Anti-choice activists in
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1. Women's lives and health are at stake.
2. Women’s liberty and conscience rights under the Charter require abortion to be funded.
3. Funding abortion is necessary to ensure women’s legal right to be free from discrimination.
4. Funding abortion is crucial to ensure fairness and equity, without discrimination on the basis of income.
5. Funding abortion is very cost-effective while unwanted pregnancies are costly.
6. Funding abortion serves to integrate abortion care into the healthcare system in general.
7. Funding abortion is the right thing to do, despite some peoples’ belief that abortion takes a human life.
8. Legal abortion is very safe for women, and generally beneficial.
9. Opinion polls showing that a majority of voters do not want to pay for abortion are misleading and not pertinent.
10. Abortion must be funded because it is not an elective procedure.
11. Women with unwanted pregnancies are not in a healthy place, and the argument that “pregnancy is not a disease” is invalid.
1. Women’s lives and health are at stake. Funding abortion is necessary to guarantee women's right to life and security of the person under the Charter of Rights and Freedoms. The main reason the Supreme Court threw out the old abortion law in 1988 was because it arbitrarily increased the risk to women’s health and lives through unnecessary delays and obstructed access. Not funding abortion would have the same effect and the same constitutional problems as the old abortion law, and would put politics and ideology ahead of women’s lives and health.
Abortion services are a critical component of public health programs, since many women will otherwise risk their lives to obtain unsafe, illegal abortions. Although no Canadian court has ever specifically ruled that abortion must be funded by taxpayers, if a legal challenge were made today, courts would likely uphold abortion funding as constitutional because it interferes with women’s equitable and unobstructed access to abortion in the same way that the old abortion law did, and therefore would negatively impact their right to life and security of the person. This was why the Supreme Court struck down the law in 1988 with the Morgentaler decision.
Charter protects the right to life and security of the
person under s.7. The right to security of the person
clearly entitles a woman to have control over her bodily
integrity. This right is compromised without funding for
abortion, since a right that becomes inaccessible or less
accessible for some women due to government restrictions is
a violated right. Further,
2. Women’s liberty and conscience rights under the Charter require abortion to be funded. The government must not interfere with the deeply personal decision to bear a child or not, which is integral to women’s autonomy and privacy. Otherwise, the government would be co-opting women's right to choose by funding childbirth but not abortion, and paternalizing women with an official stance of moral disapproval of abortion.
It is difficult to conceive of a life decision more self-defining than whether or not to become a mother. Profoundly-held personal and religious beliefs guide a decision of this gravity, and the consequences of this decision will determine a woman’s perception of herself. The government must allow a woman to follow her conscience and beliefs in deciding whether or not to carry a fetus to term, and not constrain her choices by imposing restrictions such as a ban on funding.
1988 Supreme Court Morgentaler decision,
Justice Bertha Wilson interpreted Charter rights more
broadly than the other justices (who situated the right to
abortion mainly in the “security of the person” clause).
addition, Justice Wilson affirmed broad definitions of
freedom of conscience and religion in Morgentaler
and held that personal morality that is not founded in
religion was also protected by s.2(a). She held that
“’freedom of conscience and religion’ should be broadly
construed to extend to conscientiously-held beliefs, whether
grounded in religion or in a secular morality.” (
have suggested that the Supreme Court has adopted
3. Since only women need abortions, funding abortion is necessary to ensure women’s legal right to be free from discrimination. Restrictive policies and laws that apply to only one gender violate human rights codes that provide protection on the basis of sex. Further, women’s equality rights under the Charter cannot be realized without access to safe, legal, fully funded abortion—otherwise, women would be subordinated to their childbearing role in a way that men are not.
