constitutional right to

decide.

*" Td. at 53.

” Id. at 44.

Willke & Willke, ABORTION 50 (Hayes Pub. Co. 2003).

B. The Real Life Experiences of Post-

Abortive Women and Scientifically

Validated Research Demonstrate That

Abortion Hurts Women Physically and

Psychologically, and Therefore, This

Court Should Require That Full and

Accurate Information Be Given to a

Woman Prior to Exercising Her Right

to Decide.

The Court of Appeals for the Fifth Circuit recently

cited testimony that abortion as practiced is “almost

always a negative experience for the patient...”“ The

post-abortive women Amici’s real life experiences

attest that there are harmful and negative physical

and psychological consequences to abortion.”

“ Women’s Medical Center v. Bell, 248 F.3d 411, 418 (5th

Cir. 2001).

“ For example, post-abortive women Amici attest: Tina

Brock (Georgia) — “I suffered from severe depression for years

after my abortion until | found healing.” Cynthia Carney

(Oklahoma) — “I had a replacement child. But after I gave birth

to him, I couldn’t shake the depression or the feeling that

something was wrong. The relationship with my 1 year old

changed, I felt detached from him & didn’t know why - there

was an aching hole in my heart.” T.C. (North Carolina) — “I

regret it more than anything else in my difficult life;’? Karen

Hartman (Arizona) — “I hated myself and told myself that daily.

‘TI hate myself, I hate myself!” I cried on my horses necks each

morning. I would try to escape the pain by riding the horses,

working hard, trying to please others. I wore a plastic smile,

inside I was a hole of despair. I wanted out, but I had not the

tools to climb from this deep dark hole. My nightmares involved

trying to pull a baby out of a hole, never succeeding.” Sherri

(Continued on following page)

One of the largest pregnancy resource centers,

Care Net” and other pregnancy resource centers

attest that their organizations hac over 100,000

women in post-abortion recovery programs in 2004

alone. It is estimated that there are more than one

million abortions each year. If even 1 in 10 women

suffer from negative psychological consequences of

abortion, then this Court should require that women

are given full and accurate information to make an

informed decision.

Medical research confirms what Rosa Acuna and

other post-abortive women have experienced. Dr. Priscilla

Coleman attests after approximately eighteen years

Hayden (Texas) — “...depression, loss of joy, I isolated myself,

fearful, loss of peace, emotionally numb.” Kathy Rutledge

(Kentucky) — “My abortion placed a dark cloud over my life that

never lifted — I was never the same. It was as if two people died

that day — my baby died physically, and I died emotionally and

spiritually. I continued to manage my life mentally, but in a fog,

devoid of the enormous amount of creativity and energy J had

displayed in high school. Looking back, it was an unfortunate

waste of two lives.” Norma Tanton (Texas) — “It has left a hole in

my soul — I have had to work through depression, guilt, shame,

condemnation & suicidal thoughts thru post abortion counsel-

ing. 24 years after my abortion, I never knew that was available

until 2 years ago — I tried to commit suicide once — I felt unwor-

thy of being a mother to my step daughter — I had a lot of

suppressed anger over the situation and disassociated myself

from people distrusting them. Learn to live w/a mask -— full of

fear & anxiety of others finding out.”

‘** Care Net was founded in 1975. Its focus is to develop,

equip, and promote more than 900 pregnancy centers across

North America. See www.care-net.org.

of extensive research that women are at an increased

risk for depression, suicidal ideation, suicide, and

death.” In addition, other well-established psycho-

logical difficulties include anxiety, substance abuse,

unrelenting feelings of regret, shame, guilt, bereave-

ment/loss, and lowered self-esteem.”

Dr. David Reardon, one of the world’s leading

experts on the effects of abortion on women, further

demonstrates the devastating psychological conse-

quences of abortion. Dr. Reardon states that following

temporary feelings of relief, there is emotional “pa-

ralysis” or post-abortion “numbness,” guilt and re-

morse, nervous disorders, sleep disturbances, sexual

dysfunction, depression, loss of self-esteem, self-

destructive behavior such as suicide, thoughts of

suicide, and alcohol and drug abuse, chronic problems

with relationships, dramatic personality changes,

anxiety attacks, difficulty grieving, increased ten-

dency toward violence, chronic crying, difficulty

concentrating, flashbacks, and difficulty in bonding

with later children.”

As Dr. Coleman attests, pre-abortion counseling

and informed consent are key factors in post-abortion

*’ Affidavit of Dr. Priscilla Coleman, Appendix B.

” ed.

°” “The Aftereffects of Abortion,” www.afterabortion.info/

complic.html] (calling abortion a public health issue and listing

the physical and psychological effects of abortion).

difficulties.” Avoiding discussion of fetal development

or using terms like “tissue” or “blood” encourages

consent based on false and misleading information,

but a woman may not give consent if she is told the

truth.” Furthermore, when a woman obtains truthful

information concerning fetal development, devastat-

ing psychological consequence are more probable.”

Although it is frequently overlooked, a critical

factor in a woman’s decision-making process is that

abortion is legal.” Therefore, most women assume

* Affidavit of Dr. Priscilla Coleman, Appendix B.

Id.

° Id.

“ For example, post-abortive women Amici attest: Tina

Brock (Georgia) — “I felt if it was legal it must be OK. Since I

was lied to and told it was just a blob, I didn’t know it was

murdering a human being & at 9 weeks it is very much a human

being therefore it was murder & murder is not legal — well

except abortion.” Cynthia Carney (Oklahoma) — “I would have

never had an abortion if it was illegal. Simply went into an office

that was offering free pregnancy tests, and when I left they told

me it was just tissue. No one had ever said that to me before.”

Karen Hartman (Arizona) — “We would not have considered an

abortion had it been illegal. I thought ‘It’s legal, it must be okay,

my government couldn’t hurt me!” Sherri Hayden (Texas) — “It

made it too easy and accessible.” Kay Painter (Idaho) — “Never

would have considered abortion had it been illegal. Laws are to

protect you. If it’s legal it must be a good choice and safe.” Kathy

Rutledge (Kentucky) — “My mother didn’t give me any options

and threatened that my Dad (my parents were divorced) would

kill' her if he found out I was pregnant. I believed her, and since

abortion was legal, it seemed like a legitimate way to resolve the

‘family’ crisis. Legalized abortion caused undue pressure to

terminate my pregnancy without consideration of other options.”

(Continued on following page)

that abortion is not fraught with physical and psycho-

logical consequences.

This Court recognized that a state requirement

that a woman be informed does not create an undue

burden. It also expected that a woman would be given

truthful and non-misleading information. Amici urge

this Court to grant the Petition for Writ of Certiorari

to ensure that physicians will provide a woman with

truthful and non-misleading information at what has

been recognized as the most difficult time in her life.

CONCLUSION

When this Court granted women the constitu-

tional right to decide whether to abort their unborn

child, it assumed that each woman would be given

accurate and truthful information to make an in-

formed decision. At this most difficult time in a

woman’s life, the women of this nation need to trust

that physicians will provide accurate and truthful

information. As this Court recognized, abortion can

cause psychological harm such as depression, regret,

guilt, and low self-esteem. However, a woman is at

greater risk of these complications when she later

Norma Tanton (Texas) — “If abortion wasn’t legal I wouldn’t have

had an abortion. I was already going through an emotional

trauma by being disowned by his parents’ when my mother-in-

law pressured and talked me into an abortion. She made the

appt and took me.” Cynthia Williamson (Florida) — “If it wasn’t

legal I wouldn’t have had one. You think laws and legal things

are right. Wouldn’t be legal if it was going to hurt or kill. The

law does not protect women.”

learns the truth that her choice to have an abortion

was instead the choice to kill her unborn child.

_ Rosa Acuna directly asked her doctor if her eight-

week-old unborn child was a baby. He gave her false

information when he said it was just “blood.” It was

only after suffering physical complications due to an

incomplete abortion that she was told parts of her

baby had been left inside her. Upon doing research,

she learned the truth about the gestational develop-

ment of her baby. This led to psychological problems

and a diagnosis of post traumatic stress syndrome.

The New Jersey Supreme Court erred in condoning

the physician giving Rosa Acuna false and misleading

information. This Court expected that a physician would

give truthful, non-misleading information. Without

accurate and truthful information, a woman cannot

make an informed decision to exercise her constitu-

tional right to decide whether to have an abortion.

Therefore, Amici urge this Court to grant the

Petition for Writ of Certiorari as this important issue

affects millions of women who are considering

whether to abort their unborn child.

