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Louisiana Amendment 1, No Right to Abortion in Constitution Amendment (2020)

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Louisiana Amendment 1
Flag of Louisiana.png
Election date
November 3, 2020
Topic
Abortion
Status
Approveda Approved
Type
Constitutional amendment
Origin
State legislature


Louisiana Amendment 1, the No Right to Abortion in Constitution Amendment, was on the ballot in Louisiana as a legislatively referred constitutional amendment on November 3, 2020.[1] It was approved.

A "yes" vote supported adding language to the Louisiana Constitution stating that "nothing in this constitution shall be construed to secure or protect a right to abortion or require the funding of abortion."

A "no" vote opposed adding language to the Louisiana Constitution stating that "nothing in this constitution shall be construed to secure or protect a right to abortion or require the funding of abortion."

Election results

Louisiana Amendment 1

Result Votes Percentage

Approved Yes

1,274,167 62.06%
No 779,005 37.94%
Results are officially certified.
Source


Overview

What did Amendment 1 add to the Louisiana Constitution?

The constitutional amendment added a sentence to the Louisiana Declaration of Rights: "To protect human life, nothing in this constitution shall be construed to secure or protect a right to abortion or require the funding of abortion."[1]

What did Amendment 1 have to do with state courts?

As of 2019, at least 10 states, according to The Guttmacher Institute, provided a state constitutional right to abortion based on court rulings. In April 2019, the Kansas Supreme Court held that the Kansas Bill of Rights included "a woman's right to make decisions about her body, including the decision whether to continue her pregnancy."[2] Tennessee (2014), Alabama (2018), and West Virginia (2018) each passed constitutional amendments that, like the proposed amendment to the Louisiana Constitution, declared that their constitutions cannot be interpreted as securing or protecting a right to abortion or requiring the funding of abortion.

What did Amendment 1 have to do with Roe v. Wade?

If the U.S. Supreme Court overturns Roe v. Wade, which held that abortion could not be banned before fetal viability under the U.S. Constitution's Fourteenth Amendment, states could be permitted to prohibit abortions. In the 10 states where courts have held that abortion is a constitutional right under their state constitutions, state governments would not be able to ban abortion without a state constitutional amendment or a different ruling in the future.

Text of measure

Ballot title

The ballot title was as follows:[1]

Do you support an amendment declaring that, to protect human life, a right to abortion and the funding of abortion shall not be found in the Louisiana Constitution? (Adds Article I, Section 20.1)[3]

Ballot summary

The ballot summary was as follows:[4]

Proposed Constitutional Amendment provides that in order to protect human life, nothing in the present constitution shall be construed to secure or protect a right to abortion or require the funding of abortion.[3]

Constitutional changes

See also: Article I, Louisiana Constitution

The measure added a Section 20.1 to Article I of the Louisiana Constitution. The following underlined text would be added:[1]

Section 20.1. To protect human life, nothing in this constitution shall be construed to secure or protect a right to abortion or require the funding of abortion.[3]

Readability score

See also: Ballot measure readability scores, 2020
Using the Flesch-Kincaid Grade Level (FKGL and Flesch Reading Ease (FRE) formulas, Ballotpedia scored the readability of the ballot title and summary for this measure. Readability scores are designed to indicate the reading difficulty of text. The Flesch-Kincaid formulas account for the number of words, syllables, and sentences in a text; they do not account for the difficulty of the ideas in the text. The state legislature wrote the ballot language for this measure.


The FKGL for the ballot title is grade level 7, and the FRE is 59. The word count for the ballot title is 32, and the estimated reading time is 8 seconds. The FKGL for the ballot summary is grade level 9, and the FRE is 44. The word count for the ballot summary is 33, and the estimated reading time is 8 seconds.


