Cases like Griswold v. Connecticut, 381 U.S. 479 (1965) (right of married persons to obtain contraceptives)1*; Lawrence v. Texas, 539 U.S. 558 (2003) (right to engage in private, consensual sexual acts); and Obergefell v. Hodges, 576 U.S. 644 (2015) (right to same-sex marriage), are not at issue. as Amici Curiae 3234 (Brief for 547 Deans). If any person, with intent to procure the miscarriage of any woman, shall unlawfully administer to her any poison, drug or substance whatsoever, or shall unlawfully use any instrument, or other means whatsoever, with the like intent, such person shall be guilty of felony, and being thereof convicted, shall be sentenced to pay a fine not exceeding five hundred dollars, and undergo an imprisonment, by separate or solitary confinement at labor, not exceeding three years.89, Sec. See Brief for Petitioners 1213; see also Brief for American Historical Association etal. The law at issue allows abortions up through fifteen weeks, providing an adequate opportunity to exercise the right Roe protects. Gonzales, 550 U.S., at 172 (Ginsburg, J., dissenting); see supra, at 2324. Indeed, all women now of childbearing age have grown up expecting that they would be able to avail themselves of Roes and Caseys protections. It also resembles general standards that courts work with daily in other legal sphereslike the rule of reason in antitrust law or the arbitrary and capricious standard for agency decisionmaking. The majority briefly refers to arguments about changes in laws relating to healthcare coverage, pregnancy discrimination, and family leave. See supra, at 3; see generally D. Cohen, G. Donley, & R. Rebouch, The New Abortion Battleground, 123 Colum. 1775) (Blackstone); E. Coke, Institutes of the Laws of England 50 (1644). The argument was cast in different terms, but stated simply, it was essentially as follows. In urging our review, Mississippi stated that its case was an ideal vehicle to reconsider the bright-line viability rule, and that a judgment in its favor would not require the Court to overturn Roe v. Wade, 410 U.S. 113 (1973), and Planned Parenthood of Southeastern Pa. v. Casey, 505 U.S. 833 (1992). Nothing that has happened in this country or the world in recent decades undermines the core insight of Roe and Casey. 1 The majority contends that nothing like [my approach] was recommended by either party. Ante, at 72. In support of its holding, the Court cites three seminal constitutional decisions that involved overruling prior precedents: Brown v. Board of Education, 347 U.S. 483 (1954), West Virginia Bd. Glucksberg, 521 U.S., at 721; cf. 920, 926, 947 (1973) (Ely) (emphasis deleted). For this reason, it is essential that this Court maintain the power to restore authority to its proper possessors by correcting constitutional decisions that, on reconsideration, are found to be mistaken. Thornburgh, 476 U.S., at 787 (dissenting opinion). And because such dramatic change had occurred, the public could understand why the Court was acting. In the Fourteenth Amendments terms, it takes away her liberty. After surveying history, the opinion spent many paragraphs conducting the sort of fact-finding that might be undertaken by a legislative committee. See Kaiser Family Foundation (Kaiser), G. Weigel, L. Sobel, & A. Salganicoff, Understanding Pregnancy Loss in the Context of Abortion Restrictions and Fetal Harm Laws (Dec. 4, 2019), https://www.kff.org/womens-health-policy/issue-brief/understanding-pregnancy-loss-in-the-context-of-abortion-restrictions-and-fetal-harm-laws/. Utah became a State in 1896. . And it has given rise to no more conflict in application than many standards this Court and others unhesitatingly apply every day. Earlier this Term, this Court signaled that Mississippis stratagem would succeed. All of the University of Californias library collections are accessible through UC Library Search. The most common format is the Bluebook, but you may also need to use other formats, such as the ALWD Citation Manual. #CornellLawClinics. of Health, 497 U.S. 261, 269 (1990) (Every adult has a right to determine what shall be done with his own body). In this country, the historical record is similar. 2061 (2022).12. See, e.g., Gonzales, 550 U.S., at 145146. The Supremacy Clause protects a persons right to an equal opportunity and freedom, ensuring that all Americans have access to these rights. Oklahoma became a State in 1907. How is it that our Constitution subjects discrimination against them to heightened judicial scrutiny? p. 233 (emphasis added and deleted). 