410 U.S. 113 (1973).Google Scholar

109 S.Ct. 3040 (1989)Google Scholar

The New York Times, October 12, 1989, Section A, p.23 (Florida); October 18, 1989, Section A, p.20 (Illinois); February 24, 1990, Section 1, p.26 (Indiana and Michigan); MArch 24, 1990, Section 1, p.7 (Maryland); and June 10, 1990, Section 1, Part 1, p.29 (Alabama and Utah).Google Scholar

The New York Times, May 13, 1990, Section 12CN, p.3.Google Scholar

1989 Pa. Laws 64.Google Scholar

Guam Code Annotated, Title 9, 31.20–31.23.Google Scholar

The New York Times, January 12, 1990, Section A, p.18 (Pennsylvania law enjoined); The New York Times, March 25, 1990, Section 1, Part 1, p.29 (Guam law enjoined); Planned Parenthood of Pennsylvania v. Casey, 744 F. Supp 1323 (Pennsylvania law declared unconstitutional); Guam Society of Obstetricians and Gynecologists v. Ada, 1990 U.S. Dist. Lexis 11910 (Guam law declared unconstitutional). Both cases are being appealed and could reach the Supreme Court by the fall of 1991.Google Scholar

110 S.Ct. 2972.Google Scholar

110 S.Ct. 2926.Google Scholar

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Logically, it would seem improbable for Justice O'Connor to vote that there is no constitutional right to have an abortion if she is unwilling to uphold a law that simply requires a minor to notify both parents of her intent to obtain an abortion without actually giving them the right to bar her from obtaining an abortion.Google Scholar

In one sense, however, this analysis of Hodgson may be academic. On July 21, 1990 Justice Brennan, the dean of the liberal judges on the Court, announced his retirement after 3 decades of service. The New York Times, July 21, 1990, Section 1, p.1. President Bush took the opportunity to nominate another conservative to the Court, David H. Souter of the First Circuit Court of Appeals, who was confirmed by the Senate on October 2, 1990. The New York Times, October 3, 1990, Section A, p.1. If Judge Souter's views resemble those of the last two court appointees, the delicate balance on abortion in the Court may be overthrown. There will be a five-person majority to overrule Roe v. Wade, and the post-Roe v. Wade era will truly have begun.Google Scholar

Section 251 of the Criminal Code.Google Scholar

Canada, Department of Justice, Report of the Committee on the Operation of the Abortion Law (1977); Ontario, Ministry of Health, Report on Therapeutic Abortion Services in Ontario (1987).Google Scholar

Sachdev, P., ed., International Handbook on Abortion (1988) at 69–69. In contrast, in Quebec the provincial government eventually decided not to prosecute physicians performing medically safe abortions, whether in an approved hospital or elsewhere. Id.Google Scholar

One of the most vociferous critics of both the old and new laws was Dr. Henry Morgentaler, a survivor of Auschwitz, who for more than two decades challenged the validity of abortion restrictions, arguing that a woman has an unfettered right to obtain an abortion. He set up abortion facilities outside accredited hospitals, first in Quebec, and later in Ontario and Manitoba, and openly claimed to have performed thousands of abortions. Although tried four times for violation of the Criminal Code, he was acquitted by juries on each occasion and spent time in jail only because the prosecution managed to have a higher court reverse the decision of one jury. The most recent litigation in which he was involved resulted in the Supreme Court's 1988 decision. Id.Google Scholar

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Id. at 82. The Chief Justice noted, “Forcing a woman, by threat of criminal sanction, to carry a fetus to term unless she meets certain criteria unrelated to her own priorities and aspirations, is a profound interference with a woman's body and thus a violation of security of the person.” Id. at 56–57.Google Scholar

Id. at 81.Google Scholar

In addition, the Court rejected the arguments of the defendants and ruled that Parliament does have a right to regulate abortion on a criminal basis and can establish therapeutic abortion committees as part of that regulation. Id. at 128–129.Google Scholar