Respectfully submitted,

LINDA BOSTON SCHLUETER

State Bar Card No.: 24000127

Supreme Court Admission: 1976

KATHLEEN CASSIDY GOODMAN

State Bar Card No.: 24000255

Supreme Court Admission: 2001

Counsel for Amici Curiae

App. l

APPENDIX A

AFFIDAVIT OF SANDRA CANO

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVISION

Sandra Cano, formerly

known as MARY DOE,

Plaintiff,

ARTHUR BOLTON, Attorney

General of the State of

Georgia Through His

Official Successor in Office,

THURBERT E. BAKER;

LEWIS R. SLATON, as Dis-

trict Attorney of Fulton

County, Georgia Through

His Official Successor in

Office, PAUL L. HOWARD,

JR.; And HERBERT T. JEN-

KINS, as Chief of Police of

the City of Atlanta Through

His Official Successor in

Office, Richard Pennington,

Defendants.

CIVIL ACTION

NO. 13676

STATE OF GEORGIA

COUNTY OF FULTON

App. 2

AFFIDAVIT OF SANDRA CANO

KNOW ALL MEN BY

THESE PRESENTS:

BEFORE ME, the undersigned authority, on this

day personally appeared SANDRA CANO, who after

being duly sworn upon his oath deposed and said as

follows:

My name is Sandra Cano, and I reside in

Georgia. I am competent to make this Affi-

davit. I have personal knowledge of the facts

stated herein and the following is true and

correct.

In 1973, I was the woman designated as

‘Mary Doe’, the Plaintiff in Doe v. Bolton, 410

U.S. 179 (1973), the companion case to Roe v.

Wade, 410 U.S. 113 (1973). Although the

courts understood that ‘Mary Doe’ was not

my real name, what the courts did not know

was that, contrary to the facts recited in my

1970 Affidavit, I neither wanted nor sought

an abortion. I was nothing but a symbol in

Doe v. Bolton with my experience and cir-

cumstances discounted and misrepresented.

During oral arguments before the United

States Supreme Court one of the Justices

stated that it did not matter whether I was a

real or fictitious person. This is where the

Court was so very wrong. It did matter. I was

a real person, and I did not want an abor-

tion.

App. 3

Abortion is just like Doe v. Bolton. It dis-

counts the real experiences of the mothers. It

misrepresents that abortion is for them. Just

as Mary Does’ true desires were hidden from

the courts by those promoting abortion, so,

too, have the real facts about abortion been

hidden. Today, this Court will know the real

truth about the real woman who was used to

deceive, not only the courts, but the women

of this nation about the reality of abortion.

‘Sandra Race Bensing’ was my real name in

1970. I was twenty-two years old and preg-

nant with my fourth child when I first met

the Doe v. Bolton attorney, Margie Pitts

Hames. I had gone to legal aid to get a di-

vorce and to find an attorney to help me re-

gain custody of my two children. My husband

was not supporting us, and we had to live at

the Salvation Army. At times we lived with

my mother, but my stepfather did not want

us there. I loved my children, but I could not

care for them financially.

I was a trusting person and did not read the

papers placed in front of me by my lawyer. I

truly thought Margie Pitts Hames was hav-

ing me sign divorce papers. I did not even

suspect that the papers related to abortion

until one afternoon when my mother and my

lawyer told me that my suitcase was packed

to go to a hospital, and that they had sched-

uled an abortion for the next day. They ad-

vised me that my doctor, Dr. Donald Block,

was going to perform an abortion. I told both

my mother and my lawyer that I would not

App. 4

have an abortion. Not then. Not ever. They

persisted in their demands upon me.

When the demand for an abortion persisted,

I fled to Oklahoma and stayed at the home of

my ex-husband’s grandmother. I remained in

Oklahoma until my mother and lawyer as-

sured me that they would cease their pres-

suring me to have an abortion. I was relieved

that the ordeal was ended. Because they

promised never to force me to have an abor-

tion, I returned to Georgia.

My lawyer sent me a plane ticket so I could

fly from Oklahoma to Georgia. She wanted

me to be in a courtroom with other pregnant

mothers. The night before I went to court,

my mother and my lawyer expressed concern

that I would leave again, and so they had me

stay at the apartment of a legal-aid lawyer.

Before the court appearance, I was told by

my lawyer not to say anything in court. As a

result, I never did say anything in court.

My predicsment made it difficult for me to

take care of my children, but I didn’t need an

abortion. I needed help, but all of the people

around me — my husband, my mother and

my lawyer — refused to help me with my

children.

Instead of real help, my mother, stepfather

and my lawyer persisted in their demands

that I have an abortion. Those demands were

made for themselves so they would not be

burdened. It was, in my mind, a demand for

what they thought was the easiest way for .

App. 5

them to get out from under any obligation to

help my new baby and me. But the abortion

was not in my interest. I was the mother of a

baby for whom I was responsible. I had a

natural desire to have my baby and to raise

her. I carried my child to full term and gave

birth. Because no one would help me I felt

compelled to surrender my rights and give

my baby up for adoption.

. One day in 1973, my mother and stepfather

called me into their bedroom. Their televi-

sion was on. They shouted to me excitedly,

“Look! You won! You won!” Margie Pitts

Hames was on television and the story re-

ported that the United States Supreme

Court had made abortion legal. At that time,

I did not fully comprehend what my role was

in the Court’s decision in Doe v. Bolton.

. Over the years, I gained a greater and

greater sense that I was wrongfully used in

Doe v. Bolton. A number of years ago, I de-

cided that I wanted to see my file in the case

so I could see what was said about me. I

went to the courthouse to see my records

which were under seal. An attorney, Wendell

Bird, agreed to represent me and he asked

that my records in my case be unsealed. I

produced my driver’s license, my birth cer-

tificate, and my marriage certificate. The at-

torney who represented me in Doe v. Bolton,

Margie Pitts Hames, tried to stop me from

getting my own records, and [ did not under-

stand why.

App. 6

12. It was only when I first saw the opened re

cords in Doe v. Bolton that I understood why

Margie didn’t want me to see them. The re-

cords stated that I applied for an abortion,

was turned down, and, as a result, sued the

state of Georgia. According to the records, I

had applied for an abortion through a panel

of nine doctors and nurses at a state-funded

hospital, Grady Memorial Hospital. That was

a false statement. After reading the court re-

cords, I contacted the hospital and tried to

obtain my records. At first I was told there

were records, but when my new attorney

sent his legal assistant to review the records,

we were told that they did not exist. The

hospital said they didn’t have any records. I

never sought an abortion there or anywhere

else.

At times, I have been forced to reflect upon

the events that led up to that day in 1973

when my mother and stepfather told me

about the Supreme Court decision in Doe v

Bolton. In 1970, my life was a mess. I was

having my fourth child, but no responsible

husband or real place to live. I was unedu-

cated. When I came back from Oklahoma, |

was so relieved that no one was going to

pressure me to have an abortion that I took

part in a court proceeding without under-

standing what was really happening. I was

used wrongly, but I didn’t inquire enough. In

retrospect, there were big signs which re-

vealed what was happening.

App. 7

Once a television man came to Margie’s office

and I was asked what I thought of abortion. I

told him that, “I don’t believe in abortion and

I don’t want an abortion.” I also said I didn’t

care if anyone else had an abortion, that it

wasn’t my business. All I cared about, at that

time, was that I didn’t want an abortion. I

was not thinking of the other women. I did

not understand that I was involved in a case

that sought to legalize abortion. I was naive.

In retrospect, perhaps, I could have discov-

ered what was going on. But I was in a crisis.

I depended on my mother’s help. My lawyer

became upset with me because I would never

say to anyone that I would have an abortion.

I should have, perhaps, understood what was

happening, but I was simply attempting to

survive. I remember Margie debating me.

She claimed we were involved in a liberation

right. She said women were entitled to equal

pay for equal work, and I agreed. I never saw

the pleading filed in court.

Many years later, when I saw the unsealed

records in my case, I could not believe what

the certification filed in my name said. I am

certain the signature on the affidavit that

said I wanted an abortion was not mine. I

never saw that affidavit until the records

were unsealed. If it was my signature, it was

obtained without my knowing the contents of

the affidavit. I had fled to Oklahoma to avoid

an abortion. My lawyer knew I would never

say I wanted one. The only reason I went to

a lawyer was to get my children back. My

App. 8

predicament was used to argue that my new

baby’s life should be terminated.

I have often rethought how my involvement

in Doe v. Bolton came about. Over the years

it has haunted me. I never had an abortion,

but I know what it is like to feel responsible

for one. I know what it is like to feel like a

mother who helped terminate the life of her

own child. After Doe v. Bolton was decided

and I was told about my involvement, I felt

responsible for the experiences to which the

mothers and babies were being subjected. In

a way, I felt that I was involved in the abor-

tions — that I was somehow responsible for

the lives of the children and the horrible ex-

periences of their mothers. | have felt that

experience that the death of a child is my

fault; the helplessness the mother feels as

events occur around her without any power

to stop them; and the guilt that is associated

with being told by the courts and society that

the child’s death was performed for the

mother and only the mother.

. This last assertion — that abortion is per-

formed for the mother — is the cruelest mis-

representation of all. My own circumstance,

the one used to justify legal abortion in the

first place, is a perfect example of this real-

ity. There are many doctors, and clinics and

others who were plaintiffs in Doe v. Bolton.