Support

Love Life campaign logo

The Louisiana Pro-Life Amendment Coalition led the campaign in support of Amendment 1.[5] Supporters referred to the constitutional amendment as the Love Life Amendment.[6]

Supporters

Officials

Organizations

  • Americans United for Life
  • Democrats for Life of America
  • Louisiana Conference of Catholic Bishops
  • Louisiana Right to Life

Arguments

  • Louisiana State Senator and sponsor of the measure Katrina Jackson (D): "This amendment makes sure there is no right to abortion or taxpayer funding of abortion in our state constitution. By passing this we can rest assured that, together with our state law, we will never become like New York, which recently legalized abortion up to the very moment before birth."
  • Dorinda Bordlee, a lawyer for the Bioethics Defense Fund: "This gives the judiciary something to interpret very clearly, where they can’t find through some provision or another, a right to abortion."
  • Public Affairs Research Council of Louisiana: The Public Affairs Research Council of Louisiana (PAR), a nonprofit organization, published arguments for and against each amendment on the ballot. PAR wrote the following argument in support of Amendment 1: "The purpose of this amendment is to place the abortion issue in the hands of the people through their elected officials and their statewide vote on this amendment, rather than with their state court judges. Supreme courts in 13 other states have interpreted their constitutions to discover a state right to abortion and have used that to strike down laws for mandatory ultrasounds, 72-hour waiting periods and other limitations. This amendment will prevent that from happening in Louisiana. Judicial consideration of such important issues should be decided on the clear intent of law passed by the Legislature rather than on legal ambiguities."

Campaign advertisements

The following video was released by Louisiana Right to Life:[7][8]

Title: "Love Life and Vote Yes on Nov. 3, 2020!"

Opposition

Louisiana for Personal Freedoms campaign logo

Louisiana for Personal Freedoms led the campaign in opposition to the amendment.[9]

Opponents

Organizations

  • ACLU of Louisiana
  • Choice Louisiana
  • Democracy for America
  • Forum for Equality
  • Hope Medical Group for Women
  • Independent Women's Organization
  • League of Women Voters of Louisiana
  • Louisiana Trans Advocates
  • National Council of Jewish Women
  • National Organization for Women PAC
  • New Orleans Abortion Fund
  • Planned Parenthood Gulf Coast
  • Reproductive Justice Action Collective
  • Women With a Vision

Arguments

  • Katie Schwartzmann, legal director for the ACLU of Louisiana: "There are multiple anti-abortion bills moving their way through the state legislature, you know, and I think this bill that we were just discussing really shows what the real objective is here, which is to actually outlaw abortion, to make it completely outside the reach of a woman, and we think this unnecessarily invades the very private, very personal medical decisions that every woman has the right to make. This is the government reaching in and telling you what kind of medical care you can and can’t have."
  • Steffani Bangel, the outreach manager for the New Orleans Abortion Fund: "People in Louisiana suffer when restrictions like these are passed. Women are suffering now, and so too are the children born into families that couldn’t support them."
  • Public Affairs Research Council of Louisiana: The Public Affairs Research Council of Louisiana (PAR), a nonprofit organization, published arguments for and against each amendment on the ballot. PAR wrote the following argument in opposition to Amendment 1: "If Roe v. Wade is not overturned, this amendment at best would be pointless and at worst could result in the courts allowing further restrictions on access and funding. Women who want to end a pregnancy cannot wait for long court battles to determine their rights. Louisiana law already withholds state and local funding for abortion and bans Medicaid funding up to the extent of federal law. Funding prohibitions restrict access to women least able to afford abortions. The amendment has no exceptions for cases involving rape, incest or the mother’s risk of death. Louisiana already has a law to ban abortion if Roe vs. Wade is overturned."
  • Pearl Ricks, executive director of the Reproductive Justice Action Collective: "Politicians should not get the final say on your body, or anybody out there. We want to make sure that Louisiana knows it is in our hands right now."


Campaign finance

See also: Campaign finance requirements for Louisiana ballot measures

Ballotpedia identified one committee—Louisiana Pro-Life Amendment Coalition—registered in support of Amendment 1 and one committee—Louisiana for Personal Freedoms, Inc.—registered in opposition to Amendment 1.[10]

Cash Contributions In-Kind Contributions Total Contributions Cash Expenditures Total Expenditures
Support $680,741.75 $450.00 $681,191.75 $680,921.75 $681,371.75
Oppose $346,104.00 $82,720.22 $428,824.22 $165,035.21 $247,755.43
Total $1,026,845.75 $83,170.22 $1,110,015.97 $845,956.96 $929,127.18

Support

The following were contribution and expenditure totals for the committee in support of Amendment 1.[10]

