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“Returning” Abortion to “the People and Their Elected Representatives”: Chaos, Conflict and Access in Wisconsin in the Aftermath of Dobbs v. Jackson Women’s Health Organization

« Le retour » de l’avortement « au peuple et à ses représentants » : chaos, conflit et accès dans le Wisconsin au lendemain de la décision Dobbs v. Jackson Women’s Health Organization
Anne Légier

Résumés

Le 24 juin 2022, la Cour suprême des États‑Unis mit fin à près d’un demi‑siècle de protection constitutionnelle pour le droit à l’avortement en renversant les arrêts Roe v. Wade (1973) et Planned Parenthood v. Casey (1992). Dans l’arrêt Dobbs v. Jackson Women’s Health Organization, le juge Samuel Alito, chargé de la rédaction pour la majorité de la Cour, affirma que puisque la jurisprudence n’avait pas réussi « à mettre un terme à une amère controverse nationale », l’autorité en matière d’avortement devait être « rendue au peuple et ses représentants élus ». Au cœur de l’arrêt se trouvait donc l’idée qu’il apaiserait les tensions et réduirait les incertitudes caractéristiques du débat sur l’avortement en autorisant les États fédérés et leurs habitants à adopter des lois locales qui reflèteraient mieux leurs valeurs. Or, il n’en est rien : l’arrêt est à l’origine d’une vague d’affaires complexes, soulevant des conflits de souveraineté et impliquant des sources de pouvoir à l’échelle fédérale et à celle des États fédérés. Afin de mettre en lumière ces tensions, l’article se concentrera sur un État particulier, celui du Wisconsin, dans lequel, à la suite d’un désaccord entre différentes sources de pouvoir au sujet de la loi qui devrait s’appliquer, l’accès à l’avortement fut suspendu pendant quinze mois.

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  • 1 In legal English, the term “opinion” refers to a court’s written explanation of the ruling reached (...)

1On 24 June 2022, the United States Supreme Court overturned Roe v. Wade (1973) and Planned Parenthood v. Casey (1992), putting an end to nearly fifty years of constitutional protection for abortion rights. In Dobbs v. Jackson Women’s Health Organization, Justice Samuel Alito, who authored the opinion1 for the Court, wrote that Roe and Casey had been wrongly decided because “the Constitution [did] not prohibit the citizens of each State from regulating or prohibiting abortion”. He claimed that the two landmark rulings had in fact “arrogated that authority” (Dobbs v. Jackson Women’s Health Organization, 2022: 79). Further criticizing the decisions, he wrote that “far from bringing about a national settlement of the abortion issue, [they had] enflamed debate and deepened division”. It was now “time”, he affirmed, “to heed the Constitution and return the issue of abortion to the people’s elected representatives” (Dobbs v. Jackson Women’s Health Organization, 2022: 6). To support this line of reasoning, Alito referred to the late Justice Antonin Scalia’s opinion in Casey—which concurred partly with that written by Justice O’Connor in 1992. In his opinion, Scalia had written that “the permissibility of abortion, and the limitations, upon it, are to be resolved like most important questions in our democracy: by citizens trying to persuade one another and then voting” (cited in Dobbs v. Jackson Women’s Health Organization, 2022: 6).

2One of the central ideas of the Dobbs ruling was thus that it would appease preexisting tensions and confusion on the issue of abortion by allowing the people and their representatives to better convey their values in their state laws. The ruling, however, did no such thing: it unleashed a wave of confusing cases involving competing and sometimes conflicting sources of power. The intention of this article is to highlight some of the sovereignty issues that have emerged as states face the consequences of the Court’s 2022 ruling by narrowing in on the legal situation in a specific state, Wisconsin. Our belief is that by focusing on the micro level (the state’s various sources of authority) in its relationship to the macro level (the federal framework established by the Court), this article might shed light on the general consequences of a singular event and the power dynamics at play in the abortion debate (Rhee, 2022; Siems, 2008).

  • 2 In their article, the authors reference the state of Texas and their inhabitants eighty times while (...)