As Mary Doe, I was the only pregnant

mother who was a plaintiff. All of these other

people — the doctors, nurses and clinics were

using the Court to do what they thought was

App. 9

in my interest. They pressured the Court

claiming I need the right to terminate the

life of my own child. It was their solution, not

mine. They claimed they did it out of com-

passion for me. But it was a false compas-

sion. A true compassion would result in the

fathers living up to their responsibilities. A

true compassion, once a mother is in the

predicament that the child’s father aban-

doned her, would advise her how to get help

and would provide her help. Unfortunately,

the legal right to an abortion was sought in

my case because others thought it was too

hard for them to give me real help. The abor-

tion was sought for them, not for me.

. But no matter how hard life happens to be,

no one has the right to kill a baby — espe-

cially the baby’s mother. Se is the trustee of

her child’s life. She, of all people, has the sa-

cred duty to protect the child. But the child’s

interests are not at odds with her own. They

are in concert with one another. The mother

derives a great benefit from her relationship

with her child. It is as beneficial to her as it

is the child. It is never in the interest of a

mother to terminate the life of her own child.

. I have been forced to live with the conse-

quence of this false compassion for too long

for me not to bring to the attention of the

Court the fact that abortion is not in a

woman’s interest, and the fact that legaliza-

tion of abortion began with manipulations

and misrepresentations. Too many women

who lost their children through abortion

App. 10

have told me of their emptiness, their sad-

ness, the void in their lives, and how others

forced them to have abortions and then

blamed the abortion on the mother.

20. The experience of Doe v. Bolton must be un-

derstood and accounted for, not simply to cor-

rect the record in my own case, but to correct

the law of abortion in general: abortion is not

in the interest of a mother. It is a false solu-

tion imposed upon a mother by others.

21. Doe v. Bolton and my circumstanced {sic]

were misused. Doe v. Bolton was a fraud

upon the court. Doe v. Bolton was a secret

case about abortion, which is a secret proce-

dure. This secretiveness allows others to

prevail upon the mother and others can act

against her interest. Women have told me

how they were forced to have an abortion

against their will. If it was alleged that I

spoke for other women in Doe v. Bolton, then

I gladly speak for other women in this case to

say that abortion is too coercive by nature;

too much the will of others; too much the will

of a society which finds abortion more con-

venient for it than a commitment to the well

being of the mother and the child.

22. The real experiences of the women must be

known and taken into consideration by the

court. Abortion is too much what others

would like a woman to do, rather than what

is in her interest and what she really wants.

App. ll

23. Others told the court that I wanted an abor-

tion. The law has developed, in part, based

upon what my lawyer claimed I wanted, and

that abortion was in my interest. I feel I

have the duty to tell this Court the truth

about what I really thought then, and what I

think now. As the Plaintiff in Doe v. Bolton, I

have a very substantial interest in the litiga-

tion before this court in the matter of Roe v.

Wade and I can provide the court a unique

perspective of the Doe v. Bolton case not

available from any other source.

24. In the 1970s the people closest to me success-

fully manipulated my circumstances to jus-

tify abortion and wanted me to have an

abortion, but I refused. Today this Court has

the opportunity to review, not just the real

facts surrounding the Roe v. Wade and Doe v.

Bolton, the original abortion decisions, but

the opportunity to review the testimony of

hundreds of women who have real, true, ex-

periences with abortion and not perpetuate

the Doe v. Bolton fraud upon the Court.

Further Affiant sayeth not.”

/s/ Sandra Cano

Sandra Cano a.k.a. Mary Doe of

Doe v. Bolton

App. 12

SWORN TO AND SUBSCRIBED BEFORE ME,

the undersigned authority, on this 12th day of Au-

gust, 2003.

/s/ Justin [Illegible]

NOTARY PUBLIC IN AND FOR

THE STATE OF GEORGIA

My commission expires:

Notary Public, Fulton County, Georgia

My Commission Expires Oct. 18, 2005

App. 13

APPENDIX B

Affidavit of Dr. Priscilla K. Coleman, Ph.D

TATE OF GE .

a OF GEORGIA 8 NOW ALL MEN BY

8 THESE PRESENTS:

COUNTY OF WOOD §

BEFORE ME, the undersigned authority, on this

day personally appeared Priscilla K. Coleman, Ph.D.

who is personally known to me, and after being by me

first duly sworn according to law on her oath did

depose and say that:

1. “My name is PRISCILLA K. COLEMAN. I am

over the age of eighteen (18) years of age and I reside

in Bowling Green, Ohio. I am fully competent to make

this Affidavit. I have personal knowledge of the facts

stated herein and the following is true and correct.

2. Iam a developmental psychologist and an Associ-

ate Professor of Human Development and Family

Studies at Bowling Green State University in Ohio. I

have written 44 peer-reviewed scientific articles (42

published to date), of which 29 arc on the psychology

of abortion.

3. The opinions expressed in the Affidavit are based

upon my education, professional experience, the

psychological research I have conducted, and my

extensive and ongoing review of the abortion and

mental health literature. The references in Exhibit A

and Tables 1-4 in Exhibit B list publications that

have been formative in shaping my opinions on the

App. 14

issues identified in this Affidavit, as well as other

publications too numerous to mention in my ongoing

review of the scientific literature.

Overview and Synopsis of Opinions

4. Over the course of my professional career, I have

spent approximately 18 years conducting research,

publishing the results of studies, analyzing the re-

search of others, and performing systematic reviews

of the literature for publication in peer-reviewed

journals. Based on the research I have done, it is my

opinion and I can say with a reasonable degree of

scientific and medical certainty that abortion is a

substantial contributing factor in women’s mental

health problems, including depression and increased

risk of death from suicide, natural causes and acci-

dental injury.

5. Scientific evidence accrued over the last two

decades and published in leading peer-reviewed

journals in psychology and medicine indicates that

abortion places women at an increased risk for de-

pression, suicidal ideation, suicide, and death in

general. Other well-established psychological difficul-

ties associated with abortion include anxiety and

substance use disorders. Women undergoing this

procedure often report additional adverse conse-

quences including unrelenting feelings of regret,

shame, guilt, bereavement/loss, and lowered self-

esteem. Many women withdraw from family and

friends, become preoccupied with the abortion, and

ata i i a i i ta tlh it ll crete

App. 15

develop a sense that their lives will never feel right

again.

6. Furthermore, pre-abortion counseling and _ in-

formed consent are key factors in post-abortion

difficulties. It is my opinion and research supports

that when a woman feels she was misinformed or

denied relevant information, this often precipitates

post-abortion difficulties.

7 Avoiding discussion of fetal development or using

terms like “tissue,” “blood,” “content of the uterus,” or

“a clump of cells” to refer to the fetus often encour-

ages consent that would not have been made if she

were told the truth. This deceitful practice denies

a woman the information a reasonably prudent

person would expect in considering whether or not to

pursue the abortion. Subsequently, if a woman ob-

tains truthful information concerning fetal develop-

ment, devastating psychological consequences become

more probable.

Suicide Ideation and Suicide

8. Abortion is a significant contributing factor in

suicidal ideation and suicide. In Table 1 of Exhibit B,

I provide a synopsis of the 6 available studies dealing

with abortion and suicidal behavior. When considered

in totality, the scientific criteria for isolating a signifi-

cant risk factor are sufficiently met. Abortion is a

consistent and strong risk factor for suicidal behavior.

The studies are all large scale, prospective in nature,

and they incorporate a variety of different types of

App. 16

comparison groups as well as additional control

techniques, effectively fortifying the level of confi-

dence in the results derived. In a review of the largest

and strongest published literature, Thorp and col-

leagues (2003) arrived at a similar conclusion.

Alcohol and Drug Abuse

9. Alcohol and drugs may be used as convenient

means for suppressing or blunting painful memories.

There are numerous obvious problems associated

with use of substances for coping with a painful

abortion experience. Specifically, it is likely to facili-

tate avoidance and hinder women from coming to

terms with the underlying cause of their discomfort.

Further, the many physical, psychological, social, and

practical problems associated with substance abuse

will in all likelihood introduce new sources of stress

which can exacerbate the traumatic impact of an

induced abortion.

10. There are numerous studies affirming associa-

tions between abortion and both depression and

substance abuse (reviewed below and in Tables 2 and

3, Exhibit B). Substance abuse, which constitutes a

dysfunctional coping response, and depression have

been long established as primary risk factors in the

etiology of suicidal ideation and behavior (Gliatto

& Rai, 1999). As indicated in the tables, the studies

meet the scientific criteria for establishing abortion

as a substantial, contributing factor in the etiology

of substance use and depression (time sequence,

App. 17

co-variation, control, and magnitude of effect). There-

fore, abortion is both directly and indirectly associ-

ated with suicidal ideation and suicide.