Reuters, March 7, 1989.Google Scholar

For example, British Columbia issued a regulation denying funding for abortions unless a woman's life was threatened. B.C. Regulation 54/88 of February 10, 1988. Nova Scotia enacted legislation having the effect of prohibiting the performance of abortions outside hospitals. Medical Services Act S.N.S. 1989 and Regulations thereto adopted on July 20, 1989. The British Columbia Regulation was held to be invalid by the British Columbia Supreme Court (British Columbia Civil Liberties Assn. v. Attorney General, 24 B.C.L.R.2d 189 [1988]). Although an injunction prohibiting the opening of an abortion clinic was initially granted under the Nova Scotia legislation (Nova Scotia v. Morgentaler, 93 N.S.R.2d 202 [1990]), in October 1990 a Nova Scotia court held that the legislation was invalid. See Reuters, October 19, 1990.Google Scholar

In the summer of 1988 Parliament rejected a measure introduced by the government to allow abortion in the early stages of pregnancy if a physician believed that it was necessary to protect the woman's “physical or mental well-being”, as well as five other amendments of varying degrees of severity. The New York Times, July 29, 1988, Section A, p.3.Google Scholar

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Borowski v. Attorney-General of Canada, 57 D.L.R.4th 231 (1989).Google Scholar

Tremblay v. Daigle, 59 D.L.R.4th 609 (1989). The case involved an unmarried cohabiting couple, Mr. Tremblay and Ms. Daigle, who had separated approximately 18 weeks into the pregnancy. Ms. Daigle left the relationship because of alleged abusive behavior on the part of Mr. Tremblay, and before the injunction was issued, planned to have an abortion. She stated that she would suffer irreparable psychological and moral harm if forced to carry the child to term, that she did not want to have Mr. Tremblay's child or any contact with him, and that she did not want Mr. Tremblay to maintain a hold on her through the child. The other two requests for an injunction were denied at the provincial level. See Murphy v. Dodd, 70 O.R.2d 681 (1989) and Diamond v. Hirsch, Manitoba Queen's Bench, unreported.Google Scholar

Tremblay v. Daigle, [1989] 2 S.C.R.530.Google Scholar

It reasoned that the Charter expresses no intent on the part of its framers to include fetuses within its protection, that the Code treats a fetus as a human being only where it is necessary to do so in order to protect its interests after birth, and that under Anglo-Canadian law a fetus must be born in order to enjoy rights. Id.Google Scholar

The Court could have sidestepped the issue of fetal rights again by ruling that the case was moot since during the oral hearing the defendant's attorney announced that his client had already obtained an abortion. Instead, the Court presumably agreed with the attorney, who argued that settling the suit would be of importance to the women of Quebec and Canada. Id. at 538. Although the Court did not answer the question whether a fetus is entitled to the protections of Section 7 of the Canadian Charter, it can be surmised that, if pressed, it would answer no, given its analysis of legislative intent with respect to the Quebec Charter.Google Scholar

Bill C-43.Google Scholar

Justice Communique, November 3, 1989.Google Scholar

The Times, May 30, 1990.Google Scholar

See note 20 above.Google Scholar

See Henshaw, S., “Induced Abortion: A World Review, 1990,” 22 Family Planning Perspectives 76 (1990).Google Scholar

Despite the requirement that the approval of two physicians be obtained before an abortion is performed, abortions are widely available in England. Id. at 76.Google Scholar

A third law, the Offences Against the Person Act 1861, is also in effect. It prohibits a person from “unlawfully” performing or procuring abortions. In addition, the Abortion Act 1967 is not in effect in Northern Ireland.Google Scholar