3Most recent scholarly work on abortion tends to focus on states like Texas, Louisiana and Mississippi, where anti‑abortion activism at the legislative and judicial levels has dramatically impacted abortion access (Venator & Fletcher, 2021: 775). Wisconsin seems to gravitate at the periphery of the “new abortion battleground” analyzed by legal scholars Cohen, Donely and Rebouché in their landmark 2023 article.2 However, Wisconsin is an interesting state to study because it is both at the center and at the margins of the abortion wars.

4Before Roe was overturned, Wisconsin’s anti‑abortion policies were representative of those found in other states and most Wisconsinites lived in counties with no abortion provider (Guzman, 2018: 113–116). Although the state has a relatively small population, in the past decade it has played a key role in national politics, providing the Republican Party with prominent leaders such as Reince Priebus and Paul Ryan and helping Donald Trump secure the presidency in 2016. This has led several scholars to label it “the center of the political universe” (Freyberg, 2019; Johnson, 2023).

  • 3 Wisconsin has historically been a “swing” or “purple” state because its population is evenly distri (...)

5Wisconsin’s long‑standing status as a “purple state”,3 has meant that when Roe v. Wade was overturned in 2022, power was more evenly divided than in most states, creating a greater potential for interjurisdictional conflict. In the current polarized political landscape, the abortion issue plays an important role at every level of government. The multiple intertwined and sometimes conflicting levels of government typical of the federal system seem ill‑equipped to absorb the legal chaos unleashed by the Dobbs v. Jackson Women’s Health Organization ruling in states which, like Wisconsin, do not have a clear political majority.

  • 4 Wisconsin shares a border with Minnesota, Iowa, Illinois, and Michigan.
  • 5 “Tribal sovereignty” refers to the right of each Native tribe to self‑governance. It is based on tr (...)

6In addition, Wisconsin is in an interesting geographical situation that showcases some of the issues that have emerged in the past year and a half. Since it is a medium-sized state bordering four other states and is close to Canada, people can travel to seek services which are not available locally (Venator & Fletcher, 2021: 779).4 This feature is heightened by the fact that the state’s borders are very close to progressive metropolitan areas including Chicago and the Twin Cities (Minneapolis-Saint Paul) and because Wisconsin is home to eleven federally-recognized Native nations, which could raise other interjurisdictional issues over abortion (Guzman, 2018; Cohen, Donely & Rebouché, 2023: 87).5

  • 6 Arkansas, Idaho, Kentucky, Louisiana, Mississippi, Missouri, North Dakota, Oklahoma, South Dakota, (...)
  • 7 Most trigger bans included health exceptions but did not define them clearly, leaving physicians to (...)
  • 8 Wasserman attributes the term “zombie law” to Gregg Costa, a federal judge (U.S Court of Appeals fo (...)

7This article was first drafted in March 2023, less than a year into the decision, and at a time when the situation was undoubtedly chaotic, evolving daily as some state bans were temporarily stayed by court challenges, while others took effect, sometimes in the same state, within days (Winter, 2022). “Trigger laws”, which had been written to signal the political views of their sponsors without seriously considering enforceability, had suddenly become the law in more than a dozen states.6 They were phrased in language which was confusing to physicians and contained major medical omissions that hindered health-care providers’ ability to make reasonable medical decisions (Winter, 2022).7 Several states, including Wisconsin, discovered that they had what some legal scholars called “zombie laws”—laws that were still on the books although they had been invalidated by the Court’s ruling in Roe v. Wade (Wasserman, 2021).8 In the aftermath of Dobbs, abortion rights opponents were claiming that the antiquated Wisconsin laws had been “reactivated” by the Court’s new decision. A year and a half after the ruling, some of the dust has settled but the situation remains confusing, notably because of uncertainties over conflicting sovereignties at the state and federal levels.

8Since it would be impossible and elusive to provide a comprehensive picture of the ever-evolving abortion landscape in the United States, this article will use the example of the state of Wisconsin to challenge the Supreme Court’s claim that “returning” abortion to the states can provide legal and political clarity and can enable the people’s views to be better represented. To do so, I will first argue that the Court relied on a false premise, which is the idea that Roe had stripped states of their power to regulate abortion. I will then narrow in on the conflicts that emerged between multiple levels of sovereignty as the state put abortion on hold for fifteen months. Finally, I will examine access to abortion during that period, showing that the options Wisconsinites were left with raised another set of sovereignty issues.