Mental Health Problems

11 Abortion is a significant contributing factor in

mental health problems. A minimum of 20-30% of

women who have had an abortion suffer from serious

negative psychological complications (Adler et al.,

1990; Bradshaw & Slade, 2003; Coleman, 2005;

Coleman et al., 2005; Lewis, 1997; Major & Cozza-

relli, 1992; Zolese & Blacker, 1992). With more than

1.3 million abortions performed annually in the U.S.,

using the conservative 20% figure would yield over

260,000 new cases of mental health problems each

year.

12. The results of the four largest, record-based

studies published to date have uniformly revealed

that abortion increases the risk of serious mental

health problems. In Denmark, David et al. (1981)

found the overall rate of admission for psychiatric

hospitalization was 18.4 and 12.0 per 10,000 for

women who had aborted and delivered respectively.

For those who were divorced, separated, or widowed,

the psychiatric admission rate was 63.8 per 10,000 for

women who aborted versus 16.9 for those who deliv-

ered. The outcome variable employed was admission

to a psychiatric hospital for a psychotic episode, a

worst case mental health outcome.

App. 18

13. In Canada, Ostbye, et al. (2001) compared

41,089 women with an abortic» history to a matched

group of 39,220 women without a history of abortion,

relative to hospitalization for psychiatric problems,

with the results revealing a 165% higher rate of

hospitalization for the abortion group.

14. The remaining two studies were conducted in

the U.S. using data from over 54,000 low-income

women on state medical assistance in California.

Women who had an abortion in 1989 with possible

subsequent pregnancies had significantly higher

rates of outpatient psychiatric diagnoses than women

with only birth experience in the target year and no

history of subsequent abortions after eliminating all

cases with psychiatric claims 12-18 months prior to

the initial pregnancy (Coleman et al., 2002). This

difference was apparent when data for the full time

period were examined (17% higher) and when only

data from women with claims filed on their behalf

within 90 days (63% higher), 180 days (42% higher), 1

year (30% higher), and 2 years (16% higher) of the

pregnancy event were considered. Across the 4 year

study period, the abortion group had 40% more

claims for depression compared to women who deliv-

ered. Data using the same sample and focusing on

inpatient claims revealed similar findings (Reardon

et al., 2003); this is the fourth study.

App. 19

Psychological Problems

15. In addition to these four studies, numerous

additional research reports have been _ published

throughout the world indicating that abortion is a

substantial contributing factor to decrements in

women’s mental health.

16. Abortion is a significant contributing factor in

specific psychological problems. The literature per-

taining to adverse psychological effects of abortion

has grown tremendously in the last two decades,

rendering it beyond the scope of this Affidavit to

describe in detail all the available evidence demon-

strating that abortion is a significant contributing

factor to negative psychopathologies. Therefore, in

Tables 3 and 4 of Exhibit B, I have provided synopses

of the published literature pertaining to depression

and anxiety. Application of the criteria for assessing

associations between variables definitively demon-

strates that within a reasonable degree of scientific

probability abortion is a significant contributing

factor in depression and anxiety. The analysis of

published research offered in this Affidavit further

shows that within a reasonable degree of scientific

probability abortion is a primary cause in many

women’s anguish and prolonged mental health strug-

gles.

17. I will highlight the results of one particularly

informative prospective study published in January

2006 by New Zealand researchers Fergusson, Hor-

wood and Ridder. Results of the Canterbury Health

App. 20

and Development Study published in the Journal of

Child Psychology and Psychiatry and Allied Disci-

plines revealed that young women who aborted were

at a significantly higher risk for depression, anxiety,

suicidal behaviors, and substance use disorders

compared to both women who carried a pregnancy to

term and those who were never pregnant.

18. The study was led by pro-choice researcher,

David Fergusson of the Christchurch School of Medi-

cine & Health Sciences who did not expect to find

adverse psychological consequences associated with

abortion. This study of 1,265 children born in Christ-

church in 1977 has a number of positive methodologi-

cal advantages over other studies: (a) it is

prospective, following women over many years; (b) it

used comprehensive mental health assessments

employing standardized diagnostic criteria of DSM

III-R disorders; (c) it reported considerably lower

estimated abortion concealment rates compared to

previously published studies; (d) the sample repre-

sented between 80 — 83% of the original cohort of 630

females; and (e) the study used extensive controls.

19. While 42% of the women who aborted reported

major depression by age 25, 39% of post-abortive

women suffered from anxiety disorders. In addition,

27% reported experiencing suicidal ideation, 6.8%

indicated alcohol dependence, and 12.2% were abus-

ing drugs. Compared to the pregnant/no abortion

group, the abortion group scored significantly higher

on all these variables except anxiety. Compared to the

App. 21

never pregnant group, the abortion group scored

significantly higher on all variables.

20. Dr. Fergusson and his colleagues challenged the

American Psychological Association’s recent assertion

that “well-designed studies of psychological responses

following abortion have consistently shown that risk

of psychological harm is low.” Dr. Fergusson noted

that this claim was based on a small number of

studies that suffer from significant methodological

problems as well as a general disregard for studies

showing negative effects.

21. Ten months after Fergusson’s study was pub-

lished, a prestigious group of psychiatrists and obste-

tricians wrote a letter to the London Times citing

the Fergusson study and advocating for more accu-

rate pre-abortion information dissemination: “Since

women having abortions can no longer be said to have

a low risk of suffering from psychiatric conditions

such as depression, doctors have a duty to advise

about long-term adverse psychological consequences

f abortion.”

Increased Risk for Negative Post-Abortion

Outcomes

22. There is a vast literature describing women at-

risk for negative abortion experiences. Among the

most commonly reported risk factors for poor adjust-

ment are difficulty with the decision, emotional

investment in the pregnancy, timing during adoles-

cence or being unmarried, involvement in unstable or

App. 22

violent relationships, conservative views of abortion

and/or religious affiliation, second trimester abor-

tions, and feelings of being forced into abortion by

one’s partner, others, or by life circumstances (Allan-

son, & Astbury, 2001; Bracken, 1978; Bracken et al.,

1974; Campbell et al., 1988; Cozzarelli et al., 1994;

Kero et al., 2004; Lewis, 1997; Lyndon et al., 1996;

Osofsky & Osofsky, 1972; Osofsky et al., 1973; Re-

mennick & Segal, 2001; Russo & Denious, 2001).

Internalized beliefs regarding the humanity of the-

fetus, moral, religious, and ethical objections to

abortion, and feelings of bereavement/loss also fre-

quently distinguish those who suffer profoundly (see

Coleman et al., 2005 for a review).

23. The percentage of women falling into “high-risk”

groups is in actuality quite high. For example, Hus-

feldt and colleagues (1995) reported that 44% of the

women surveyed had doubts about their decision

upon confirmation of pregnancy and 30% continued to

express doubts when the abortion date arrived.

24. If a woman has doubts about her abortion and

believes it was morally wrong, guilt feelings, which

are often implicated in depression are likely to arise.

Guilt associated with abortion has been consistently

reported (Broen et al., 2004) and identified in the pre-

abortion counseling literature (Baker et al., 1999).

Rue and colleagues’ (2004) study revealed that 78% of

U.S. women felt guilt in association with a past

abortion. Further, close to 50% of Russian women

who reside in a culture that is very accepting of

abortion reported guilt feelings.

App. 23

25. Kero et al. (2001) found that 46% of women who

aborted indicated that their thoughts regarding

termination evoked a conflict of conscience. The

source of such conflict is likely women’s understand-

ings of the humanity of the fetus. In Conklin and

O’Connor’s (1995) study of 800 women who had an

induced abortion, those who reported perceiving the

fetus as human experienced significantly more post-

abortion negative affect and decision dissatisfaction

than women who did not. Awareness of the humanity

of the fetus is common among women who are seri-

ously contemplating an induced abortion. For exam-

ple, using semi-structured interviews Smetana and

Adler (1979) found that 25% of women confronting an

induced abortion decision understood that the fetus

was a human being and understood induced abortion

as terminating his or her life. In a recent study

conducted by Rue et al. (2004), 50.7% of American

women and 50.5% of Russian women who had an

induced abortion felt induced abortion was morally ~

wrong.

26. The decision to abort is obviously often conflict-

ridden with many women seriously questioning their

decision and suffering from their choice to abort.

Coleman and Nelson (1998) noted that 38.7% of

female college students voiced regret in the first few

years following an abortion. Moreover, the results of a

study by Soderberg and colleagues (1998) indicated

that 76.1% of women who had a past abortion would

never consider repeating the experience.

App. 24

Pre-Abortion Counseling

27. The importance of pre-abortion counseling and

informed consent for women considering abortion has

been well-documented in the scientific literature. The

overwhelming preponderance of objective scientific

evidence published in prestigious academic journals

world-wide indicates that abortion does indeed pose

serious mental health risks and significantly in-

creases a woman’s chance of dying, particularly by

her own hand. These facts were known by the end of

2000 and earlier, and have been strongly reaffirmed

with studies since that time.

28. Rosa Acuna had the right to be informed of these

risks, as do all women who seek an abortion. Affirma-

tive statements that minimize the risks of mental

health problems are incorrect and should never be

made when the scientific/medical evidence is to the

contrary.