Committees in support of Amendment 1
Committee Cash Contributions In-Kind Contributions Total Contributions Cash Expenditures Total Expenditures
Louisiana Pro-Life Amendment Coalition $680,741.75 $450.00 $681,191.75 $680,921.75 $681,371.75
Total $680,741.75 $450.00 $681,191.75 $680,921.75 $681,371.75

Top donors

The following is a list of the top donors that contributed to Louisiana Pro-Life Amendment Coalition:[10]

Donor Cash Contributions In-Kind Contributions Total Contributions
LA Right to Life Educational Committee $280,000.00 $0.00 $280,000.00
Edward L. Rispone $50,000.00 $0.00 $50,000.00
Donald T. Bollinger $25,000.00 $0.00 $25,000.00
Kenneth Wood Sr. $25,000.00 $0.00 $25,000.00
William Henry Shane Jr. $20,000.00 $0.00 $20,000.00

Opposition

Committees in support of Amendment 1
Committee Cash Contributions In-Kind Contributions Total Contributions Cash Expenditures Total Expenditures
Louisiana for Personal Freedoms, Inc. $346,104.00 $82,720.22 $428,824.22 $165,035.21 $247,755.43
Total $346,104.00 $82,720.22 $428,824.22 $165,035.21 $247,755.43

Top donors

The following is a list of the top donors that contributed to Louisiana for Personal Freedoms, Inc.:[10]

Donor Cash Contributions In-Kind Contributions Total Contributions
BYP 100 $150,000.00 $0.00 $150,000.00
Open Society $100,000.00 $0.00 $100,000.00
Lift Louisiana $0.00 $80,758.12 $80,758.12
Planned Parenthood Action Fund $50,000.00 $1,448.10 $51,448.10
Catholics for Choice $5,000.00 $0.00 $5,000.00

Methodology

To read Ballotpedia's methodology for covering ballot measure campaign finance information, click here.

Background

Senate Bill 184 (2019)

In 2019, the Louisiana State Legislature passed Senate Bill 184 (SB 184), which Gov. John Bel Edwards (D) signed on May 30, 2019.[11]

SB 184 was designed to ban abortion when a fetal heartbeat is present, except to prevent death or substantial and irreversible impairment of a major bodily function of the pregnant woman.

SB 184 also included a provision that would prohibit knowingly performing an abortion, except to prevent death, a substantial risk of death, or a serious and permanent impairment to life-sustaining organs of a pregnant woman, should the U.S. Supreme Court allow states to prohibit elective abortions or a federal constitutional amendment is passed to allow states to prohibit elective abortions.[11]

The legislative votes on SB 184 were as follows:[11]

Vote in the Louisiana State Senate
May 6, 2019
Requirement: Simple majority vote of all members in each chamber
YesNoNot voting
Total3153
Total percent79.49%12.82%7.69%
Democrat653
Republican2500

Vote in the Louisiana House of Representatives
May 29, 2019
Requirement: Simple majority vote of all members in each chamber
YesNoNot voting
Total79233
Total percent75.24%21.90%2.86%
Democrat16221
Republican6002
Independent310

U.S. Supreme Court on abortion

Roe v. Wade

In 1973, the Supreme Court of the United States issued its ruling in Roe v. Wade, finding that state laws prohibiting abortion prior to fetal viability violated the Due Process Clause of the Fourteenth Amendment of the United States Constitution. The high court held that states can regulate and/or prohibit abortions (except to preserve the life or health of the mother) once a fetus reaches the point of viability. In Roe v. Wade, the court defined fetal viability as "the interim point at which the fetus becomes 'viable,' that is, potentially able to live outside the mother's womb, albeit with artificial aid." The high court further stated that "viability is usually placed at about seven months (28 weeks) but may occur earlier, even at 24 weeks."[12]

The ruling established a strict trimester framework to guide state abortion policies. States, according to this framework, were prohibited from banning or regulating abortion during the first trimester of pregnancy. During the second trimester, states were permitted to regulate abortion to protect the mother's health. During the third trimester, states were allowed to ban abortion, except in cases where an abortion is needed to preserve the life or health of the mother.[12]