[1987] 1 All E.R. 1230.Google Scholar

The Times, February 15, 1990. The suit was brought by the parents of a child suffering from spina bifida, who claimed that the defendants had been negligent in failing to detect signs of spina bifida in the fetus so that the mother could have had an abortion. In particular, they noted that a radiographer had, in fact, detected signs of a problem during a scan performed approximately the 26th week of pregnancy, but that no further action had been taken to notify the plaintiffs or to perform additional tests.Google Scholar

Id.Google Scholar

The case is also interesting for revealing that in 1990 a general state of confusion existed in England about when abortions could legally be performed. Three prominent obstetricians called as expert witnesses wrongly believed that abortions could be performed in the twenty-seventh week of pregnancy.Google Scholar

The Times, April 25, 1990 and June 22, 1990. The House of Commons rejected amendments to the bill that would have allowed abortion on demand during the first 12 weeks of pregnancy and extended the provisions of the Abortion Act 1967 to Northern Ireland. The changes in the abortion law were part of the larger Human Fertilisation and Embryology Bill, which allowed research on fetuses up to 14 days after fertilization.Google Scholar

The Independent, 19 October 1990, p.8. The bill was the occasion of considerable protest. The Archbishop of Westminster, Head of the Catholic Church in England, denounced proposed changes, and the Society for the Protection of Unborn Children (SPUC) sent life-size plastic fetuses of 20 weeks' gestation to members of Parliament. Sunday Telegraph, April 29, 1990, p.4; The Independent, April 24, 1990, p.6. Because emotions were so impassioned, the government announced that members of Parliament could vote their consciences on outstanding controversies in the bill. Id.Google Scholar

Note 38 above. The bill was endorsed by Sir David Steele, the force behind the 1967 liberalization, as well as the Royal College of Obstetricians and the British Medical Association. See The Independent, April 25, 1990.Google Scholar

Note 34 above at 77.Google Scholar

Tietze, C. and Henshaw, S.K., Induced Abortion: A World View 1986 (6th ed. 1986) at 21; The Times, April 25, 1990. See also Note 38 above.Google Scholar

Id.Google Scholar

Note 34 above at 77.Google Scholar

Frankowski, S.J. and Cole, G.F., eds., Abortion and the Protection of the Human Fetus(1987) at 119–121.Google Scholar

For example, in McGee v. Attorney General, [1974] 1 R 284, the Irish Supreme Court held that a law prohibiting the importation and sale of contraceptives violated a right to privacy in marital affairs.Google Scholar

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Irish Times, September 9, 1983. The Amendment was also criticized because it could be interpreted as outlawing post-coital birth control methods, including IUDs; because it might inflame sectarian strife and hinder efforts to reunite Ireland, and because it would be ineffective in decreasing the number of Irish women who travelled to England to obtain abortions.Google Scholar

Note 48 above at 122; The Independent, May 16, 1990. p.3.Google Scholar

Attorney General (S.P.U.C.) v. Open Door Counselling, [1987] I.L.R.M. 477.Google Scholar

Attorney General (S.P.U.C.) v. Open Door Counselling, [1989] I.L.R.M. 19.Google Scholar

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S.P.U.C. Ireland Ltd. v. Coogan, [1990] I.L.R.M. 70.Google Scholar

S.P.U.C. Ireland Ltd. v. Grogan, [1990] C.M.L.R. 689.Google Scholar

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See [1990] 8 I.L.T. 1.Google Scholar

As of January 1991 the Commission had ruled that the complaint was admissible, setting the stage for further action if the parties were unable to negotiate a settlement. (Communication with a representative of the Council of Europe.)Google Scholar

See, for example, Paton v. United Kingdom, [1980] 3 E.H.R.R. 408, where the Commission held that Article 2 of the European Convention on Human Rights did not give a husband the right to prevent his wife from obtaining a lawful abortion by asserting the right to life of a fetus of eight weeks' gestation.Google Scholar

See Matscher, F. and Petzold, H., eds., Protecting Human Rights: The European Dimension (1988).Google Scholar