29. Criticism leveled against pre-abortion counsel-

ing has focused on insufficient assistance with the

decision-process (Butlet, 1996; Stites, 1982). Profes-

sionals will more effectively serve women by helping

them to avert a decision that can cause later suffering

through dissemination of accurate and objective

scientific information regarding the risk factors for

emotional problems, listening sensitively for any

feelings of ambiguity, and offering assistance that

facilitates the woman’s autonomous decision-making.

This idea was emphasized by Miller (1992, p. 91) who

stated that “a woman considering abortion who

App. 25

expresses enjoyment in being pregnant or the desire

to have a child to take care of deserves some pre-

abortion, exploratory counseling regarding these

teelings.” A related opinion was expressed by, Lemkau

(1991, p. 100) who noted “in a political environment

in which a woman’s right to choose abortion is con-

stantly challenged, it is easy to forget the importance

of the right to choose not to abort.”

30. Furthermore, professionals working with women

contemplating an abortion need to be encouraged not

to interject their own opinions regarding what they

perceive to be the best decision for an individual and

should help instill confidence in women to not yield to

pressures from others as they weigh their options.

Informed Consent

31. Unfortunately, many women who make the

decision to abort do so without a thorough under-

standing of the procedure. Research suggests that

feeling misinformed or being denied relevant infor-

mation often precipitates post-abortion difficulties

(Congleton & Calhoun, 1993; Franz & Reardon,

1992).

32. Provision of accurate information pertaining to

fetal development would help to insure that women

are making decisions that are consistent with their

beliefs and value systems. Avoiding discussion of fetal

development or using terms like “tissue,” “blood,”

“content of the uterus,” or “a clump of cells” to refer to

an embryo or fetus may seem to make the women’s

App. 26

decision easier, but it can often encourage a consent

that would not have been made if she were told the

truth. This deceitful practice is wrong as it denies

women the information a reasonably prudent person

would expect in considering whether or not to pursue

the medical procedure. Moreover, employment of

ambiguous, misleading language violates a woman’s

right to make a fully informed decision and leaves her

vulnerable to adverse outcomes, unanticipated at the

time of the decision.

33. If a woman obtains subsequent information,

contradicting that provided by the abortion facility

and used as the basis of her earlier abortion decision,

devastating psychological consequences become more

probable. This fact is one that has been known in the

medical profession for decades. In a 1980 letter

published by the New England Journal of Medicine,

this position is expressed by Riggs: “Women deserve

to know exactly what would be removed before they

make a decision. The doctor who protects them from

the facts to preserve them from anxiety and guilt has

made a moral decision on their behalf ... and to

deprive a woman contemplating abortion of a descrip-

tion of the fetus whether or not she requests it, is to

deprive her of truly informed consent” (p. 350).

34. In a paper published in the top-rated medical

ethics journal, The Journal of Medical Ethics, Reardon,

Lee, and I found that 95% of a socio-demographically

diverse group of women wished to be informed of all

possible complications associated with drugs, surgery,

and/or other forms of elective treatments, including

App. 27

abortion (Coleman et al., 2006). In addition, a fre-

quency of complications of 1:100 or higher would

factor into most women’s elective treatment decisions.

As indicated by Gissler and colleagues as a key point

in their 2005 article “Elevated mortality risk after a

terminated pregnancy has to be recognized in the

provision of health care and social services” (p. 462).

35. As previously noted, research firmly indicates

that when women feel they have been misinformed

regarding the specifics of an abortion procedure, they

are more inclined to suffer in the aftermath as they

acquire factual information (Congleton & Calhoun,

1993; Franz & Reardon, 1992).

Further Affiant sayeth not.”

/s/ Priscilla Coleman

Dr. Priscilla K. Coleman, Ph.D

SWORN TO AND SUBSCRIBED BEFORE ME,

the undersigned authority, on this 2nd day of May,

2008.

/s/ Karen Brueggemeier

NOTARY PUBLIC IN AND FOR

THE STATE OF OHIO

My commission expires: 5-29-11

Notary Public, Wood County, Ohio

App. 28

Exhibit A:

Scientific Literature Relied Upon in

Part in the Formation of My Opinions

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Russo, N. F., & Wyatt, G. E. (1990). Psychological

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and broken attachments: Violence, pregnancy, and

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151.

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first postnatal year. British Medical Journal, 302:

137-140.

Baker, A., Beresford, T., Halvorson-Boyd, G., & Gar-

rity, J. (1999). In Paul, M. et al. (eds). A Clinician’s

Guide to Medical and Surgical Abortion. New York:

Churchill Livingstone (a National Abortion Federa-

tion task force compendium).

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matic reactions to vacuum aspiration abortion. Social

Psychiatry, 13, 135-145.

Bracken, M. B., Hachamovitch, M., & Grossman, G.

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lae. Journal of Nervous and Mental Disease, 158, 155-

161.

App. 29

Bradshaw, Z., & Slade P. (2003). The effects of in-

duced abortion on emotional experiences and rela-

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abortion: Questions from a primary care physician.

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Campbell, N., Franco, K. & Jurs, S. (1988). Abortion

in adolescence. Adolescence, 23, 813-823.

Carroll, P. S. (2007). The breast cancer epidemic:

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risk factors. Journal of American Physicians and

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creased risk of substance use: A review of the evi-

dence. Current Women’s Health Reviews 1, 21-34.

Coleman, P. K., & Nelson, E. S. (1998). The quality of

abortion decisions and college students’ reports of

post-abortion emotional sequelae and abortion atti-

tudes. Journal of Social and Clinical Psychology, 17,

425-442.

Coleman, P. K., Reardon, D. C., & Lee, M. B. (2006).

Women’s preferences for information and ratings of

the seriousness of complications related to elective

App. 30

medical procedures. Journal of Medical Ethics, 32,

435-438.

Coleman, P. K., Reardon, D. C., Rue, V., & Cougle, J.

(2002). State-funded abortions vs. deliveries: A com-

parison of outpatient mental health ciaims over four

years. American Journal of Orthopsychiatry, 72, 141-

152.

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J. (2005). The psychology of abortion: A review and

suggestions for future research. Psychology & Health,

20, 237-271.

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perceptions: A comparison of self-identified distressed

and non-distressed populations. International Jour-

nal of Social Psychiatry, 39, 255-265.

Conklin, M. & O’Connor, B. (1995). Beliefs about the

fetus as a moderator of postabortion psychological

well-being. Journal of Social Psychiatry, 39, 76-81.

Cozzarelli, C., Karrasch, A., Sumer, N., & Major, B.

(1994). The meaning and impact of partner’s accom-

paniment on women’s adjustment to abortion. Jour-

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Weiss, N. S. (1994). Risk of breast cancer among

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App. 31

David, H., Rasmussen, N. & Holst, E. (1981). Post-

partum and postabortion psychotic reactions. Family

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mental health. Journal of Child Psychology and

Psychiatry, 47, 16-24.

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treatment of patients with suicidal ideation. Amert-

can Family Physician, 59.

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profiles of adolescents and young adults choosing

abortion. Adolescence, 27, 655-673.

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of abortion on adolescents and adults. Adolescence,

27, 161-172.

Gissler, M., et al. (2005). Injury deaths, suicides and

homicides associated with pregnancy, Finland 1987-

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463.

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on causality: a counterfactual perspective. Themes in

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M., & Pettersson, B. (1995). Ambivalence among

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App. 32

Khlat, M., Ronsmans, C. (2000). Deaths attributable

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Pierce, T. (1996). Pregnancy decision making as a

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nal of Personality and Soctal Psychology, 71, 141-151.

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App. 33

Martin, C. D. (1973). Psychological problems for the

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App. 34

and the medical and legal implications. The Journal

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Emotional distress following induced abortion: A

study of its incidence and determinants among

App. 35

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cal complications of therapeutic abortion. British

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Exhibit B

Tables 1-4

Table 1: Scientific Studies Identifying Abortion as a

TELS Factor in Su

1. Fergusson, D. M.,

Horwood, J., &

Ridder, E. M.

(2006). Abortion in

young women and

subsequent mental

health. Journal of

* Child Psychology

and Psychiatry, 47,

16-24.

oe Gilchrist, A. Cc

al (1995).

Termination of

pregnancy and

psychiatric

morbidity.

Journal of

Psychiatry 167:243-

British

Lag AeY at quay orth digg Wits ? + Sisal

ri Tit T Bee sai ni de tc ‘Co- “mati paai sida came! AAD, Oly get ea aicebe

te Atuences MY ariation: RENE a cigipnatareauerad Sa.

licidal ideation and Suicide.

nwa pannaulee/Taap ude. OF

weer effect

7. AROS ¥3: °

Pewee ote aca

Those who delivered

and were never

pregnant used as

comparison groups.

Statistical control for

maternal education

childhood sexual abuse,

physical abuse

Child neuroticism

Sclf-esteem

Grade point average

Child smoking

Prior history of

depression, anxiely

Prior history of suicide

ideation

Living with parents

| 3. Gisster, M., et al.