1. Returning abortion to the states: a false premise?

9The Court’s opinion in Dobbs claimed Roe had “abruptly ended” the “political process” that respected state sovereignty in an “exercise of raw judicial power” (Dobbs, 23: 2–3; Hodge, Ghaith & Krumholz, 2022). However, a brief overview of abortion regulation in the United States shows that abortion never ceased to be a state prerogative.

  • 9 The Comstock Act, a federal anti-pornography statute enacted in 1873, did provide a federal framewo (...)

10When pregnancy termination was criminalized in the second half of the 19th century, it was through state laws.9 In the 1960s and early 1970s, under social, political, and cultural pressure, some states started reforming or repealing their abortion laws. When the state of New York legalized abortion in 1970 with no residency requirement, women from the entire country began travelling to the state to terminate their pregnancies legally. As abortion travel required various resources, inequalities were highlighted (Reagan, 2019). Abortion rights activists made the argument that this meant abortion laws were “unfair” (Carmen & Moody, 1973; Légier, 2019).

  • 10 Planned Parenthood v. Casey considered the constitutionality of the Pennsylvania Abortion Control A (...)
  • 11 The term “abortion provider” refers to health care professionals who perform abortions or to medica (...)
  • 12 Planned Parenthood provides the following examples of TRAP (Targeted Regulation of Abortion Provide (...)
  • 13 This provision was never enforced and it was eventually struck down by the 7th Circuit Court of App (...)

11When the Supreme Court established in Roe v. Wade (1973) that the U.S. Constitution’s privacy protections were broad enough to include a woman’s right to end a pregnancy, it did not brush aside states’ rights. It established a carefully crafted trimester framework which balanced individual rights with those of individual states, within the limits of the Constitution (Roe v. Wade, 1973; Beck, 2011). While retaining “the central holding” of Roe, the 1992 Planned Parenthood v. Casey ruling increased state power by allowing states to regulate termination at any point in pregnancy if this did not “unduly burden” a woman’s right to choose (Planned Parenthood v. Casey, 1992; Greenhouse & Siegel, 2016; Winter, 2016; Beck, 2011; Guzman, 2018).10 Anti‑abortion lobbies such as Americans United for Life seized the avenue opened by Casey to craft creative laws at the state level with the intention of making abortion as difficult to access as possible (New, 2011; Moughty, 2022). They convinced Republican majorities in state legislatures to pass laws that set limitations on abortion, first by imposing unnecessary burdens on patients and then turning to abortion providers11 (Greenhouse & Siegel, 2016; Guttmacher Institute, 2023b; Ziegler, 2023).12 In 2013, for example, the Wisconsin legislature passed a law which targeted both patients and physicians. It compelled abortion patients to undergo an ultrasound regardless of medical necessity and it also required that doctors attempt to visualize a heartbeat while displaying and commenting ultrasound images. It was also mandatory for abortion providers to have admitting privileges at a local hospital.13

12The idea that the divisive topic of abortion could be settled by returning it to the states is thus contradicted by the history of state abortion bans and regulations, even those operating within the framework established by Supreme Court rulings. States have been at the center of the abortion wars for decades, if not centuries. However, the Court’s radical approach in Dobbs removed baseline protections that established limits on what states could do. This had an immediate impact on abortion laws and abortion provision.

  • 14 Alabama, Arkansas, Idaho, Indiana, Kentucky, Louisiana, Mississippi, Missouri, North Dakota, Oklaho (...)

13If we look at abortion provision in the United States since the 2022 ruling, it is very clear that lifting constitutional protection at the federal level has had a dramatic impact on abortion access across the country. As of January 2024, sixteen states had a ban or near total ban14 in effect and five more had limits that would have been unconstitutional before 2022, placing 18 million women of reproductive age without access to abortion care in their home state (Forouzan & Guarnieri, 2023). In those states, people seeking to terminate pregnancies must now turn to interstate travel, a phenomenon which, according to the Guttmacher Institute, doubled between 2020 and 2023, affecting one in five patients (Guttmacher Institute, 2023a). As travel might require taking several days off from work, as well as organizing childcare and planning for various expenses, patients who are most likely to be able to do so are those with social and economic resources. People who are in vulnerable situations—for instance because they are minors, undocumented or victims of domestic abuse—are less likely to have the means and opportunities to access abortion.