Law No. 75-17 of January 17, 1975 (Journal officiel, January 18, 1975, p. 739), reenacted and amended by Law No. 79-1204 of December 31, 1979 (Journal officiel, January 1, 1980, p.3). Under this Law an abortion can be performed during the first ten weeks of pregnancy on a woman “whose condition places her in a condition of distress,” and later in pregnancy if two physicians certify that the pregnancy poses a serious danger to the woman's health or the fetus is suffering from a serious disease or condition. The determination of what constitutes “distress” is left to the woman.Google Scholar

Silverstre, L. et al, “Voluntary Interruption of Pregnancy with Mifespristone (RU 486) and a Prostaglandin Analogue,” 322 New England J. of Med., 645 (1990). RU 486 is an antiprogesterone drug which inhibits the activity of progesterone, a hormone that is necessary to begin or sustain pregnancy. Depending on when an antiprogestin drug is introduced, a fertilized ovum will not be able to attach itself to the wall of the uterus, or, if already attached, will become detached and abort. See Baulieu, E.E., “RU 486 as an Antiprogesterone Steroid: From Receptor to Contragestion and Beyond,” 262 Journal of the American Medical Association, 1808 (1989); Baulieu, E.E., “Contragestion and Other Clinical Applications of RU 486, an Antiprogesterone at the Receptor,” 245 Science, 1351 (1989).Google Scholar

See The New York Times, October 29, 1988, Section 1, p.1 and February 12, 1989, Section 6, p.23; Newsday, May 29, 1989, p.5 and April 24, 1989, p.31.Google Scholar

Hoechst, A.G., the major stockholder of Roussel-UCLAF, was particularly upset over comparisons protesters were making between it and I.G. Farben, its corporate predecessor, which had manufactured the poison gas used in Nazi gas chambers in World War II. It also did not want to have to decide whether selling an abortifacient violated the company's credo to support life. The New York Times. February 12, 1989. In the United States the RCR Alliance was established specifically to put pressure on Roussel-UCLAF and Hoechst. As outlined by its spokesperson, the strategy of Hoechst was three-fold: a) to threaten to organize an economic boycott of firms holding stock in Roussel-UCLAF and Hoechst; b) to threaten to picket and perform acts of civil disobedience; and c) to threaten to tie the company up in litigation with third world plaintiffs using RU 486. Newsday, May 29, 1989, p.5. Subsequently, the drug was characterized as a weapon of “chemical war on innocent human beings” (The Reuter Library Report, November 4, 1989).Google Scholar

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The New York Times, February 12, 1989, Section 6, p.23.Google Scholar

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Journal officiel, January 12, 1989, p.465.Google Scholar

Journal officel, February 25, 1990, p.2452.Google Scholar

Cook, R.J., “Antiprogestin Drugs: Medical and Legal Issues,” 21 Family Planning Perspectives 267 (1989) at 268–269.Google Scholar

Note 64 above, New England J. of Med.Google Scholar

Abortions using vacuum aspiration are usually performed about six weeks following a missed period, while abortions using RU 486 can be performed between one day and three weeks following a missed period.Google Scholar

Note 15 above at 51.Google Scholar

In addition, Article 383 of the Penal Code, enacted in 1923, forbade all publicity and aid with respect to abortion.Google Scholar

Note 15 above at 49–53; Jacobs, V., L'Avortement aujord'hui, Brussels (1983) at 7–10.Google Scholar

Id. at 10–21.Google Scholar

Journal des tribunaux (1983) 522.Google Scholar

Note 15 above at 52; Pasicrisie belge (1985) 670; Revue de jurisprudence de Liege, Mons et Bruxelles (1988) 1448; The Reuter Library Report, November 14, 1988.Google Scholar

Note 15 above at 50.Google Scholar

Id. at 59.Google Scholar

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Recueil annuel de jurisprudence belge (1988) 163.Google Scholar

Note 15 above at 52; Reuters, February 15, 1988; The Reuter Library Report, November 14, 1988 and March 29, 1990.Google Scholar