Planned Parenthood v. Casey

In Planned Parenthood v. Casey of 1992, the Supreme Court reaffirmed the essential holding of Roe v. Wade but rejected the strict trimester framework established in that case. The high court affirmed that states could not ban abortions before fetal viability. However, according to the court, neonatal care developments since Roe v. Wade meant fetal viability occurred somewhat earlier than the start of the third trimester of pregnancy.[13]

The ruling in Planned Parenthood v. Casey also provided for a standard of undue burden to determine whether a law created substantial obstacles for a woman seeking an abortion before fetal viability. Unlike in Roe v. Wade, the court permitted states to regulate abortion during the first trimester if the regulations did not create an undue burden for women.[13]

State constitutions on abortion

As of 2019, at least nine states provided a state constitutional right to abortion based on court rulings.[14] Ballotpedia has identified five ballot measures to amend state constitutions to declare that nothing in the state constitution provides a right to abortion. In Tennessee (2014), Alabama (2018), and West Virginia (2018), these constitutional amendments were passed. In Massachusetts (1986) and Florida (2012), these constitutional amendments were defeated.

The following map illustrates the states where courts have ruled that a right to abortion exists under the state constitution and states with constitutional amendments stating that no right to abortion exists under the state constitution:

Rulings for state constitutional rights

At least nine states provide a right to abortion under their state constitutions based on court rulings. None of these states provide an explicit constitutional right to abortion; rather, state courts have ruled that provisions related to privacy, liberty, and equality provide a right to abortion. The following is a list of states where courts have ruled that state constitutions provide a right to abortion:[14]