14Without the federal protection afforded by Roe, it has sometimes also been unclear what the legal situation is at the state or even federal levels and how to resolve conflicts that had been settled by the Court’s 1973 ruling. The political saga which unfolded in Wisconsin after Dobbs exemplifies this uncertainty.

2. Who gets to determine the legality of abortion?

15In their January 2024 article on Dobbs and democracy, Melissa Murray and Katherine Shaw convincingly argue that the Court’s opinion “misapprehended the processes and institutions that are constitutive of democracy, focusing on state legislatures while overlooking a range of other federal, state, and local constitutional actors” (Murray & Shaw, 2024: 729). This “myopic” understanding of the democratic process became very apparent as the state of Wisconsin’s institutions struggled to make sense of what the Court’s ruling meant for the legality of abortion.

  • 15 When Roe was decided, only four states had repealed their abortion bans (Alaska, Hawaii, New York, (...)
  • 16 The initial ban referred to “quickening”, i.e. the point in time where the woman starts to feel fet (...)

16When the Court established, in 1973, that abortion was a constitutionally protected right, most states had wide abortion bans.15 Roe rendered them inapplicable, but some have never been repealed and are thus still technically on the books as “dormant laws” or “zombie laws”, a term that implies they are not really “dead” and could “come back to life”. In Wisconsin, an 1849 statute which was considerably amended in 1858 to prohibit all abortions16 (Mohr, 1978: 139–140; Leahy, 2022) became a focal point after the 2022 ruling. Anti‑abortion advocates and Republican politicians argued it became enforceable when Roe was overturned and could be used to prosecute doctors on felony charges that carried a sentence of up to six years in prison. Abortion rights activists and members of the state executive disagreed (Spears, 2023; Lehr, 2022).

  • 17 Both state Houses adjourned the special session a mere seconds after it had convened.

17In June, after an unprecedented Supreme Court leak indicated that constitutional protection for abortion would vanish, the Democratic Governor of the state of Wisconsin, Tony Evers, sprang into action. He convened a special session of the state legislature to pressure lawmakers to repeal the dormant ban. His efforts proved unsuccessful as the Republican majority in the state Senate and state House refused to even discuss the issue (Hatfield, 2022).17

18That same month, after Governor Evers’s attempt failed, Josh Kaul, the state’s Attorney General, and the state’s health agencies filed a lawsuit against the state legislature, arguing that the pre‑Civil War ban was unenforceable. The lawsuit claimed that because the state legislature had passed other abortion legislation after Roe—such as a 1985 law that criminalizes abortion after “viability”—“the Wisconsin statutes contain[ed] two sets of criminal laws that directly conflict[ed] with each other” (Kaul v. Kapenga, 2022). It urged the Courts to provide clarity to the physicians and the people of Wisconsin (Johnson, 2022; Felix, Sobel & Salganicoff, 2023).

19Republican lawmakers countered by saying that the state legislature was not in charge of enforcing the law, and Kaul modified the lawsuit to name the Republican District Attorneys of three different counties where abortions had been performed (CBS News, 2022; Redman, 2022). One of them, Joel Urmanksi, had stated that he would prosecute doctors who terminated a pregnancy under the 1849 ban (Kaul v. Kapenga, 2022, CV‑1594; Associated Press, 2022; Fannon, 2022). In November 2022, Urmanski filed a motion to dismiss the case, claiming that “Wisconsin courts have never recognized that a statute can lose effect through disuse and, even if they had, this case would not warrant application of that principle”. He argued that if “the Plaintiffs believe[d] the statute lack[ed] the consent of the governed”, they should turn to the Legislature and the Governor to seek legal change rather than the courts (CBS News, 2022).

  • 18 “Feticide” refers to the criminal activity of attacking a woman who is pregnant and causing her to (...)

20The motion to dismiss was denied in July 2023, and again in December. The circuit judge who allowed the lawsuit to move forward, Diane Schlipper, rendered a declaratory judgement which was understood as protective enough to allow abortions to resume in September (Venhuizen, 2023; CBS News, 2023). The decision, which is not a final ruling, stated that “there [was] no such thing as an ‘1849 Abortion Ban’ in Wisconsin (Kaul v. Urmanski: 2). The reasoning was that the pre‑Roe statute did not mention abortion, and that the state had always interpreted it as applying to feticide18 rather than elective abortion (Kaul v. Urmanski; Choi, 2023). The case is still ongoing and likely to reach the state Supreme Court.