The Supreme Court in 1988 did not cite the Charter’s gender equality clause (Section 15), probably because it was not added to the Charter until 1985 and no jurisprudence existed for the clause until 1989. However, interpretation of this clause has gained strength in many subsequent court decisions, including a Supreme Court decision stating that s.15 might be contravened if a pregnant woman owed a legal duty of care towards her fetus.
at what happened in
have been defined broadly by
There have been attempts in Canadian law to characterize a woman’s pregnancy as a voluntary action, thus arguing that it is not the state that is imposing the burden of carrying the fetus to term, but her own actions. But this characterization has been repeatedly rejected by the Supreme Court, which said in one decision that characterizing pregnancy as a voluntary decision imposes unfair disadvantages on one group of people, from which all of society benefits. Further, most abortions are the result of unintended pregnancy, which is certainly not voluntary—it’s an accident. Medical treatment for other accidents is fully funded, so why not for pregnancy accidents? Also, men share responsibility for accidental pregnancy, so it would be discriminatory to place the burden of payment on women.
In addition, Justice Beverly McLaughlin stated in the Dobson decision:
women choose pregnancy is no answer. Pregnancy is
essentially related to womanhood. It is an
inexorable and essential fact of human history that
women and only women become pregnant. Women should
not be penalized because it is their sex that bears
children: Brooks v. Canada Safeway Ltd,
 1 S.C.R. 1219. To say that broad legal
constraints on the conduct of pregnant women do not
constitute unequal treatment because women choose to
become pregnant is to reinforce inequality by the
fiction of deemed consent and the denial of what it
is to be a woman. (
A woman’s equality rights are intrinsically tied to her right to determine whether she will carry a fetus to term. Anti-abortion restrictions—which by extension include lack of funding—compromise a woman’s bodily integrity and autonomy, thus imposing a burden not experienced by any other group of citizens. This conforms to the Supreme Court’s definition of discrimination that violates the Charter; therefore, defunding abortion would also be discriminatory and contrary to the constitution.
4. Abortion funding is crucial to ensure fairness and equity, without discrimination on the basis of income. We must not compel low-income women and other disadvantaged women to continue an unwanted pregnancy due to lack of funding, or to delay care while they try to raise money. Any delay in abortion care raises the medical risks, especially when it extends into the second trimester. Delays are also a punitive burden that unnecessarily prolong stress and discomfort for women. Best medical practice should ensure that abortion takes place as early as possible in pregnancy, and this requires full funding.
Around the world, restricted access to abortion kills and injures the poor, not the rich, because better-off women have always been able to pay for safe abortions. This inequity was one of the key reasons abortion was legalized decades ago in most western countries.
According to the Guttmacher Institute, in a report about the consequences of lack of funding for poor women:
Research indicates that women who are economically disadvantaged are delayed at two key stages. Poor women typically take more time than better-off women to confirm a suspected pregnancy, which could be because of the cost of a home pregnancy test or the difficulty in getting a test from a clinic or doctor. In addition, they take several more days between making the decision to have an abortion and actually obtaining one. When asked why they were delayed at this stage, poor women are about twice as likely as more affluent women…to report having difficulties in arranging an abortion, usually because of the time needed to come up with the money. Moreover, other research shows that poor women who are able to raise the money needed for an abortion often do so at great sacrifice to themselves and their families. Studies indicate that many such women are forced to divert money meant for rent, utility bills, food or clothing for themselves and their children.
Up to a third of poor American women seeking an abortion are forced to continue their pregnancy because they can’t raise the money to pay for an abortion. But governments are obligated to ensure that people can exercise their constitutional and human rights without undue hardship. There is no right to abortion without access to services, and funding is absolutely necessary to ensure reasonable access.
5. Funding abortion is very cost-effective while unwanted pregnancies are costly. The medical costs of childbirth are about four times higher than the medical costs of abortion, and the social costs of forced motherhood and unwanted children are prohibitive. Further, the overall cost of abortion care to the taxpayer is a pittance relative to healthcare costs as a whole.Paying for abortion care is actually very cost-effective compared to childbirth. According to
one of the main reasons cited by anti-choicers for defunding
Funding abortion serves to integrate abortion
care into the healthcare system in general, and ensure
that reproductive healthcare is properly comprehensive. If
abortions were not funded, it would ghettoize abortion
care, as well as the women who need it and the healthcare
professionals who deliver it. This would likely increase stigma,
lead to other restrictions, further marginalize abortion
care over time, and increase anti-choice harassment and
violence. All of this occurred in the
The Hyde Amendment was passed in 1977 to prohibit federal funding for abortion except in cases of rape, incest, and life endangerment. Since then, more than a million poor women—mostly women of colour—have been denied funds for abortion, severely limiting their right to reproductive healthcare. Studies over the last two decades show that 18–35% of poor American women who would have had an abortion had to forfeit their right to abortion and continue unwanted pregnancies because their Medicaid funding was cut off.