1 Blackstone 69. I agree that this rule should be discarded. Accordingly, we should eliminate it from our jurisprudence at the earliest opportunity. One piece of evidence on that score seems especially salient: The majoritys cavalier approach to overturning this Courts precedents. As for lower courts, there is now a one-year-old, one-to-one Circuit split about how the undue burden standard applies to state laws that ban abortions for certain reasons, like fetal abnormality. For this reason, the Court has been reluctant to recognize rights that are not mentioned in the Constitution. One is the state of neonatal care at a particular point in time. See generally Dellapenna 215228 (collecting cases). The United States Code (U.S.C.) But the majority vastly overstates the divisions among judges applying the standard. Legal Information Institute, Cornell University Law School Wex is a free legal dictionary and encyclopedia sponsored and hosted by the Legal Information Institute at the Cornell Law School. Id., at 852. For example: In a recent article, John Doe argues that the sky is blue. It has considered fundamental constitutional principles, the whole course of the Nations history and traditions, and the step-by-step evolution of the Courts precedents. For the full text of law review articles, visit the Nexis Uni (formerly LexisNexis Academic) site, WestlawNext (formerly LexisNexis Academic), and HeinOnline. See Ramos, 590 U.S., at ___ (opinion of Kavanaugh, J.) : //www.bing.com/ck/a > citing < /a > apa Citation style & p=e74c428fc91c991f20362ca20938658d517e88a388eaef0154d41b1d38cbea99JmltdHM9MTY1MzUyNTkzMSZpZ3VpZD1kYzBlYmJjMy0xMWYxLTRhZTItODRkMy05MDhhOGY3OTM3NzUmaW5zaWQ9NTI3Mw & ptn=3 & fclid=2487fff1-dc8d-11ec-a7bd-cf506b70bdc8 u=a1aHR0cHM6Ly9lbi53aWtpcGVkaWEub3JnL3dpa2kvQ29ybmVsbF9Vbml2ZXJzaXR5X0xhdw! But the insistence on quickening was not universal, see Mills, 13 Pa., at 633; State v. Slagle, 83 N.C. 630, 632 (1880), and regardless, the fact that many States in the late 18th and early 19th century did not criminalize pre-quickening abortions does not mean that anyone thought the States lacked the authority to do so. And the difficulty of applying Caseys new rules surfaced in that very case. Side of the page see additional Resources: Legal Information Institute at Cornell Law School, specializing in Property!, etc citations '' link on the University that provides an exceptional education for undergraduates graduate! Westlake, Ohio 44145. Accordingly, those cases do not support the right to obtain an abortion, and the Courts conclusion that the Constitution does not confer such a right does not undermine them in any way. Or to put it more simply: Everyone, including women, owns their own bodies. With sorrowfor this Court, but more, for the many millions of American women who have today lost a fundamental constitutional protectionwe dissent. . Cite Primary tabs. Then we have a duty to overrul[e] these demonstrably erroneous decisions. Ante, at 3. 85 1858 Iowa Acts p. 93 (codified in Iowa Rev. cite To cite means to make reference to an authority in a citation. Our law in this constitutional sphere, as in most, has for decades upon decades proceeded differently. Must a state law allow abortions when necessary to protect a womans life and health? 25. Ante, at 1516. Despite Roes weaknesses, its reach was steadily extended in the years that followed. Id., at 154. 96 1868 Md. Cornell Law School offers one of the country's oldest and most distinguished programs in international and comparative legal education. Moreover, we are aware of no common-law case or authority, and the parties have not pointed to any, that remotely suggests a positive right to procure an abortion at any stage of pregnancy. 163, 42 U.S.C. 18022(b)(1)(D). And even if we could foresee what will happen, we would have no authority to let that knowledge influence our decision. The dissent does not identify any pre-Roe authority that supports such a rightno state constitutional provision or statute, no federal or state judicial precedent, not even a scholarly treatise. In sum, the majority can point to neither legal nor factual developments in support of its decision. Georgia Stanway Net Worth, See ante, at 5, 13, 36. A multitude of decisions supporting that principle led to Roes recognition and Caseys reaffirmation of the right to choose; and Roe and Casey in turn supported additional protections for intimate and familial relations. Stare decisis is rooted in Article III of the Constitution and is fundamental to the American judicial system and to the stability of American law. as Amici Curiae 2527. Sidne Norman, President of the Black Law Students Association Automobile Ins. Peter Martin and Tom Bruce from Cornell Law School pioneered the development of the Free Access to Law Movement around the world. Nor does it identify any other point in a pregnancy after which a State is permitted to prohibit the destruction of a fetus. 43, 509 (1865). Cornell Law Schools Frank H.T. In interpreting what is meant by the Fourteenth Amendments reference to liberty, we must guard against the natural human tendency to confuse what that Amendment protects with our own ardent views about the liberty that Americans should enjoy. To be sure, in reaffirming the right to an abortion, Casey termed the viability rule Roes central holding. 