  • Alaska: In Valley Hospital Association v. Mat-Su Coalition for Choice (1997), the Alaska Supreme Court ruled that Amendment 3 (1972), which declared that people have a right to privacy, provided a right to abortion.[15] Attorney General Kevin Clarkson (R), appointed in 2018, said, "Basically, Alaska provides more protection for abortion rights than the federal Constitution. So if Roe vs. Wade were overturned, in Alaska, nothing would change. ... What could change things in Alaska to move it towards a more protective-of-life perspective would be an amendment to the Alaska Constitution."[16]
  • California: In People v. Belous (1969), the California Supreme Court ruled that women have "[constitutional] rights to life and to choose whether to bear children." The court's ruling stated that "the fundamental right of the woman to choose whether to bear children follows from the Supreme Court's and this court's repeated acknowledgment of a "right of privacy" or "liberty" in matters related to marriage, family, and sex."[17] Voters approved Proposition 11 in 1972, which established a constitutional right to privacy. The state Supreme Court cited Proposition 11 in Committee to Defend Reproductive Rights v. Myers (1981), which stated that "the protection afforded the woman's right of procreative choice as an aspect of the right of privacy under the explicit provisions of our Constitution."[18] In 2002, the California State Legislature passed the Reproductive Privacy Act, which added language to state statute declaring that women have a "fundamental right to choose to bear a child or to choose and to obtain an abortion."[19] Voters rejected the constitutional amendment.
  • Florida: The Florida Supreme Court decided the case In re T.W., a Minor in 1989, holding that Amendment 2, passed in 1980, included a right to abortion before viability. The state Supreme Court's ruling said that Amendment 2, which established a state constitutional right to privacy, "is clearly implicated in a woman's decision of whether or not to continue her pregnancy."[20] In 2004, the Florida State Legislature referred Amendment 1, which required parental notification for a minor to receive an abortion, to the ballot.[21] Amendment 1 exempted the notification from the constitutional right to privacy. Voters approved Amendment 1. In 2011, the state legislature referred a Amendment 6 to the ballot for November 6, 2012. Amendment 6 contained a provision that stated, "This constitution may not be interpreted to create broader rights to an abortion than those contained in the United States Constitution."[22] Voters rejected Amendment 6.
  • Iowa: In 2018, the Iowa Supreme Court held that women have a state constitutional right to abortion in Planned Parenthood v. Reynolds. Chief Justice Mark Cady wrote, "Autonomy and dominion over one’s body go to the very heart of what it means to be free. ... We therefore hold, under the Iowa Constitution, that implicit in the concept of ordered liberty is the ability to decide whether to continue or terminate a pregnancy."[23] During the 2019 legislative session, several joint resolutions were introduced to amend the Iowa Constitution to state that nothing in the constitution secured or protected a right to abortion or abortion funding. However, none of the resolutions were passed.[24]
  • Kansas: The Kansas Supreme Court ruled in Hodes & Nauser v. Schmidt (2019) that Section 1 of the Kansas Bill of Rights included "a woman's right to make decisions about her body, including the decision whether to continue her pregnancy." Section 1 was part of the original Kansas Constitution of 1861, reading, "All men are possessed of equal and inalienable natural rights, among which are life, liberty, and the pursuit of happiness."[2] Senate President Susan Wagle (R-30) said a ballot measure to amend the state constitution in response to the ruling was possible. Sen. Wagle stated, "I think the consequences of that ruling are still being determined. We really need some time to figure out how we’ll address it and I think the voters of Kansas will want to have a say in an election year."[25]
  • Massachusetts: In Moe v. Secretary of Administration and Finance (1981), the Massachusetts Supreme Judicial Court held that "The Massachusetts Declaration of Rights affords a greater degree of protection to a woman's right to decide whether or not to terminate a pregnancy by abortion than does the Federal Constitution."[26] The Massachusetts General Court referred a constitutional amendment to the ballot in 1986, which stated, "Nothing in this Constitution shall prevent the General Court from regulating or prohibiting abortion unless prohibited by the United States Constitution, nor shall anything in this Constitution require public or private funding of abortion, or the provision of services or facilities therefor, beyond that required by the United States Constitution."[27]
  • Minnesota: The Minnesota Supreme Court ruled in Women of Minnesota v. Gomez (1995) that "under our interpretation of the Minnesota Constitution's guaranteed right to privacy, the difficult decision whether to obtain a therapeutic abortion will not be made by the government, but will be left to the woman and her doctor." The state Supreme Court cited Sections 2, 7, and 10 of Article I of the Minnesota Constitution to determine that women had a constitutional right to abortion.[28]
  • Montana: In Armstrong v. State (1999), the Montana Supreme Court held that Section 10 of Article II of the Montana Constitution provided women with a right of procreative autonomy, including an abotion before fetal viability. Section 10 read, "The right of individual privacy is essential to the well-being of a free society and shall not be infringed without the showing of a compelling state interest." The provision was included as part of the 1972 Montana Constitution.[29]
  • New Jersey: In 2000, the New Jersey Supreme Court ruled that abortion is a state constitutional right in Planned Parenthood of Central New Jersey v. Farmer. The ruling stated that Section 1 of Article I of the New Jersey Constitution "incorporates within its terms the right of privacy and its concomitant rights, including a woman's right to make certain fundamental choices."[30]

Amendments declaring no state constitutional rights

As of 2019, three states had constitutional amendments declaring that their constitution does not secure or protect a right to abortion or require the funding of abortion. The first state to pass a constitutional amendment was Tennessee in 2014. In 2018, Alabama and West Virginia passed constitutional amendments. Arkansas has a constitutional amendment, passed in 1988, that says "The policy of Arkansas is to protect the life of every unborn child from conception until birth, to the extent permitted by the Federal Constitution."

  • Tennessee Amendment 1 (2014): Amendment 1 received 52.6 percent of the vote, making Tennessee the first state with an amendment proclaiming that the state constitution does not secure or protect a right to abortion or require the funding of abortion. Amendment 1 was proposed as a response to the Tennessee Supreme Court's ruling in Planned Parenthood v. Sundquist (2000), which held that the state constitution provided a right to procreational autonomy. Sen. Mae Beavers (R-17), who was a legislative sponsor of Amendment 1, said, "[The amendment] is meant to neutralize the 2000 [state] Supreme Court decision."[31]
  • Alabama Amendment 2 (2018): Amendment 2 received 59.0 percent of the vote. Amendment 2 declared that the state constitution does not secure or protect a right to abortion or require the funding of abortion. The constitutional amendment also said the state's public policy was to "recognize and support the sanctity of unborn life and the rights of unborn children, including the right to life." In the Alabama State Legislature, Amendment 2 received the vote of Republicans, but Democrats voted 3-31.[32]
  • West Virginia Amendment 1 (2018): Amendment 1 passed with 51.7 percent of the vote. Amendment 1 declared that the state constitution does not secure or protect a right to abortion or require the funding of abortion. According to the West Virginia Bureau for Medical Services, Amendment 1 invalidated the state Supreme Court's ruling in West Virginia Women’s Health Center v. Panepinto (1993), which held that the state had to fund abortion via Medicaid.[33] Legislative Republicans voted to put the constitutional amendment on the ballot. Democrats voted 3-9 in the House and 10-25 in the Senate.[34]