strong case can be made that lack of funding has contributed
significantly to the marginalization and stigma of abortion,
opened the door to more and more restrictions over time, and
perpetuated or escalated violence against abortion
providers. In the
Also, a heavily stigmatized atmosphere is decidedly not safe for providers. An epidemic of violence has occurred since 1977, committed by anti-choice radicals and terrorists—including 8 murders and 17 attempted murders of abortion providers, 41 clinic bombings, 175 arsons, 98 attempted bombings and arsons, 391 clinic invasions, 100 butyric acid attacks, 662 anthrax threats, 653 bomb threats, 188 cases of assault and battery against clinic staff or patients, 418 death threats, 523 stalking incidents, 1,451 cases of clinic vandalism, 154,000 pickets in front of clinics, and more.
All of this would be much less likely to occur if abortion was funded and better integrated into mainstream healthcare. In Canada, the levels of stigma, marginalization, harassment, and violence are far less than in the U.S., which must be due at least in part to the fact that abortion is treated much more like a healthcare procedure in Canada, with full funding and about half of abortions done at hospitals. In addition, abortion funding likely enables increased opportunities and grants for research into improving abortion care and techniques, thereby enhancing the quality and safety of abortion care even more.
7. Funding abortion is the right thing to do, despite some peoples’ belief that abortion takes a life. There is no social consensus on the moral status of the fetus, and our laws do not bestow legal personhood until birth. Regardless, most Canadians believe that the woman’s rights are paramount in all or most circumstances, because she is the one taking on the health risks of pregnancy, bearing a child is a major decision with significant lifelong consequences, and a woman should be able to direct her own life and pursue her own aspirations apart from motherhood.
There is a wide divergence of opinion on “when life begins” or what the moral value of a fetus should be. Biology, medicine, philosophy, and theology have no consensus on that issue. There will never be a consensus because of the subjective and unscientific nature of the claim. That's why we should give the benefit of the doubt to women, because they are indisputable human beings with rights.
The practice of abortion is unrelated to the status of the fetus anyway—it depends totally on the aspirations and needs of women. Women have abortions regardless of the law, regardless of the risk to their lives or health, regardless of the morality of abortion, and regardless of what the fetus may or may not be. For example, overall abortion rates do not differ much between countries where it's legal and countries where it's banned to "protect life." Of 41 million abortions a year in the world, 21 million are unsafe and mostly illegal. In the developing world, about 47,000 women die every year from unsafe abortion, and five million are hospitalized.
is not just a problem in developing countries. Because
abortion is not funded in the U.S., many poor American women
resort to cheap, illegal “do-it-yourself” abortions using
the drug misoprostol, which can be unsafe without medical
Also, almost all
fetuses do not have rights in
8. Legal abortion is very safe for women and generally beneficial. The alleged medical and psychological “dangers” of abortion to women as described by anti-choice activists are either totally false or grossly overstated. Regardless, such arguments cannot support the defunding of abortion, since pregnancy and childbirth are far more medically risky, and many other funded medical treatments carry substantial risk. Access to legal, safe, fully funded abortion is also beneficial for women and families because it allows them to continue with their lives, and plan wanted children later when they are ready to care for them.
According to anti-choicers, the supposed risks of abortion for women include: breast cancer, infertility, pelvic inflammatory disease, subsequent premature birth and low birth weight, and "post-abortion syndrome", which includes depression, drug and alcohol abuse, suicide, and other mental health problems and negative psychological after-effects.
But most of the studies relied on by anti-choicers to prove their contention that abortion has such negative health risks or side-effects are flawed and essentially worthless, or have been misinterpreted. Unfortunately, the abortion issue has attracted more than its fair share of shoddy science, since anti-choice “researchers” themselves have been successful at getting many studies published in peer-reviewed scientific journals, despite serious methodological flaws in their work.  The most common errors are recall bias, small or non-random samples, non-matching control groups, and wrong assumptions that correlation equals causation.