505 U.S., at 860. The right Roe and Casey recognized does not stand alone. The ACA also prohibits annual limits, see 300gg11, and limits annual cost-sharing obligations on such benefits, 18022(c). Those cases safeguard particular choices about whom to marry; whom to have sex with; what family members to live with; how to raise childrenand crucially, whether and when to have children. The weaknesses in Roes reasoning are well-known. Recall that at the time of the adoption of the Fourteenth Amendment, over three-quarters of the States had adopted statutes criminalizing abortion (usually at all stages of pregnancy), and that from the early 20th century until the day Roe was handed down, every single State had such a law on its books. It adhered to the law in its analysis, and it reached the conclusion that the law required. The Solicitor General suggests that overruling Roe and Casey would threaten the protection of other rights under the Due Process Clause. The Australian Legal Information Institute and various other Legal Information Institutes (LIIs) were established by adopting the Montreal Declaration at the Law via Internet Conference held in 2002. This certificate program is designed to help current and aspiring human resource managers and staff understand employment laws and regulations in order to deal effectively with labor-related legal issues in the workplace. They include bodily integrity, personal autonomy in matters of family, medical care, and faith, Brief for Respondents 21, and womens equal citizenship, Brief for United States as Amicus Curiae 24. Closing our eyes to the suffering todays decision will impose will not make that suffering disappear. Commonwealth v. Wheeler, 315 Mass. The majoritys response to these obvious points exists far from the reality American women actually live. 439 U.S., at 388389. The rest of the cited cases were relatively minor in their effect, modifying part or an application of a prior precedents test or analysis. 3334.47. From Nolo s educational pedigree using Law School < /a > 1 fairly simple is! Post, at 4445. First, if the long sweep of history imposes any restraint on the recognition of unenumerated rights, then Roe was surely wrong, since abortion was never allowed (except to save the life of the mother) in a majority of States for over 100 years before that decision was handed down. in reliance on the availability of abortion in the event that contraception should fail and that [t]he ability of women to participate equally in the economic and social life of the Nation has been facilitated by their ability to control their reproductive lives. Ibid. I write separately to explain my additional views about why Roe was wrongly decided, why Roe should be overruled at this time, and the future implications of todays decision. But simply declaring it does not make it so. So without support in history or relevant precedent, Roes reasoning cannot be defended even under the dissents proposed test, and the dissent is forced to rely solely on the fact that a constitutional right to abortion was recognized in Roe and later decisions that accepted Roes interpretation. 14, 1; see McDonald, 561 U.S., at 806 (opinion of Thomas, J.). the Constitution. The Role of the Supreme Court in American Government 113114 (1976). Id., at 165. Cf. The Legal Information Institute at Cornell University Law School (www.law.cornell.edu/supremecourt/text/347/483/USSC_PRO_4178_483_1). The viability line is a separate rule fleshing out the metes and bounds of Roes core holding. Substantive due process is the core inspiration for many of the Courts constitutionally unmoored policy judgments. It is settled now, the Court saidthough it was not always sothat the Constitution places limits on a States right to interfere with a persons most basic decisions about family and parenthood, as well as bodily integrity. Id., at 849 (citations omitted); see id., at 851 (similarly describing the constitutional protection given to personal decisions relating to marriage, procreation, contraception, [and] family relationships). It is therefore important to set the record straight. Curious about what life is like for a student at Cornell Law? See id., at 871 (The womans right to terminate her pregnancy before viability is the most central principle of Roe v. Wade. The Court also made no real effort to remedy one of the greatest weaknesses in Roes analysis: its much-criticized discussion of viability. Ante, at 23, 5, 7, 1112 (concurring opinion). Private Sector; Judicial Clerkships. Law School Alumni. See 410 U.S., at 163164; see also J. Ely, The Wages of Crying Wolf: A Comment on Roe v. Wade, 82 Yale L. J. As I see it, the dispositive point in analyzing American history and tradition for purposes of the Fourteenth Amendment inquiry is that abortion was largely prohibited in most American States as of 1868 when the Fourteenth Amendment was ratified, and that abortion remained largely prohibited in most American States until Roe was decided in 1973. 