Law of April 4, 1990. Approval of the Law by Parliament provoked a constitutional crisis in Belgium. Before a bill can become law it must be signed by the King, and King Baudouin refused to sign. He informed the Prime Minister that the Bill presented him with a “serious problem of conscience” because he feared that it would “significantly diminish the respect for life of the weakest.” During secret meetings held over the next several days the government devised a plan to deal with the King's refusal to sign. The King would be removed from office temporarily, the Cabinet would sign the Bill, and then Parliament would reinstate the Constitution, which authorizes the Cabinet to determine that the King is “unable to reign” and assume power. Execution of this plan caused enormous controversy. A number of politicians called for the abdication of the King, the abolition of the monarchy, or amendment of the Constitution. At least one legal scholar objected to the reliance of the government on Article 82 of the Constitution, explaining that the Article was meant to be applied only if the King was sick, insane, or physically unable to exercise his office. As of February, 1991, no action to change the Constitution had been taken. See The Reuter Library Report, April 5, 1990; The New York Times, April 5, 1990, Section A, p.14 and April 6, 1990, Section A, p.3.Google Scholar

Note 63 above.Google Scholar

Note 48 above at 241–242.Google Scholar

Decree No. 770 of September 29, 1966 (Buletinul Oficial al Republicii Socialiste Romania, Part I, October 1, 1966, No. 60, p. 416; 18 International Digest of Health Legislation 822 [1967]). See also David, H.P., “Romania Ends Compulsory Childbearing,” 18 Population Today 4 (1990). Previously Romania had one of the most liberal laws in the world. Abortions were available virtually on request. See Decree No. 463 of September 30, 1957 (Buletinul Oficial, Part I No. 26, September 30, 1957.Google Scholar

Zlatescu, V. D., “L'imperatif de l'accroissment de la population de la Roumanie et les moyens juridiques de realisation de la politique demographique,” 25 Revue Roumaine des Sciences Sociales 57 (1981) at 59. According to some reports President Ceausescu wanted to increase the population to 30 million by the year 2000. See The Boston Globe, April 29, 1990; The Independent, February 7, 1990. The fall in the birthrate has been attributed to changes in the age structure of women, increased professional activity of women without increased relief from household obligations, lack of housing and child care services, and the increased availability of abortions. See Note 48 above at 271–272.Google Scholar

Decree No. 53 of February 16, 1972 (Buletinul Oficial Romania, Part I, February 17, 1972, No. 21, p. 160; 25 International Digest of Health Legislation 433 [1974]).Google Scholar

Medical indications for abortion are set forth in instructions No. 819 of October 19, 1966 of the Ministry of Health and Social Welfare (18 International Digest of Health Legislation 824 [1967]).Google Scholar

Note 48 above at 324; United Nations, Demographic Yearbook, 1987, New York, 1989, at 334.Google Scholar

Buletinul Oficial, Part I, No. 18, March 3, 1984; 10 Population and Development Review 572 (1984).Google Scholar

The practice of terminating pregnancies was characterized as “an anti-national and anti-social action, as it prevents the normal development of our people, and the most resolute action—in keeping with the laws and regulations—[is] demanded to combat and eliminate it.” All involved organizations were strongly urged to undertake “control mechanisms” and “severe” measures to prevent illegal abortions. On March 7, 1984 President Ceausescu reinforced this line of thought, stating “To have and raise children is the loftiest patriotic duty of each family….[O]ne has the duty to permanently think of the present and future of the people.” He also termed abortion “an abusive impermissible practice.” The British Broadcasting Corporation, Summary of World Broadcasts, March 9, 1984, Part II B., p. EE/7587/B/1.Google Scholar