  • 19 In specific circumstances a seat may be filled by appointment by the governor.
  • 20 Wikler chose to use “nobody” instead of “anybody” to signal the disconnect between the race’s high (...)

21In Wisconsin, the state Supreme Court is composed of seven Justices who are elected in statewide elections for ten‑year terms.19 As the lawsuit over the enforceability of the 1849 abortion ban was making its way through the judicial system, a race to decide who would fill one of the seven Supreme Court seats was ongoing, and it was clear this would determine the balance of the state’s highest court for the next two years, at least. Ben Wikler, the chair of the state Democratic Party, aptly qualified the race as “the most important election nobody[had] ever heard of” (Sneed & Schouten 2023),20 arguing that the case had “implications that w[ould] affect national politics for years to come, really at every level of government” (Montellaro & Messerly, 2023). Because political parties and groups on both sides of the abortion divide were keenly aware of the political battle’s high stakes, millions of dollars were injected into it, breaking national spending records (Montellaro & Messerly 2023; Johnson, 2023). Anthony Chergosky, who teaches political science at the University of Wisconsin-La Crosse, explained in April 2023 that this showed “that Wisconsin just tends to be the center of the political universe” (Johnson, 2023).

22Janet Protasiewicz, the candidate who had been endorsed by the Democratic Party of Wisconsin and had expressed very clearly that she would support abortion rights, won the April general election with a clear majority and was sworn in as a State Justice the following August. Very quickly, Republicans started talking about a possible impeachment, a move that raises questions about political representation and the legitimacy of elections (Epstein, 2023). They argued that because Justice Protasiewicz had vowed to fight gerrymandering, she could not rule on a case challenging the current electoral maps drawn by the Republican state legislature. Since Wisconsin is a purple state, the current Supreme Court majority “serves as an existential danger” for Republicans who would be stripped “of what now amounts to permanent majorities in the Legislature” (Epstein, 2023). Who holds the power in the state Supreme Court might also determine future legislative majorities, which will in turn decide the future of abortion rights in the state of Wisconsin. Justice Protasiewicz’s election and the unprecedented amount of attention it has drawn shows how complex the idea of “returning” abortion “to the people and their elected representatives” can be.

23While the case filed by Attorney General Kaul is still ongoing, it could reach the state Supreme Court. Even after a ruling on the matter, the possibility of then petitioning the U.S. Supreme Court would remain. The uncertainty over which abortion law should apply in the state of Wisconsin could endure for years.

  • 21 In March 2023, NPR ran a story about Texas prosecutors being targeted by their state lawmakers for (...)

24As the case was making its way through the courts, Kaul, the Democratic Attorney General of Wisconsin, said his office would not prosecute people for providing or seeking abortion services (Marley, 2022). His leading challenger in the November 2022 general election, Republican candidate Eric Toney, however, promised that he would enforce the 19th century ban if elected (Cortellessa, 2022). Toney lost the election but the fact that enforcement of the same laws might differ drastically depending on who holds the executive power in the state is a new feature of the abortion landscape.21

25In this context, local prosecutors on both sides of the divide found themselves in complicated situations. In Wisconsin, one district attorney from La Crosse County, Tim Gruenke, a Democrat, publicly stated in July 2022 that even though he believed in a woman’s right to access abortion services, he felt that, as a member of the executive branch of government, he was bound to enforce existing laws. He added that “at this point, [he was] not sure which one the legislature intend[ed] him to follow” (Freyberg, 2022).

26Meanwhile, what was the impact on the Wisconsin women seeking abortion care as different branches of government fought over the enforceability of a 19th‑century statute?

3. Accessing abortion care after Dobbs

27As their elected representatives fought over issues of sovereignty for more than a year, the people of Wisconsin looking for abortion care had limited options. Examining these options further highlights conflicts over governance and institutions, notably at the intersection of federal and state powers.

  • 22 Anti‑abortion activists have creatively invoked “trafficking” or “conspiracy” laws (Mulvihill, 2023 (...)