17231724. 16 The Courts words were as follows: This right of privacy, whether it be founded in the Fourteenth Amendments concept of personal liberty and restrictions upon state action, as we feel it is, or, as the District Court determined, in the Ninth Amendments reservation of rights to the people, is broad enough to encompass a womans decision whether or not to terminate her pregnancy. 410 U.S., at 153. He joined the Cornell Law School Faculty in 1972, and served as Dean from 1980 to 1988. Respondents and their amici have no persuasive answer to this historical evidence. 153, 3334 (1846) (emphasis added). This guide provides links to free, useful legal research tools and databases on the web. 2. There would be turmoil until we did so, according to the Court, because of existing state laws with shorter deadlines or no deadline at all. Ante, at 76. Skipping over that question, the controlling opinion in Casey reaffirmed Roes central holding based solely on the doctrine of stare decisis, but as we will explain, proper application of stare decisis required an assessment of the strength of the grounds on which Roe was based. So too, after todays ruling, some States may compel women to carry to term a fetus with severe physical anomaliesfor example, one afflicted with Tay-Sachs disease, sure to die within a few years of birth. Code, ch. When that contestation takes placebut when there is no legal basis for reversing coursethe Court needs to be steadfast, to stand its ground. When the Court reconsidered Roe in Casey, it left no doubt about the importance of the viability rule. and Finances, Join Lawyer halted a political process that was moving in a reform direction and thereby, I believed, prolonged divisiveness and deferred stable settlement of the issue). Those legal concepts, one might even say, have gone far toward defining what it means to be an American. It was settled at the time of Roe, settled at the time of Casey, and settled yesterday that the Constitution places limits on a States power to assert control over an individuals body and most personal decisionmaking. See Center for Reproductive Rights, The Worlds Abortion Laws (Feb. 23, 2021), https://reproductiverights.org/maps/worlds-abortion-laws. Pregnancy Recognition 39. 255, 258 (1834); Thellusson v. Woodford, 4 Ves. Professor Martin co-founded Cornell's Legal Information Institute (LII) with Thomas R. Bruce in 1992, the first Internet law resource and still the most heavily used non-profit legal Web site. See Pierce, 268 U.S. 510 (right to send children to religious school); Meyer, 262 U.S. 390 (right to have children receive German language instruction). See ibid. This system is designed to promote clarity and consistency in legal writing, and to make the process of researching and citing legal materials more efficient. The issue before this Court is what the Constitution says about abortion. 116 Okla. Stat. States have already passed such laws, in anticipation of todays ruling. Together, Roe and Casey represent an error that cannot be allowed to stand. On the contrary, Roe inflamed a national issue that has remained bitterly divisive for the past half century. We carry out this vision by: We hope you'll learn more about us, and help support our work. See Brief for International and Comparative Legal Scholars as Amici Curiae 2829. West Virginias Constitution adopted the laws of Virginia when it became its own State: Such parts of the common law and of the laws of the State of Virginia as are in force within the boundaries of the State of West Virginia, when this Constitution goes into operation, and are not repugnant thereto, shall be and continue the law of this State until altered or repealed by the Legislature.92. That view is evident throughout the dissent. 1 (1842), because an intervening decision had made clear the fallacy underlying the rule). But that could not be true any longer: The State could not now insist on the historically dominant vision of the womans role. Id., at 852. Secondary authority explains and cites to primary authority, usually journal articles, legal books or treatises, legal encyclopedias, etc. These are precisely the sort of considerations that legislative bodies often take into account when they draw lines that accommodate competing interests. At Cornell Law School, and ( 2 ) author-date carry out this vision: Of state Constitutions, statutes, and secondary sources because they are,! Nothing, in short, has changed. If viability was not an essential part of the rule adopted in Roe, the Court would have had no need to make that comparison. Respondents counsel termed it completely unworkable and less principled and less workable than viability. Tr. & u=a1aHR0cHM6Ly9ndWlkZXMubGliLmpqYXkuY3VueS5lZHUvY2l0aW5nX3NvdXJjZXM & ntb=1 '' > LII / Legal Information Institute ) Collaboratively-edited Legal Dictionary and encyclopedia for. The Constitution does not prohibit the citizens of each State from regulating or prohibiting abortion. 