Path to the ballot

See also: Amending the Louisiana Constitution

In Louisiana, a two-thirds vote is needed in each chamber of the Louisiana State Legislature to refer a constitutional amendment to the ballot for voter consideration.

State Rep. Katrina Jackson (D-16) introduced the constitutional amendment as House Bill 425 (HB 425) on March 29, 2019. The House Civil Law and Procedure Committee passed HB 425 in a 7-0 vote on April 16. The full state House approved the constitutional amendment on April 23, with 81 members supporting the bill, 10 members opposing the bill, and 14 members not voting. At least 70 votes were needed to pass HB 425.[35]

The state Senate approved HB 425 on May 21, 2019, but modified the intent and purpose section of the bill. The state Senate voted 31 to four with four members absent. At least 26 votes were needed to pass HB 425.[35] Because the state Senate modified HB 425, a concurrence vote was needed in the state House to refer the constitutional amendment to the ballot.

The state House rejected concurrence with the Senate's modified HB 425 and instead asked for a conference committee. The state House appointed Katrina Jackson (D-16), Ray Garofalo (R-103), and Dustin Miller (D-40) to the committee. The state Senate appointed Rick Ward III (R-17), Gerald Boudreaux (D-24), and Beth Mizell (R-12) to the committee. The conference committee recommended passing HB 425 without the Senate's change and changing the election date from October 12, 2019 to November 3, 2020.[35] Rep. Jackson said she wanted the election date changed because "I think it'll help the pro-life Democrats, but at the same time it may hurt other Democrats. I think it'll help my election but it's not all about me."[36] In Louisiana, state legislative and executive elections were held in odd-numbered years, such as 2019.

On June 5, 2019, the state House approved the conference's HB 425 in a vote of 78 to 21, and the state Senate approved the conference's HB 425 in a vote of 33 to five.[35] With approval in both legislative chambers, HB 425 was referred to the ballot for the election on November 3, 2020.

Vote in the Louisiana House of Representatives
June 5, 2019
Requirement: Two-thirds (66.67 percent) vote of all members in each chamber
Number of yes votes required: 70  Approveda
YesNoNot voting
Total78216
Total percent74.29%20.00%5.71%
Democrat16203
Republican5903
Independent310

Vote in the Louisiana State Senate
June 5, 2019
Requirement: Two-thirds (66.67 percent) vote of all members in each chamber
Number of yes votes required: 26  Approveda
YesNoNot voting
Total3351
Total percent84.62%12.82%2.56%
Democrat851
Republican2500

How to cast a vote

See also: Voting in Louisiana

Click "Show" to learn more about voter registration, identification requirements, and poll times in Louisiana.