(1996). Suicides

after pregnancy in

Finland, 1987-94:

study. British

Medical Journal,

313, 1431-4

4. Gissler, M., et al.

(2005). Injury

deaths, suicides and

homicides

ussociated with

pregnancy, Finland

1987-2000.

European Journal of

Public Health,

459-463.

15,

27% of women who

aborted reported

expericncing suicidal

ideation This effect was

significant at the >.001

level, meaning there was

ona lin 1000 chance that

the result was due to

chance. ‘The risk was 4

times greater for women

who aborted compared to

never preynant women

and more than 3 times

greater than women who

for women who delivered

Living 4a iui ”

Comparisons included

women who were

refused abortion

and women who chose

abortion but changed

their minds

. skican

Among women with no

history of psychiatric

illness, the rate of

deliberate self-harm was

significantly higher (70%)

after abortion than

childbirth

—

Compared women who

aborted to those who

delivered, miscarried,

and the general

population

Suicide rate was nearly G

times greater among

women who aborted

compared to women who

gave birth

Compared women who

aborted to those who

delivered, miscarried,

and were not pregnant.

Distinguished the level

of risk associated with

suicide and other forms

of death.

Abortion was associated

with a 6 times higher risk

for suicide compared to

birth.

gg ‘ddy

pela iat

Fi : -Co--

"ER tS

< variation.”

cafepelts/. esha ean tae of

“effect - he tS

E. pre a D. C.. et

al. (2002). Deaths

associatcd with

delivery and

abortion among

California Medicaid

patients: A record

linkage study.

Southern Medical

Journal, 95, 834-841

Use of homogenous

population.

Controlled for prior

psychiatric history, age,

and months of

eligibility for state

medical coverage

Suicide risk was 154%

higher among women

who aborted compared to

those who delivered

6. Rue, V.M.,

Coleman, P. K.,

Rue, J. J., &

Reardon, D.C.

(2004). Induced

abortion and

traumatic stress: A

preliminary

comparison of

American and

Russian women.

Medical Science

Monitor 10, SR 5-

_16.

Controlled for severe

stress symptoms prior

to the abortion, other

stressors pre-and post-

abortion, several

demographic variables,

and psycho-social

variables (harsh

discipline, sexual,

physical, and emotional

abuse, parental divorce,

etc).

36.4% of the American

women and 2.8% of the

Russian women

respectively reported

suicidal ideation.

Lg ‘ddy

Table 2: Scientific Studies Identifying Abortion

as a Risk Factor in Substance Use/Abuse

| Time.

Sequence’

Con

variation | |:

“"]" Resuits/ Magnitude of effect |

. Amaro H.,

Zuckerman B, &

Cabral H. (1989).

Drug use among

adolescent

mothers: profile of

risk. Pediatrics,

S84, 144-151.

2. Coleman, P. K.

(2006). Resolution

of Unwanted

Pregnancy During

Adolescence

Through Abortion

versus Childbirth:

Individual and

Family Predictors

and

Consequences.

Journal of Youth

and Adolescence.

3. Coleman, P. K.,

Reardon, D. C.,

mue, V., &

Cougle, J. (2002).

IHistory of induced

abortion in

relation to

substance use

during subsequent

pregnancies

carried to tenn.

American Journal

of Obstetrics and

Gynecology, 187,

1673-1678.

Other forms of perinatal

loss as comparison

groups

Adolescent drug users when

compared to nonusers were

significantly more likely to

report a history of elective

abortion (33% vs. 16.3%).

No associations were identified

between drug use and parity or

other forms of perinatal loss

(miscarriage /stillbirth).

Demographic,

educational,

psychological, and

family variables found

to predict the choice to

abort

Exclusive focus on

unwanted pregnancies

After implementing controls,

adolescents with an abortion

history, when compared to

adolescents who had give birth

were 6 times more likely to use

Marijuana.

Results were stratified

by potentially

confounding factors

(marital status, income,

ethnicity, and time

elapsed since a prior

abortion or birth)

Compared with women who had

previously given birth, women

who aborted were significantly

more likely to use marijuana

(929%), various elicit drugs

(460%), and alcoho! (122%)

during their next pregnancy.

Differences relative to marijuana

and use of any elicit drug were

more pronounced among

married and higher income

woirnen and when more time had

elapsed since the prior

pregnancy.

Differences relative to alcohol

use were most pronounced

among the white women and

when more time had elapsed

since the prior pregnancy.

per eS SF

Set oP B

“‘Wariation @ [sends

oD atoms hate

[aREesalts/ Magnitude of

Mig sx $35 a eee

man, P. K.,

Reardon, D. C., &

Cougle, J. (2005)

Substance use

among pregnant

women in the

context of

reproductive loss

and desire for

current pregnancy.

British Journal of

Health

Psychology, 10,

255-268.

Other forms of loss

Age

Marital status

Trimester in which

prenatal care was

sought

Education

Number in household

No differences were observed in

the risk of using any of the

substances measured during

pregnancy relative to a prior

history of miscarriage or

stillbirth.

A prior history of abortion was

associated with a significantly

higher risk of using marijuana

(201%), cocaine-crack (198%),

cocaine-other than crack

(406%), any illicit drugs (180%),

and cigarettes (100%)

S. Reardon, D. C.,

Coleman, P. K., &

Cougle, J. (2004)

Substance use

associated with

prior history of

abortion and

unintended birth:

A national cross

sectional cohort

study.

Am. Journal of

Drug and Alcohol

Abuse, 26, 369-

383.

6. Fergusson, D.

M., Horwood, J.,

& Ridder, E. M.

(2006). Abortion

in young women

and subsequent

mental health.

Journal of Child

Psychology and

Psychiatry, 47,

16-24.

Aye

Eth city

Marital status

Income

Education

Pre-pregnancy self-

esteem and locus of

control

Maternal education

Childhood sexual

abuse, physical abuse

Child neuroticism

Self-esteem

Grade point average

Child smoking

Prior history of

depression, anxiety

Prior history of suicide

ideation

Living with parents

Living with partner

Compared to women who

carried an unintended first

pregnancy to terin, those who

aborted were 100% more likely

to report use of marijuana in the

past 30 days and 149% more

likely to use cocaine in the past

30 days (only approached

significance).

Women with a history of

abortion also engaged in more

frequent drinkir z than those who

carried an unintended pregnancy

to term.

Except for less frequent

drinking, the unintended

delivery yroup was not

significantly different from the

no pregnancy group

6.8% indicated alcohol

dependence, and 12.2% were

abusing drugs. By age 2S.

. Time =

. i 3% ° x 38 Pe Pee ~ Sis Sequence” Variation Hid FE * at eevee % eS & Bock 3 ca : £5 ait. pe Pe fuss Poe Se ie iiedo Spetmencbaems ey

7 V V V

gee a a» Controls for a wide Compared to adolescents who

rhea TI ‘ range of socioeconomic ended their pregnancies through

f lati )- Ses and demographic abortion, those who keep their

Bite adotesccint variables likely to babies experienced a dramatic

influence juvenile reduction in smoking and

regnancy, . “

bei sine delinquency. marijuana use

gna ;

resolution, and

juvenile

delinquency, 7he

Sociological

Quarierly, 44,

555-576. eee

8. Reardon ID.C., Ni

Ney, P.G. (2002)

Abortion and

subsequent

substance abuse.

American

Journal of Drug

and Alcohol Women who aborted a first

Abuse, 26, 61-75. pregnancy were 4 times more

likely to report substance abuse

compared to those who suffered

from a non-voluntary pregnancy

loss

Le Gon ay (ERT a Col trol: 5 Results/Magnitude of effect |

Controlled for Women who aborted a first

substance use prior to pregnancy were 5S times more

the abortion and age likely to report subsequent

substance abuse than women

who carried to term.

9. Yamaguchi D, Pt & J

aut es sem , The use of illicit drugs other

¢ d > eg — than marijuana was 6.1 times

ee ans ie ell higher among women witha

i ae aang history of abortion when

premarital

ES ROSEN ro compared to women without a

Pres y history.

outcome: A

dynamic analysis

of competing life

events. Journal of

Marriage and the

Family, 49, 257-

270.

Table 3:

Scientific Studies Identifying Abortion

as a Risk Factor in Depression.

HP ay

Times] 5

“sequence

-Co-;

eS etdan ii bes

control

akestey hd Maguicude oF =

3 effect’ debibsircseet

~~ IK. CF

cigeay Abortion and

subsequent

pregnancy.

Canadian Journal of

Psychiatry, 29, 494.

Women with and

without a history of

abortion had similar

demographic

characteristics, obstetric

experiences, and

attitudes about labor and

Women, who aborted, when

compared to women without

a history of abortion, were

significantly more likely to

report depressive affect

during pregnancy and in the

postpartum period.

2. Coleman, P.K.,&

Nelson, E.S.