Reuters, June 29, 1985; The Washington Post, March 28, 1990 and June 7, 1990; Note 89 above, Population Today. No legislation specifically mandating such exams was ever published in Romania's Official Gazette, although the provisions of the Resolution of March 3, 1984 did call for “improvements in the supervision of pregnant women,” local “monthly analys[e]s of demographic developments,” and other such broad measures.Google Scholar

Decree No. 411 of December 26, 1985 (Buletinul Oficial Romania, Part I, No. 76, December 26, 1985; 12 Annual Review of Population Law 36 [1985]). In addition, monthly chilbirth and child allowances were increased as was the tax contribution to be made by childless persons. The latter was almost doubled for workers in the highest income brackets and quadrupled for workers receiving the lowest salaries. Decree No. 410 of December 26, 1985 (Buletinul Oficial, Part I, No. 76, December 26, 1985; 12 Annual Review of Population Law 94 [1985]) and Decree No. 409 of December 26, 1985; 12 Annual Review of Population Law 17 [1985]).Google Scholar

Decree-Law No. 1, December 26, 1989 (Monitorul Oficial al Romniei, No. 4, December 27, 1989, p.1). Contrary to some reports this Decree-Law had no effect on contraceptives.Google Scholar

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The Independent, February 7, 1990. In addition, it was reported that 10 percent of orphans under three years old tested positive for the AIDS virus. The New York Times, 24 June 1990. Indeed, the Government had become so embarrassed about its increased infant mortality rate that it tried to disguise it by imposing in 1987 a 30 day delay in recognizing births so as not to report those children who had died during the first month of life. Note 89 above, Population Today at 10; The Economist, 20 January 1990; The New York Times, 10 January 1990, Section A, p.27. In the month following the repeal of the laws restricting abortion an estimated 10,000 abortions were performed in Bucharest alone. The Chicago Tribune, March 8, 1990.Google Scholar

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Note 48 above at 324.Google Scholar

Decree No. 2 of February 1, 1990 (Durzaven Vestnik, No. 12, February 9, 1990, p. 4).Google Scholar

Although newspapers have reported that the government had banned contraceptives, no legislation doing so appeared in the Offical Gazette. It is more likely that the government took steps to make sure that contraceptives, althoush legal, were unavailable. Indeed, contraceptives were not readily available in Romania even before 1984 and abortion was used as a form of birth control. See Frejka, T., “Induced Abortion and Fertility: A Quarter Century of Experience in Eastern Europe,” 9 Population and Development Review 494 (1983) at 516. In 1965 1.1 million abortions were performed in Romania, more than in the rest of Eastern Europe combined, excluding the Soviet Union. Note 48 above at 318–323.Google Scholar

In 1984 the birthrate increased to 15.5 per thousand. Note 93 above, Demographic Yearbook at 334.Google Scholar

Note 48 above at 318, 324.Google Scholar

It has been reported that abortions are performed on request during the first 12 weeks of pregnancy and for medical reasons thereafter. See 19 Planned Parenthood in Europe, 5 (1990).Google Scholar

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After the Governor vetoed the first law, the Louisiana legislature enacted legislation containing these restrictions which was also vetoed. The New York Times, July 28, 1990, Section 1., p. 1. Legislation vetoed by the Governor of Idaho would have prohibited abortions except in case of rape, incest, severe fetal deformity, or threat to life or physical health. The New York Times, March 30, 1990, Section 1, Part 1, p. 10.Google Scholar

See “Editorial,” 79 Americal Journal of Public Health, 689 (1989).Google Scholar

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Commendable in itself is the fact that France, as well as England and most other industrialized countries—unlike the United States—pay directly for the performance of abortions or reimburse their costs under their health insurance schemes. See Eser, A. and Koch, H.G. Schwangerschaftsabbruch in internationalen Vergleich (1988); Ketting, E. and Van Praeg, P. Schwangerschaftsabbruch: Gesetz und Praxis in internationalen Vergleich (1985); Note 45 above, Tietze.Google Scholar

Note 72 above at 269–270.Google Scholar

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