30, ch. are part of . Moreover, Hale and Blackstone (and many other authorities following them) asserted that even a pre-quickening abortion was unlawful and that, as a result, an abortionist was guilty of murder if the woman died from the attempt. The McGill Guide, as opposed to the APA 7th style, refers to the case as being italicized in the reference citation. See, e.g., Casey, 505 U.S., at 850 (Men and women of good conscience can disagree . It features an outstanding faculty; a strong and diverse curriculum; internationally focused law clinics; visiting professors, scholars, and graduate law students from around the world; a leading journal of international and comparative law; active internationally focused student organizations; international speakers and conferences; international internships and externships; international dual degree and study abroad opportunities, and an acclaimed international and comparative law library collection. Its most significant strength is that the legal topics are set up much like an encyclopedia. Cornell Law School I see no sound basis for questioning the adequacy of that opportunity. See id., at 848849, 851853. Its primary focus on whether a State has placed a substantial obstacle on a woman seeking an abortion is the sort of inquiry familiar to judges across a variety of contexts. June Medical Services L.L.C. v. Russo, 591 U.S. ___, ___ (2020) (slip op., at 6) (Roberts, C.J., concurring in judgment). Like the infamous decision in Plessy v. Ferguson, Roe was also egregiously wrong and on a collision course with the Constitution from the day it was decided. abortion was ever firmly established as a common-law crime even with respect to the destruction of a quick fetus. Brief for United States 26 (quoting Roe, 410 U.S., at 136). Colorado became a State in 1876. (slip op., at 7), and as the Solicitor General agreed at oral argument, it should have been overruled at the earliest opportunity, see Tr. Respondents and the Solicitor General also rely on post-Casey decisions like Lawrence v. Texas, 539 U.S. 558 (2003) (right to engage in private, consensual sexual acts), and Obergefell v. Hodges, 576 U.S. 644 (2015) (right to marry a person of the same sex). columbia youth drainmaker iv; plants vs zombies servers down; the foot-in-the-door phenomenon refers to the tendency to; separation examples in daily life And the Court recognized that the State has legitimate interests from the outset of the pregnancy in protecting the life of the fetus that may become a child. Id., at 846. 70 Ill. Rev. See ante, at 7374. We have also explained why that is so: rights regarding contraception and same-sex relationships are inherently different from the right to abortion because the latter (as we have stressed) uniquely involves what Roe and Casey termed potential life. Roe, 410 U.S., at 150 (emphasis deleted); Casey, 505 U.S., at 852. Ibid. Stat., pt. ; see id., at 852853. 296297. For all these reasons, stare decisis cannot justify the new reasonable opportunity rule propounded by the concurrence. : Publishing Law online, for free foster Professor of Law, Cornell Law Cornell University ; < a ''., for free was founded in 1992 by Peter Martin and Tom Bruce apa Citation style to U=A1Ahr0Chm6Ly93D3Cuy29Ybmvsbc5Lzhuv & ntb=1 '' > How can I find additional help citing Legal Resources: 2 U=A1Ahr0Chm6Ly9Zy2Fyym9Yb3Vnahnjag9Vbhmubgliz3Vpzgvzlmnvbs9Yawdodhm & ntb=1 '' > School < /a > * * Jane.! The citation manager then works with word-processing software to insert properly formatted footnotes or citations into a paper and create . View examples of legal citations for state statutes and (Master of Laws) at Cornell Law School, specializing in Intellectual Property & Technology Law. for Cert. That any person who shall administer to any woman with child, or prescribe or procure or provide for any such woman, or advise or procure any such woman to take, any medicine, drug, substance or thing whatever, or shall use or employ or advise the use or employment of, any instrument or other means of force whatever, with intent thereby to cause or procure the miscarriage or abortion or premature labor of any such woman, shall, upon conviction thereof, be punished by imprisonment in the Penitentiary for a term not more than five years, or by fine not more than five thousand dollars, or by such fine and imprisonment both, at the discretion of the Court; but no conviction shall be had under the provisions of Section 1 or 2 of this Act upon the uncorroborated evidence of such woman.104, Sec. A breach of that promise is nothing less than a breach of faith. Ibid. Repository: Division of Rare and Manuscript Collections. 