A good example that illustrates each of these errors is anti-choicers’ treatment of the alleged increased risk of breast cancer after abortion. They continue to tout this disproven link despite a comprehensive 2003 review of the evidence by the National Cancer Institute and over 100 of the world’s leading experts on pregnancy and breast cancer risk, which concluded that having an abortion or miscarriage does not increase a woman’s subsequent risk of breast cancer. Reputable health agencies all continue to support this conclusion, including the World Health Organization, American Cancer Society, and Canadian Cancer Society.
The recall bias error may occur when studies obtain women’s abortion history by interviewing them. But when women are asked to self-report their abortion, many won’t admit it. Various studies have shown that they under-report past abortions by 20 to 80 per cent, depending on the interview circumstances. This has much to do with abortion stigma and fear of being judged by others, but under-reporting also skews the data. That’s because women with diseases that may be linked to past behaviours, such as breast cancer, are much more likely to admit to those past behaviours, as they’re anxious to find answers that may help with their treatment. Women acting as controls are not as inclined to admit to strangers that they’ve done something in the past that might be disapproved of, especially when they have no stake in the outcome. Conclusions from such flawed methodology are not justified.
One of the most ubiquitous flaws committed by anti-choice “researchers” is to confuse correlation with causation. When they find that women who had abortions suffer ill health more than women who carried to term, they tend to conclude that abortion was responsible. But correlation does not equal causation, which means that some other factor could be causing the negative effect, not abortion. In fact, women with planned pregnancies tend to be in better physical or mental health compared to women who have abortions, and tend to have more stable lives. For example, married women are generally healthier than unmarried women, but most abortions are obtained by unmarried women. Also, women leading dysfunctional or unhealthy lives are much more likely to experience unintended pregnancy in the first place, and more likely to seek abortions. Such disparities can lead to significant differences in outcome that should not be attributed to the birth or abortion itself. The American Psychological Association has concluded that mental health problems are not a direct result of choosing to have an abortion, and a recent study confirms this.
Some research done or cited by anti-choicers have
relied on studies that look at small groups of women, or
that use non-random samples for their study subject, which
means that the findings are not statistically significant
or may be invalid because the conclusions cannot be
applied to women in general. Another common flaw is using
an inappropriate control group for comparison purposes.
For example, anti-choicers may mistakenly compare women
with unplanned pregnancies to women with planned
pregnancies or to women who had miscarriages, even though
those groups have dissimilar characteristics. The best
control group would be women who carried to term after
being denied an abortion. Finding such a control group
would not be impossible in western countries, because
women are still frequently denied abortion due to various
access barriers, particularly in the
Legalized abortion has had many
health benefits for women and their families. As shown in
The last point reflects the fact
that abortion is about good motherhood—women have
abortions primarily so they can be better mothers to their
existing or future children, which means that legal
abortion helps strengthen families and keep them out of
poverty. (It’s no coincidence that U.S. states with the
strictest anti-abortion laws are the same states that have
the worst records for the health and well-being of their
women and children.)
speaking, when abortion is legal and accessible in a
country, so is contraception. When abortion is
illegal, some forms of contraception may be illegal
as well, or at least very difficult to access. The
lack of access to these two services typically go
hand in hand, probably because right-wing
conservatives tend to equate contraception and
abortion—or at least see both as immoral since they
give women control over childbearing.
However, the evidence is very clear
that contraception and family planning services are key to
reducing unintended pregnancy, which is by far the main
cause of abortion. [57a] In countries where
abortion is legal and contraceptive use improves over
time, abortion rates decline predictably and often
dramatically. This pattern has repeated itself countless
times around the world,
Abortion is one of the most commonly
performed clinical procedures in the world, including in
These facts expose anti-choicers’ professed concern for women as a cruel hypocrisy. They limit their claims about the alleged dangers of abortion only to legal abortion but rarely talk about the well-proven and devastating impact of illegal abortion on women’s lives and health, even though that’s what they want to return all women to. They are indifferent not only to the serious endangerment of women’s lives and health through illegal abortion, but to the prospect of criminalizing one-third of Canadian women. In fact, some of them want to put women in jail. It’s easy to conclude that anti-choicers are really more interested in punishing women for having abortions—including letting them die—than they are in protecting their health.