28While they were waiting for the legal situation to settle, the first option for Wisconsinites seeking to end their pregnancies was crossing state lines. In the aftermath of Dobbs, Republican states and counties across the country have attempted to prevent abortion travel; Wisconsin never created such restrictions, however (Mulvihill, 2023).22 During the fifteen months when no abortions were provided in the state, there were no formal barriers to crossing state lines to terminate a pregnancy. In theory, Wisconsinites could go to neighboring Minnesota, where the state Supreme Court had recognized the right to abortion under its Constitution and where the governor had issued an executive order protecting people seeking or providing abortions from laws in other states (The New York Times, 2023). But the eight existing abortion clinics in Minnesota did not seem equipped to handle the potential influx of out-of-state patients (Pradhan, 2022; Abortion Finder). Even before this decision, Minnesota residents regularly had to wait at least two weeks for appointments at the state clinics (Pradhan, 2022). Wisconsin residents could also go to neighboring Michigan where a pre‑Roe ban was temporarily blocked, then ruled null and void after the state amended its constitution to protect abortion rights and eventually repealed by the state legislature (Kekatos, 2023). Despite Michigan’s efforts to secure abortion rights, it seemed to be facing the same struggle as many other states in responding to the demands of its own residents. One real option for Wisconsin residents was to travel to Illinois, which has strong abortion rights protections, no parental consent requirement for minors and a robust network of providers that could absorb many out-of-state patients, at least for early medication abortion.

29Another option for Wisconsinites seeking abortion care was to turn to medication, a solution which entailed either physically or virtually crossing state lines. A Wisconsin law enacted in 2012 to regulate the use of abortion pills in the state required that the physician who obtained consent from the abortion patient administer the medications and watch the patient take them, in person. This seemed to prohibit the use of telehealth to obtain abortion pills and meant that if there were no state providers, Wisconsin residents had to travel out of state to obtain a drug‑induced abortion (Valley & Alvarez, 2021; Valley, Zander, Jacques & Higgins, 2023).

30After Dobbs, two main websites, I need an A and Plan C started to provide ways to bypass such barriers to telehealth by setting up virtual mailboxes to forward prescriptions and medication. To a certain degree, these websites operate in the same way as pre‑Roe abortion referral networks but with a major difference: a medication that can safely be used to self‑manage abortions at home is now available. The pills are sent by physicians or pharmacies licensed outside the state or the country (generally in India). As attested by the warnings on the website, the legality of these services remains uncertain.

  • 23 The Biden administration, through Attorney General Merrick Garland, has taken strong stances on the (...)

31While the Wisconsin state law was understood to prohibit the remote provision of medication abortion, the Food and Drug Administration (FDA), which approves medications at the federal level, has authorized the use of abortion medication since 2000 and lifted telehealth restrictions during the pandemic. One of the many questions that arose after Dobbs was thus whether anti-abortion states could ban drugs that had been approved at the federal level. In December 2023, the U.S. Supreme Court agreed to hear a case from Texas questioning the authority of the FDA to regulate the provision of one of the drugs involved in the medication abortion protocol commonly used in the United States. Uncertainties over medication provision have loomed large and have raised questions about the rights of physicians, pharmacies, and drug companies. Is it lawful for a state to prohibit out-of-state physicians from prescribing or delivering drugs to its residents? Can it prevent pharmacies from delivering drugs that have been approved at the federal level?23

32The complicated landscape which the people of Wisconsin had to navigate as they looked for ways to terminate pregnancies underscores chaos and confusion about which sources of power have the ultimate authority to adjudicate between matters determining access.

4. Conclusion

  • 24 On abortion and Native sovereignty in Wisconsin, see Guzman (2018).