(1998). The quality

of abortion decisions

and college students’

reports of post-

abortion cmotional

sequelae and

abortion attitudes.

Journal of Social

and Clinical

Psychology, 17, 425-

442.

birth.

Compared men and

women with abortion

experience.

‘Time elapsed since

abortion

Depression increased after

abortion: female: S6.7%;

male: 25.9%

3. Coleman, P. K.,

Reardon, D. C., Rue,

V., & Cougle, J.

(2002). State-funded

abortions vs.

deliveries: A

comparison of

outpatient mental

health claims over

four years. American

Journal of

Orthopsychiatry, 72,

141-152

4. Congicton, G. &

Calhoun, L. (1993).

Post-abortion

perceptions: A

comparison of self-

identified distressed

and non-distressed

populations.

International

Journal of Social

Psychiatry, 39, 255-

2065

“ig

Compurison groups

likely very similar

except for the abortion

experience

Controls for pre-

pregnancy psycho-

logical difficulties, age,

and months of eligibility

Across the 4-yrs, the abortion

OZ a

group had 40% more claims

for neurotic depression than

the birth group

Compared women who

self-identified as

distressed and non-

distressed only.

Depression reported in 20%

of women who aborted.

ol sequence.

Tete],

S. orn 5.

Reardon, D.C., &

Coleman, P. K.

(2003). Depression

associated with

abortion and

childbirth: A long-

term analysis of the

NLSY cohort

Medical Science

Monitor, 9, CR105-

112

6. Cozzarelli, C.

(1993). Personality

and self-efficacy as

predictors of coping

with abortion.

Journal of

Personality and

Social Psycholoxy,

65, 1224-1236.

Pe Fayote, F.O.,

Adcyemi, A.B.

Oladimeji, B.Y.

(2004). Emotional

distress and its

correlates. Journa/

of Obstetrics and

Gynecology, 5, 504-

oe.

8. Fergusson, D. M.,

Horwood, J., &

Ridder, F. M.

(2006). Abortion in

young women and

subsequent mental

health. Journal of

Child Psycholozy

and Psychiatry, 47,

16-24.

Controlled for prior

psychological state and

several other variables:

age, race, marital status,

divorce history,

education, and income

(stratification by

ethnicity, current marital

Status, and history of

divorce)

lised a matched control

group

Maternal cducation

Childhood sexual abuse,

physical abuse

Child neuroticism

Sclf-esteem

Cirade point average

Child smoking

Prior history of

depression, anxiety

Prior history of suicide

ideation

Livings with parents

Living with partner

Women whose 1*

pregnancies ended in abortion

were 65% more likely to

score in the “high-risk” range

for clinical depression.

Differences Between the

abortion and birth groups

were greatest among the

demographic groups least

likely to conceal! an abortion

(White: 79% higher risk;

married: 116% higher risk;

marriage didn’t end in

divorce: 119% higher risk).

3 weeks after the abortion,

depression was higher than

zencral population norms, but

lower than psychiatric norms.

Previous abortion was

significantly associated with

depression among the

preznant women

—y

42% of the women who had

aborted reported major

depression by age 2S.

ea He ‘scquance.

pResulte/magnieuas Fs

Se effect + sigs

“9. tistoo E | 2 as oe

Cohen, L. S., Otto,

M. W., Spiegelman,

D., & a ae D. W.

(2004). Early life

menstrual

characteristics and

pregnancy

experiences among

women with and

without major

depression: the

Harvard Study of

Mood and Cycles.

Journal of Affective

Disorders, 79,

167176.

10. Major, B.,

Cozzarelli, C.,

Cooper, M.L.,

Zubek, J., Richards

C., Wilhite, M., &

CGramzow, R.H.

(2000).Psych

ological responses

of women after

first trimester

abortion. Archives of

General Psychiatry,

S7, 777-84.

11. Major, B.

Cozzarelli,

C., Sciacchitano,

A. M., Cooper, M.

i_., Testa, M., &

Mueller, P.M.

(1990). Perceived

social support,

self-efficacy, and

adjustment to

abortion. Journal of

Personality and

Social Psychology,

S59, 186-197.

Employed demographic

controls (age, age at

menarche, educational

attainment, and history

of marital disruption

Compared to women with no

history of induced abortion,

those with two or more were

2-3 times more likely to have

a lifetime history of major

depression at study

enrollment.

When only antecedent

induced abortions were

compared to no history of

abortion, there was a three

fold increase risk of

developing depression later in

life.

Controls for

demographic

characteristics,

medical

complications, and

prior mental health

—+——

Two years post-abortion,

28% were not satisfied with

their decision, 31% would not

have the abortion

again, and 20 % were

depressed.

Younger age and having more

children pre-abortion

predicted more negative post-

abortion outcomes.

—

Immediately after abortion

Mild depression 21%

Modcrate depression 11%

Severe depression 4%

ep ‘ddy

ey:

2 sie aes wy

a ime- OER

“Sequence ®

. Co-

“Wariation |

» Control...

Sinatat ch 1A otk abaonll OF

_effect™ eo

T2. "Milles, Ww. 'B.

Pasta, D. J.,

C. L. (1998).

Testing a model of

the psychological

consequences of

abortion. In L. J.

Beckman and S. M.

Harvey (eds)., The

new civil war: The

psychology, culture,

and politics of

abortion.

Washington, DC:

American

Psychological

Association.

& tiie:

13. Pope, L. M.,

Adler, N. E., &

Tschann, J. M.

(2001). Post-

abortion

psychological

adjustment: Are

minors at increased

risk? Journal of

Adolescent Heaith,

29, 2-11.

2 weeks post-abortion: 29.5%

felt some guilt, 36.6%

experienced some depression,

30.4% reported mood

problems, 17.3% reported

decreased relationship

satisfaction, and 26.9%

reported decreased interest in

sex.

6-8 weeks post-abortion:

35.9% felt some guilt, 35.9%

experienced some depression,

30% reported mood

problems, 22% reported

decreased relationship

satisfaction, and 26%

reported decreased interest in

pp dy

14. Reardon, D. li

& Cougle, J. (2002)

Depression and

Unintended

Pregnancy in the

National

Longitudinal Survey

of Youth: A cohort

Study. British

Medical Journal,

324, 151-152.

Compared current

sample results with

those reported in other

studies using similar

samples..

Confined analyses to

unintended pregnancy

aborted or delivered.

Controls for the

following: prior

psychiatric state, family

income. Education,

age at first pregnancy

Stratified by marital

status

race,

Sex.

19% experienced moderate to

severe levels of depression 4

wecks post-abortion.

The percentage of women

who carried to term

considered to be in the high-

risk range for depression was

22.7% compared to 27.3% of

women who aborted

(OR=1.54)

Among married women, the

percentage of women who

carried to term considered to

be in the high-risk range for

depression was 17.3%

compared to 26.2% of women

who aborted (OR=2.38)

sieciataal

‘Af izaia pe SPR pecs

Variation. .}... secs:

7 Resuie/Ma

Bl etalon

Cougle, J., Rue, V.

M., Shuping, M.,

Coleman, P. K., &

Ney, P. G. (2003).

Psychiatric

admissions of low-

income women

following abortion

and childbirth.

Canadian Medical

Association Journal,

168, 1253-1256.

Comparison groups are

likely very similar

except for the abortion

experience.

Controls for pre-

pregnancy psych-

ological difficulties, age,

and months of eligibility

Extended time frame

Across the 4-yrs, the abortion

group more claims for

depressive disorders

compared to the birth group,

with the percentages equaling

90%, 110%, and 200% for

depressive psychosis, single

and recurrent episode. and

bipolar disorder respectively.

16. Schmicge, S., &

Russo, N. F. (2005).

Depression and

unwanted first

pregnancy:

Longitudinal cohort

study. British

Medical Journal

17. Slade, P., Heke,

S., Fletcher, J., &

Stewart, P. (1998).

A comparison of

medical and surgical

methods of

termination of

pregnancy: Choice,

psychological

consequences, and

satisfaction with

care. British Journal

of Obstetrics and

Gynecology, 10S,

1288-1295.

Age

Age at first pregnancy

1992 marital status

Education

Family income

Percent of women exceeding

the depression cut-off score

on the Center for

Epidemiological Studies

depression scale after an

abortion:

Married White women: 16%

Married Black women: 24%

Unmarried White women:

30%

Unmarried Black women:

38%

Non-Catholic: 27%

Catholic: 20%

1 month post-abortion:

Cases of depression: 9%

Results/ Magnitude of:

18. Séderberg H,

Janzon L and

Sjéberg NO (1998).

Emotional distress

following induced

abortion. A study of

its incidence and

determinants among

abortees in Malmé6,

Sweden. European

Journal of

Obstetrics.and

Gynecology and

Reproductive

Biology 79, 173-8

Utilized a case control

data analysis strategy

50-60% of the women

experienced emotional

distress of some form (e.g.,

mild depression, remorse or

guilt feelings, a tendency to

cry without cause, discomfort

upon meeting children),

classified as severe in 30% of

cases.