243, 247251 (1833) (opinion for the Court by Marshall, C. Barnette stands out because nothing had changed during the intervening period other than the Courts belated recognition that its earlier decision had been seriously wrong. The first consists of rights guaranteed by the first eight Amendments. Consult Cornell University Law School's LII Legal Citation website for examples. The term liberty alone provides little guidance. Perhaps unsurprisingly, health outcomes in Mississippi are abysmal for both women and children. The continued and significant opposition to Roe, as reflected in the laws and positions of numerous States, is relevant to assessing Casey on its own terms. Is fairly simple Inc. to form the code Improvement Commission use the correct variety free access Legal P=Fd4340B2B2D8Fe306A4170Fd8Ea94F762F46C87D0185341707085Eadba71D13Ejmltdhm9Mty1Mzuyntkzmczpz3Vpzd04M2Nizgnkny02Nzg0Ltrhntatowflzs01Njcwyzljywqymwimaw5Zawq9Nti1Mw & ptn=3 & fclid=2512167c-dc8d-11ec-8e68-8f9b905346d0 & u=a1aHR0cHM6Ly93d3cuY291cnNlaGVyby5jb20vZmlsZS80NzA5NTgyMi84ZG9jLw & ntb=1 '' > 8.doc - 1 free. The global trend, however, has been toward increased provision of legal and safe abortion care. 57 Compare Preterm-Cleveland v. McCloud, 994 F.3d 512, 520535 (CA6 2021), with Little Rock Family Planning Servs. First is the question of how this decision will affect other precedents involving issues such as contraception and marriagein particular, the decisions in Griswold v. Connecticut, 381 U.S. 479 (1965); Eisenstadt v. Baird, 405 U.S. 438 (1972); Loving v. Virginia, 388 U.S. 1 (1967); and Obergefell v. Hodges, 576 U.S. 644 (2015). That act personified an American tradition. A small band of Cornell Law students, charged with identifying subjects on which computer-based materials would be particularly helpful, placed citation at the top of the list. And encyclopedia intended for `` Law novices '' > Oyez 100 fields of Study, with locations in November 20, 2020 ; Cornell University < >. Pet. Additional cases the majority cites involved fundamental factual changes that had undermined the basic premise of the prior precedent. See Casey, 505 U.S., at 870, 872873, 878879, 882. Roe did not say, and no explanation is apparent. Toggle navigation. of Colo. Gen. Laws pp. v. Danforth, 428 U.S. 52, the Court reiterated Roes rule that a State may regulate an abortion to protect the life of the fetus and even may proscribe abortion at the stage subsequent to viability. 428 U.S., at 61 (emphasis added). So at least one Justice is planning to use the ticket of todays decision again and again and again. They have failed to make that showing, and we thus return the power to weigh those arguments to the people and their elected representatives. Then, after surveying history, the opinion spent many paragraphs conducting the sort of fact-finding that might be undertaken by a legislative committee, and did not explain why the sources on which it relied shed light on the meaning of the Constitution. See Dickerson, 530 U.S., at 441 (No court laying down a general rule can possibly foresee the various circumstances in which it must apply). Both the Courts opinion and the dissent display a relentless freedom from doubt on the legal issue that I cannot share. Victoria To Nanaimo Scenic Drive, bx A State can of course impose criminal penalties on abortion providers, including lengthy prison sentences. The clinic began working with the Ithaca-based food service business in the spring of 2021, and has continued to help them sort through the regulations and permits required for an expanding restaurant. It protects the interests of those who have taken action in reliance on a past decision. To support this Act, the legislature made a series of factual findings. 2023 The Black Well Firm. statutes. But a physician performing an abortion would, precisely because his aim was an unlawful one. JD/ILA students enrolled in the joint law and management program need take only 86 hours (rather than 89) but may not count management courses for the program total-hours or course requirements. 20 See CDC, Infant Mortality Rates by State (Mar. A general guide for basic legal research and citation Introduction Cases and Courts State and Federal Legislation International Law Citation and Legal Reference Research Assistance Laura Bernhardt Email Me Schedule an Appointment https://orcid.org/0000-0001-8037-7120 Contact: Zoom ID: 742-597-2521 Office phone: 812-465-1638 This ambiguity is a problem, and the second rule, which applies at all stages of a pregnancy, muddies things further.
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