33Through the great confusion unleashed by Dobbs, one fact does appear clear: the evidence does not back the idea put forth by the Supreme Court’s majority that abortion regulation might better be addressed by “the people and their elected representatives”. In the state of Wisconsin—which is both unique and somewhat representative of the complex power dynamics and conflicting sources of authority—who are “the elected representatives” who best embody the values and beliefs of the people of Wisconsin? Are they the lawmakers who passed the 1849 ban and amended it in 1858 at a time when the only people who had the right to vote were white men? The state’s current executive branch headed by Democrats, who support reproductive rights? The state legislature whose current majority is arguing for the enforcement of a pre‑Civil War statute, something most of their constituents disagree with? Circuit Court Judges? District Attorneys? The Wisconsin Supreme Court? Individuals whose campaign donations might sway the next local election results? Are state policies going to end up being determined by the rulings of federal judges, who are not elected? Will they be shaped by health care providers determining how likely they are to be prosecuted? And what about the sovereignty of the 11 federally recognized Native Nations of the state of Wisconsin?24

34What we do know is that, despite popular support for abortion rights (Marquette Law School, 2022; Pew Research Center, 2022b) and no clear abortion ban, pregnancy termination was unavailable in the state of Wisconsin because of conflicting sovereignties, threatening the health and safety of people who might become pregnant and those who care for them.

35As of January 2024, it is hard to determine what the future of abortion rights will look like in Wisconsin. The lack of clarity that has characterized the legal situation in the state since 2022 does not only questions the validity of the Court’s invocation of democracy to justify overturning Roe, it also exemplifies the current political crisis threatening American democracy.

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Notes

1 In legal English, the term “opinion” refers to a court’s written explanation of the ruling reached in a case. If not specified, “opinion” refers to “majority opinion”, i.e. the ruling. Opinions can also be “concurring” (if a judge votes with the majority but has a diverging legal reasoning to reach the same decision) or “dissenting” (written by a judge who disagrees with the ruling).

2 In their article, the authors reference the state of Texas and their inhabitants eighty times while Wisconsin is mentioned only four times, exclusively in footnotes.

3 Wisconsin has historically been a “swing” or “purple” state because its population is evenly distributed along party lines (Pew Research Center, 2022b; White, 2020).

4 Wisconsin shares a border with Minnesota, Iowa, Illinois, and Michigan.

5 “Tribal sovereignty” refers to the right of each Native tribe to self‑governance. It is based on treaties signed between the United States and Native nations and on the U.S. Constitution (Article I, sections 2 and 8). It protects the right of Native nations to govern their lands, resources, and citizens. The sovereignty of federally recognized nations places them outside of the realm of state authority and gives them the right to make and enforce substantive laws. Of the 12 Indigenous nations of Wisconsin, 11 are federally recognized. On tribal sovereignty and its evolution, see Guzman (2018: 99–106).

6 Arkansas, Idaho, Kentucky, Louisiana, Mississippi, Missouri, North Dakota, Oklahoma, South Dakota, Tennessee, Texas, Utah, Wyoming (Nash & Guarnieri, 2022).

7 Most trigger bans included health exceptions but did not define them clearly, leaving physicians to determine what terms like “major bodily function” or “substantial impairment” might refer to (Felix, Sobel & Salganicoff, 2023). In addition to that, trigger bans often ignored common situations which generally require termination: ectopic pregnancies (which happen outside the uterus, are not viable but extremely dangerous), miscarriages and hemorrhaging (Winter, 2022; Zernike, 2022). Doctors, concerned they could be prosecuted for standard medical procedures, reported having to consult lawyers while dealing with medical emergencies (Zernike, 2022).

8 Wasserman attributes the term “zombie law” to Gregg Costa, a federal judge (U.S Court of Appeals for the 5th Circuit).

9 The Comstock Act, a federal anti-pornography statute enacted in 1873, did provide a federal framework to prosecute the dissemination of abortion information and products, but state laws were the main instruments through which abortions were criminalized between the mid‑19th century and 1973.

10 Planned Parenthood v. Casey considered the constitutionality of the Pennsylvania Abortion Control Act of 1982, a law which required parental consent for minors, spousal notification for married women and a 24‑hour waiting period. Planned Parenthood of Southeastern Pennsylvania had filed a lawsuit arguing that these requirements violated the trimester framework established by Roe: they applied to all three trimesters even though Roe explicitly prohibited restrictions in the first trimester. The ruling, written by Sandra Day O’Connor, a Reagan appointee who was also the first woman to sit on the U.S. Supreme Court, reaffirmed that abortion was a constitutionally protected right but modified the trimester framework, introducing the “undue burden standard”.

11 The term “abortion provider” refers to health care professionals who perform abortions or to medical facilities where abortions are performed (such as clinics, hospitals, or doctors’ offices).