76.1% said that they would

not consider abortion again

(suggesting indirectly that it

was not a very positive

experience).

19. Suri, R,

Altshuler, L.,

Hendrick, V. et al.

(2004). The impact

of depression and

fluoxetine treatment

on obstetrical

outcome. Archives

of Women’s Mental

Health, 7, 193-200.

46 women with a history of

depression had a significantly

higher mean number of prior

therapeutic abortions than 16

women without a history of

depression (.78 vs. .31). The

mean number of prior

pregnancies and spontaneous

abortions did not differ.

20. Urquhart D.R.,

& Templeton, A. A.

(1991). Psychiatric

morbidity and

acceptability

following medical

and surgical

methods of induced

abortion. British

Journecl of

Obstetrics and

Gynecology, 98,

396-399.

Clinically significant feelings

of depression at 1 month post-

abortion by 10% of the

sample.

Table 4: Scientific Studies Identifying Abortion

as a Risk Factor in Anxiety Disorders.

Be Ap Rta

, pha 2 E i idan ea

‘wariation

Sige SS $5 ASS

Set ioe

3 Controbe es

|} Results/ Magnitude of «—

effect

I. Broen, A.N.,

Moum, T., Bodtker,

A. S., & Ekebergy, O.

(2004).

Psychological

impact on women of

miscarriage versus

induced abortion: A

2 year follow-up

study.

Psychosomatic

Medicine, 66, 265-

: es Ss

Number of children

Marital status

Vocational status

10 days after the pregnancy

ended, 30% of those who

had an abortion scored high

on measures of avoidance

or intrusion, which includes

symptoms such as

flashbacks and bad dreams.

2 years after the pregnancy

ended, nearly 17% of 80

women who had an

abortion scored highly on a

scale measuring avoidance

symptoms, compared with

about 3% of those who

2. Broen, A.N.,

Moum, T., Bodtker,

A. S., & Ekeberg, O.

(2005). Reasons for

induced abortion and

their relation to

women’s emotional

distress: a

prospective, two-

vear follow-up

study. General

Hospttal Psychiatry,

27, 36-43.

Marital status

Psychiatric history

miscarried.

Male pressure on women to

abort was significantly

associated with negative

abortion-related emotions

in the two years following

an abortion.

Pre-abortion psychiatric

history was not

significantly related to

immediate negative

abortion related emotion or

with negative emotional

responses measured at 2

years out.

23.8% of the sample scored

high on The Impact of

Events Scale (a measure of

stress reactions after a

traumatic event) 10 days

after the abortion, 13.3% at

6 months, and 1.4% after 2

years

een Sr ae pial Bd

ait pantie vis cE

ey ta PYaET, Hicks tok thaehaae naan soceaetina

i Results/Magnitude of

setts ® aatrantte aes sitaaas effect* por

a's 3 a oka 3 eh rash: th 3

3. Coleman, P. K. a

Nelson, E.S.

(1998). The quality

of abortion decisions

and college students'

reports of post-

abortion emotional

sequelae and

abortion attitudes.

Journal of Social

and Clinical

Psychology, 17, 425-

442.

Gender: Compared

men and women with

abortion experience.

Time elapsed since

abortion

Anxiety increased after the

abortion: female: 13.3%;

male: 9.7%

4. Cougle, J.,

Reardon, D. C.,

Coleman, P. K., &

Rue, V. M.

(2005).General-ized

anxiety associated

with unintended

pregnancy: A

cohort study of the

1995 National

Survey of Family

Growth.

Journal of Anxiety

Disorders, 19, 137-

142

All women were

experiencing an

unintended pregnancy

Stratification by

ethnicity, current

marital status, and

age.

The odds of experiencing

subsequent Generalized

Anxiety was 34% higher

among women who aborted

compared to delivered.

Greatest differences among

the following demographic

groups: Hispanic: 86%

higher risk, Unmarried at

time of pregnancy: 42%

higher risk; under age 20:

46% higher risk.

5. Fayote, F.O.,

Adeyemi, A.B.,

Oladimeji, B.Y.

(2004). Emotional!

distress and its

correlates. Journal

of Obstetrics and

Gynecology, 5, 504-

509.

Used a matched

control group

6. Fergusson, D. M.,

Horwood, J., &

Ridder, E. M.

(2006). Abortion in

young women and

subsequent mental

health. Journal of

Child Psychology

and Psychiatry, 47,

16-24.

Maternal education

Childhood sexual

abuse, physical abuse

Child neuroticism

Self-esteem

Grade point average

Child smoking

Prior history of

depression, anxiety

Prior history of

suicide ideation

Living with parents

Living with partner

Previous abortion was

significantly associated

with anxiety among the

pregnant women

“J

39% of post-abortive

women suffered from

anxiety disorders by age

a5.

Tee eh HEHE Sa iit ih i OOET ST adeeb ‘Results / Magnitude. of

study... itmRiee we Pe eee hee pi : Me “te 7 4

t Qe owiek ‘jah

Fededt han ea Pe eld Rosai ha wrath sequence’ ah ‘variation: , dP Fy Od ene Shee yy tg } HOHE TR ria Pesan on -effect:: ran Abbie

7. L-atmioel, P., i i VV

Rager-Achim, D.» Random sample of the Before the abortion, 56.9%

Achim, A., & Boyer, general population of of women and 39.6% of

R. (2000). ; reproductive age used men were much more

Emotional distress as the control group distressed than their

RUS scuptes. respective controls.

involved in first

trimester abortions. Three weeles after the

Canadian Family abortion, 41.7% of women

Physician, 46, 2033- and 30.9% of men were

tonietiaty a still highly distressed.

8. Major, B.,&

<sramZow, Two years after abortion:

R. Fi. : Intrusive thoughts

(i972). Abortion - quite a bit: 3%

wiht — - some intrusive thoughts:

Cognitive 62%

and emotional

implications of

concealment.

Journal

of Personality

and Social

Psychology ,77,

735-745 Me ie

9. Sivuha, S. J

ecard of 35% of women had some

eres Streas postiraumatic consequences

oasemaboantel Following of abortion (elevated

Abortion in 7 avoidance, intrusion, or

Somer ey eet hyper-arousal scores)

Union Country.

Journal of Prenatal 46% of women had

& Perinatal Psych evidence of PTSD.

& Health, 17, 41-61 exceeding the cut-offs for

(2002). both intrusion and

avoidance subscales

22% of women experienced

PTSD, exceeding the cut-

as ; ae PPE ie offs on all 3 subscales

10. Pope, L. M., ~/ VV

Adier, N. E., & Compared current Impact of Events Scale —

Tschann, J. M. sample results with Intrusion Subscale (a

(200 1). Post- those reported in other measure of stress

abortion : studies using similar associated with a traumatic

psychological samples. event) score = 13.46, which

eeemest: erated is similar to adults

Se increased experiencing a recent

ant sowed! af arental bereavement

Adolescent Health, ” . :

an, 2-1.

acelin Bia:

ened Pens WU aT Weare

sequence:

Min COBB E

wariation. ;

* sige h Cp he i

jo Results/ Magnitude of,

os @ffect

11. Rue, V. M.,

Coleman, P. K.,

Rue, J. J., &

Reardon, D. C.

(2004). Induced

abortion and

traumatic stress: A

preliminary

comparison of

American and

Russian women.

Medical Science

Monitor 10, SR 5-

16.

Extensive controls for

background variables:

- Severe stress

symptoms prior to the

abortion

- Other stressors pre-

and post-abortion

- Several demographic

variables

- Psycho-social

variables (harsh

discipline, abuse,

parental divorce, etc).

The percentages of Russian

and U.S. women who

experienced 2 or more

symptoms of arousal, | or

more symptom of re-

experiencing the trauma,

and 1 or more experience

of avoidance (consistent

with DSM-IV diagnostic

criteria for PTSD) were

equal to 13.1% and 65%

respectively.

i2. Slade, P., Heke,

S., Fletcher, J., &

Stewart, P. (1998).

A comparison of

medical and surgical

methods of

termination of

pregnancy: Choice,

psychological

consequences, and

satisfaction with

care. British Journal

of Obstetrics and

Gynecology, 105,

1288-1295.

1] month post-abortion:

Cases of anxiety: 27%

13. Williams, G. B.

(2001). Short-term

grief after an

elective abortion.

Journal of

Obstetrics,

Gynecologic, and

Neonatal Nursing,

30, 174-183.

Controlled for other

forms of loss and

psychiatric history

Used a control group

of women who had

not aborted

Women with a history of

elective abortion

experienced more grief in

terms of loss of control,

death anxiety, and

dependency than controls.

14. Urquhart D.R.,

& Templeton, A.’A.

(1991). Psychiatric

morbidity and

acceptability

following medical

and surgical

methods of induced

abortion. British

Journal of

Obstetrics and

Gynecology, 98,

| 396-399.

Clinically significant

feelings of anxiety at I

month post-abortion by

10% of the sample.

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