See also

External links

Support

Opposition

Footnotes

  1. 1.0 1.1 1.2 1.3 Louisiana State Legislature, "HB 425," accessed April 24, 2019
  2. 2.0 2.1 NPR, "Kansas Supreme Court Rules State Constitution Protects Right To Abortion," April 26, 2019 Cite error: Invalid <ref> tag; name "kansasruling" defined multiple times with different content
  3. 3.0 3.1 3.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source. Cite error: Invalid <ref> tag; name "quotedisclaimer" defined multiple times with different content
  4. Louisiana Secretary of State, "2020 Ballot Questions," accessed August 20, 2020
  5. Louisiana Pro-Life Amendment Coalition, "Homepage," accessed June 5, 2019
  6. The News Star, "Louisiana voters to decide whether to add abortion ban to constitution," June 5, 2019
  7. YouTube, "‘Protect Dogs’ drops new video on greyhound industry," accessed July 21, 2018
  8. YouTube, "Love Life and Vote Yes on Nov. 3, 2020!" accessed September 10, 2020
  9. Louisiana for Personal Freedoms, "Home," accessed July 23, 2020
  10. 10.0 10.1 10.2 10.3 Louisiana Ethics Administration Porgram, "Campaign Finance Portal: Louisiana Political Action Committees," accessed June 8, 2020
  11. 11.0 11.1 11.2 Louisiana State Legislature, "Senate Bill 184," accessed June 5, 2019
  12. 12.0 12.1 U.S. Supreme Court, "Roe v. Wade," January 22, 1973
  13. 13.0 13.1 U.S. Supreme Court, "Planned Parenthood v. Casey," June 29, 1992
  14. 14.0 14.1 The Guttmacher Institute, "Ensuring Access to Abortion at the State Level: Selected Examples and Lessons," January 9, 2019
  15. Alaska Supreme Court, "Valley Hospital Association v. Mat-Su Coalition for Choice," November 21, 1997
  16. Alaska Public Media, "What happens if Roe v. Wade goes? In Alaska, ‘nothing’," September 10, 2018
  17. California Supreme Court, "People v. Belous, September 5, 1969
  18. California Supreme Court, "Committee to Defend Reproductive Rights v. Myers," March 20, 1981
  19. California State Legislature, "Reproductive Privacy Act," September 5, 2002
  20. Florida Supreme Court, "In re T.W., a Minor," October 5, 1989
  21. Florida State Legislature, "House Joint Resolution 1," accessed June 25, 2019
  22. Florida State Legislature, "House Joint Resolution 1179," accessed June 25, 2019
  23. Iowa Supreme Court, "Planned Parenthood v. Reynolds," September 18, 2018
  24. Des Moines Register, "Gov. Kim Reynolds supports anti-abortion language in the Iowa Constitution," February 5, 2019
  25. The Wichita Eagle, "Abortion opponents say they’ll wait until 2020 to seek to change Kansas constitution," May 3, 2019
  26. Massachusetts Supreme Judicial Court, "Moe v. Secretary of Administration and Finance," February 18, 1981
  27. Massachusetts General Court, "House Bill 3310," accessed June 25, 2019
  28. Minnesota Supreme Court, "Women of Minnesota v. Gomez," December 15, 1995
  29. Montana Supreme Court, "Armstrong v. State," October 26, 1999
  30. New Jersey Supreme Court, "Planned Parenthood of Central New Jersey v. Farmer," August 15, 2000
  31. Commercial Apparel, "Tennessee Senate advances abortion amendment," April 18, 2011
  32. Alabama State Legislature, "House Bill 98," accessed March 16, 2017
  33. West Virginia Metro News, "West Virginia’s rapid political shift on abortion," August 29, 2015
  34. West Virginia Legislature, "Senate Joint Resolution 12," accessed February 9, 2018
  35. 35.0 35.1 35.2 35.3 Louisiana State Legislature, "HB 425 Overview," accessed April 24, 2019
  36. Vice, "This Democrat Is Backing Louisiana’s Attack on Abortion," June 1, 2019
  37. Louisiana Secretary of State, "FAQ: Voting on Election Day," accessed August 15, 2024
  38. Louisiana Secretary of State, "Vote on Election Day," accessed August 15, 2024
  39. 39.0 39.1 39.2 Louisiana Secretary of State, "Register to Vote," accessed August 15, 2024
  40. WWNO, "Louisiana now requires proof of citizenship to vote, but hasn’t issued any guidance," January 15, 2025
  41. Louisiana Secretary of State, "Louisiana Voter Registration Application," accessed June 30, 2025
  42. Under federal law, the national mail voter registration application (a version of which is in use in all states with voter registration systems) requires applicants to indicate that they are U.S. citizens in order to complete an application to vote in state or federal elections, but does not require voters to provide documentary proof of citizenship. According to the U.S. Department of Justice, the application "may require only the minimum amount of information necessary to prevent duplicate voter registrations and permit State officials both to determine the eligibility of the applicant to vote and to administer the voting process."
  43. 43.0 43.1 Louisiana Secretary of State, "Vote on Election Day," accessed August 15, 2024
  44. Louisiana Secretary of State, "Louisiana voters' bill of rights and voting information," accessed August 15, 2024