It’s not clear
why Canadian mortality and morbidity rates from abortion
are lower than in the
Finally, the overall rate of death from pregnancy-related causes is 7 deaths per 100,000 women in Canada, and 17 deaths per 100,000 women in the U.S., with abortion deaths a miniscule proportion of those. That means abortion is about 7 times safer than carrying a pregnancy to term in Canada, and 17 times safer than in the U.S. The risks of death and complications for teen pregnancy are even greater, for both the teen and her baby. Pregnancy can also aggravate or trigger various serious conditions, including heart disease, high blood pressure, cancer, diabetes, kidney disease, and autoimmune diseases. Nevertheless, the wide range of risks, complications, and side-effects of pregnancy are a topic that anti-choicers are completely silent on, despite their wish to forcibly subject women to those risks.
9. Opinion polls showing that a majority of voters do not want to pay for abortion are misleading and not pertinent. Voter opinion on this issue has been shaped by anti-choice misinformation, as well as lingering prejudice about women who have abortions. Regardless, voters have no authority to dictate what medical treatments to fund, as this is the role of provinces and professional medical organizations. Women's basic rights and freedoms must not be subject to a majority vote.
All provinces and territories have deemed abortion to be medically required, which means they must fully fund the procedure under the Canada Health Act, whether it is performed in a hospital or private clinic. The reason all abortions are medically required—not just the “hard cases” of life endangerment, rape, or incest—is because it became impossible and unconstitutional in 1988 (via the Morgentaler decision) for third parties to decide whether a woman should be able to obtain an abortion, based on her reasons for abortion. Ultimately, whether an abortion is "medically required" or not is a decision that only the pregnant woman has the right to make (with the assent of her doctor), not a medical organization and certainly not the government. Even if a particular pregnancy does not pose a serious risk to a woman’s physical health or life (but every pregnancy poses some medical risk), the World Health Organization’s definition of health includes “mental health”. In practical terms, this fits all abortions, since if a woman wants an abortion but can’t obtain one due to lack of funds, that would be very distressing or traumatic, and could have long-term negative psychological consequences for her.
Anti-choicers have claimed that provincial governments are exclusively responsible for deciding which services should be on the list of medically required services to be funded, and that courts have even said that a province could simply delist abortion. This is inaccurate or at least misleading, as there would be formidable obstacles to overcome. Provincial governments cannot make delisting decisions alone because they need to consult with doctors. As cited by anti-choicers themselves, the head of the Senate Standing Committee on Social Affairs said in 2001 that: "the determination of what services meet the requirement of medical necessity is made in each province by the provincial government in conjunction with the medical profession." In other words, the government consults with provincial medical associations and colleges of physicians and surgeons.
lesson learned in
Taxpayer funding of healthcare works similarly to how citizens pay taxes in general. We cannot pick and choose which government services or initiatives we’re willing to pay taxes for and which we’re not. Otherwise, chaos would result and the government would not be able to function.
Finally, if a majority of taxpayers really don't want to fund abortion, that more likely indicates a misunderstanding of the issue by the public, rather than an informed and reasonable perspective. The public has been subjected to relentless anti-choice propaganda for years. As a result, many misconceptions about abortion have made their way into the mainstream, such as the notion that women who have abortions are irresponsible and promiscuous. Such misconceptions contribute to the belief that abortion should not be funded, and indicate the need for more public education.
10. Abortion must be funded because it is not an elective procedure, any more than childbirth is. Pregnancy outcomes are inescapable, meaning that a pregnant woman cannot simply cancel the outcome—once she is pregnant, she must decide to either give birth or have an abortion. To protect her health and rights, both outcomes need to be recognized as medically necessary and fully funded, on an equal basis.