12 Planned Parenthood provides the following examples of TRAP (Targeted Regulation of Abortion Providers) laws: “Down-to-the-inch dimensions for exam rooms, hallways and janitors’ closets, and medically unnecessary requirements for doctors” (Planned Parenthood Action Fund, 2023).

13 This provision was never enforced and it was eventually struck down by the 7th Circuit Court of Appeals. Relying on medical evidence in a similar case involving the state of Texas (Whole Woman’s Health v. Hellerstedt, 2016), the Supreme Court later clarified that the admitting privileges requirement was unconstitutional under the “undue burden” concept established by Casey as it placed a “substantial obstacle in the path of a woman’s choice” without providing medical benefits.

14 Alabama, Arkansas, Idaho, Indiana, Kentucky, Louisiana, Mississippi, Missouri, North Dakota, Oklahoma, South Dakota, Tennessee, Texas and West Virginia ban all abortions with very limited exceptions. Georgia and South Carolina ban abortion after six weeks of pregnancy, which amounts to a near total ban (The New York Times, 2023).

15 When Roe was decided, only four states had repealed their abortion bans (Alaska, Hawaii, New York, and Washington). The District of Columbia and 12 states had also enacted abortion reforms (Arkansas, California, Colorado, Delaware, Georgia, Kansas, Maryland, New Mexico, North Carolina, Oregon, South Carolina and Virginia).

16 The initial ban referred to “quickening”, i.e. the point in time where the woman starts to feel fetal movement, which means that abortions would not have been criminalized until well into the second trimester. However, the word “quickening” was removed from the law in 1858 (Mohr, 1978: 139–140; Leahy, 2022).

17 Both state Houses adjourned the special session a mere seconds after it had convened.

18 “Feticide” refers to the criminal activity of attacking a woman who is pregnant and causing her to miscarry.

19 In specific circumstances a seat may be filled by appointment by the governor.

20 Wikler chose to use “nobody” instead of “anybody” to signal the disconnect between the race’s high stakes and the fact that, at that point, most people were unaware of its importance.

21 In March 2023, NPR ran a story about Texas prosecutors being targeted by their state lawmakers for refusing to enforce state laws (Jaspers, 2023).

22 Anti‑abortion activists have creatively invoked “trafficking” or “conspiracy” laws (Mulvihill, 2023). These attempts have been countered by the Biden administration, which argues that “the right to travel from one state to another is firmly embedded in the Supreme Court’s jurisprudence and the Constitution”, and that the Court “has held that states may not prevent third parties from assisting others in exercising [this right]” (DOJ, 2023b).

23 The Biden administration, through Attorney General Merrick Garland, has taken strong stances on the issue of medication and the safety of pregnant people, arguing notably that anti-abortion laws are a violation of the Emergency Medical Treatment and Labor Act (EMTALA) of 1986 (DOJ, 2023a; DOJ, 2023b; DOJ, 2023c).

24 On abortion and Native sovereignty in Wisconsin, see Guzman (2018).

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Référence électronique

Anne Légier, « “Returning” Abortion to “the People and Their Elected Representatives”: Chaos, Conflict and Access in Wisconsin in the Aftermath of Dobbs v. Jackson Women’s Health Organization »ILCEA [En ligne], 55 | 2024, mis en ligne le 26 mai 2024, consulté le 17 juin 2024. URL : http://0-journals-openedition-org.catalogue.libraries.london.ac.uk/ilcea/20162 ; DOI : https://0-doi-org.catalogue.libraries.london.ac.uk/10.4000/11prg

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Auteur

Anne Légier

Université Paris Cité, laboratoire ICT
anne.legier@u-paris.fr
 
Anne Légier is associate professor of American studies at Université Paris Cité (laboratoire ICT). She specializes in the history of abortion, women and gender in the United States. Her PhD dissertation, which she defended at Université Sorbonne Nouvelle in 2019 under the supervision of Hélène Le Dantec-Lowry, traces the history of the Clergy Consultation Service, a group of progressive ministers and rabbis who built the largest abortion referral network in the U.S. before Roe v. Wade. She Recently published Womanhoods and Equality in the United States: 20th–21st Century Perspectives, edited with Christen Bryson and Amélie Ribieras (Routledge, 2024).

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