Anti-choicers try to marginalize the medical necessity of abortion by labeling it as a “lifestyle” choice that women make for socio-economic reasons; therefore, it should not be funded. Although abortion is indeed often referred to as a choice, this is political rhetoric that cannot be used as an argument to deny abortion funding. Deciding to become pregnant and have a baby is also a choice, often a socio-economic one, but no-one would suggest defunding childbirth because it’s an elective procedure. Also, every medical procedure is essentially a choice—people have the right to opt out, even if it means choosing death instead. And as explained previously, funding childbirth while not funding abortion would be discriminatory and violate women’s constitutional rights.
11. Anti-choice activists often say that “pregnancy is not a disease” and therefore abortion should not be funded. But the same arguments can be made for childbirth, since there are no medical reasons for a woman to get pregnant and have a baby. More importantly, health is much more than the absence of disease – it’s about achieving a state of overall health and wellness. Women with unwanted pregnancies are not in a healthy place, so their abortion care should be funded.
The anti-choice position that “pregnancy is not a disease” implies that healthcare is about treating illness, but of course health is much more than simply the absence of sickness or injury, it’s about achieving a state that benefits a person and helps them get the most value out of their life. To quote feminist writer Amanda Marcotte: “We don’t want women to be just “not sick.” We want them to be healthy. Not just healthy, but thriving.” She points out that the “pregnancy is not a disease” mindset sets up a minimalist view of what women need—as long as the body is functioning and can make babies, that’s all a woman needs. But women are not baby-making machines; they are far more than that. Besides, a woman with an unwanted pregnancy is not in a healthy place, either physically or mentally. Her body is out of her control, and she’s in a distressed state.
If anti-choicers think pregnancy is not a disease, then they should be consistent and oppose funded reproductive healthcare for all pregnant women, including any medical assistance in childbirth. Of course, this is absurd, but it effectively shows how the “choice” rhetoric is being inappropriately exploited in this context by anti-choicers to marginalize the medical necessity of abortion. Bearing children should not be constructed as a voluntary choice, as if it’s a frivolous activity like a hobby, because in order to survive and prosper, societies need most women to reproduce. This makes it essential for societies to protect women’s rights and ensure they have the supports they need to bear children when they are ready. That means providing access and funding for a wide range of reproductive health services, including abortion, in order to avoid the negative health and social consequences of forced motherhood and unwanted children. The opposite tactic of oppressing women and trying to force them into reproductive slavery simply does not work. It is also profoundly immoral and a serious violation of human rights.
would like to thank Sarah Galeski, who supplied many of the
arguments and citations provided for Points 2 and 3 in an
unpublished 2007 article co-authored by her and Joyce
Arthur, called The Case for
Repealing Criminal Laws Against Abortion: Lessons from
Note: Portions of the following sources by the same author were excerpted or adapted for this article:
January 2011. Abortion Is a “Medically
Required” Service and Cannot Be Delisted. Abortion
Rights Coalition of
Why Abortion Won’t Be Defunded in
Can Abortion be De-funded in
Arthur, Joyce. March 1,
2010. Abortion Still Does Not Lead to an Increased
Risk of Breast Cancer (or other health
problems). Abortion Rights
links for anti-choice arguments in favour of defunding
 Childbirth by Choice Trust. 1998. No Choice: Canadian Women Tell Their Stories of Illegal Abortion. Childbirth by Choice Trust. http://section15.ca/features/reviews/1999/07/07/no_choice/
 Syndicat Northcrest v. Amselem. 2004. 2 S.C.R. Para 42. At: http://www.canlii.org/en/ca/scc/doc/2004/2004scc47/2004scc47.pdf.
 Godbout v. Longueuil (City). 1997. 3 S.C.R. 844 at para. 66. At: http://scc.lexum.org/en/1997/1997scr3-844/1997scr3-844.html.
 Big M Drug Mart. 1985. 1 S.C.R. 295. At: http://www.canlii.org/en/ca/scc/doc/1985/1985canlii69/1985canlii69.pdf
 R v. Edwards Books and Art Ltd. 1986. 2 S.C.R. 713. At: http://scc.lexum.org/en/1986/1986scr2-713/1986scr2-713.html
 R v. Beare. 1988. 2 S.C.R. 387. At: http://csc.lexum.org/en/1988/1988scr2-387/1988scr2-387.html.
 Dobson (Litigation Guardian of) v. Dobson. 1999. 2 SCR 753 at paras 23-34. At: http://scc.lexum.org/en/1999/1999scr2-753/1999scr2-753.html.
 Hurley, Mary C. March 2007. Charter Equality Rights: Interpretation of Section 15 in Supreme Court of Canada Decisions. Law and Government Division. http://www.parl.gc.ca/content/LOP/ResearchPublications/bp402-e.htm#section15
 Dobson. Ibid, at para 22.
Arthur, Joyce. Abortion Is a “Medically Required” Service
and Cannot Be Delisted. Abortion Rights Coalition
 R v. Turpin. 1989. 1 S.C.R. 1296 at 1331-32. At: http://scc.lexum.org/en/1989/1989scr1-1296/1989scr1-1296.html.
 R v. Swain. 1991. 1 S.C.R. 933 at 992. At: http://scc.lexum.org/en/1991/1991scr1-933/1991scr1-933.html .
 Brooks v. Canada Safeway Ltd. 1989. 1 S.C.R. 1219 at 1238. At: http://scc.lexum.org/en/1989/1989scr1-1219/1989scr1-1219.pdf.
 Norwegian Agency for Development Cooperation. July 3, 2008. The global injustice regarding abortions. http://www.norad.no/en/about-norad/news-archive/the-global-injustice-regarding-abortions
Boonstra, Heather D.
The Heart of the Matter: Public Funding of Abortion for
Poor Women in the
Krendl, Anne C.
March 1, 1995. Abortion in the Curriculum. The
Harvard Crimson. http://www.thecrimson.com/article/1995/3/1/abortion-in-the-curriculum-pthe-accreditation/
Primary citation: Alan Guttmacher Institute. 1993. Facts in Brief: Abortion in the
[26a] Arthur, Joyce. October 1999.
Legal Abortion: the Sign of a Civilized Society.
 Tuns, Paul. Oct. 8, 2011. How much does abortion cost taxpayers? The Interim. http://www.theinterim.com/issues/abortion/how-much-does-abortion-cost-taxpayers/
 Guttmacher Institute. Oct. 5, 2009. Unsafe Abortion Costs The Developing World Hundreds Of Millions Of Dollars Each Year. http://www.guttmacher.org/media/nr/2009/10/05/index.html
 Center for Reproductive Rights. 2010. Whose Choice: How the Hyde Amendment Harms Poor Women. http://reproductiverights.org/sites/crr.civicactions.net/files/documents/Hyde_Report_FINAL_nospreads.pdf
 Boonstra, ibid.
 National Abortion Federation. 2010. Unequal Access to Abortion. http://www.prochoice.org/about_abortion/access/about_access.html#hospitals
 Guttmacher Institute. October 1, 2011. An Overview of Abortion Laws. State Policies in Brief. http://www.guttmacher.org/statecenter/spibs/spib_OAL.pdf
 Gold, Rachel and Elizabeth Nash. July 13, 2011. States Enact Record Number of Abortion Restrictions in First Half of 2011. Guttmacher Institute. http://www.rhrealitycheck.org/blog/2011/07/13/states-enact-record-number-abortion-restrictions-first-half-2011
 National Abortion Federation. 2010. Violence and Disruption Statistics. http://www.prochoice.org/pubs_research/publications/downloads/about_abortion/stats_table2010.pdf
 Tillman, Laura. August 26, 2010. Crossing the Line. The Nation. http://www.thenation.com/article/154166/crossing-line
 Tremblay v. Daigle. 1989. 2 S.C.R. 530 at 567. At: http://scc.lexum.org/en/1989/1989scr2-530/1989scr2-530.html.
 Dobson (Litigation Guardian of) v. Dobson. 1999. 2 SCR 753 at paras 95/96. At: http://scc.lexum.org/en/1999/1999scr2-753/1999scr2-753.html.
 Chamberlain, Pam. Summer 2006. Politicized Science: How Anti-Abortion Myths Feed the Christian Right Agenda. The Public Eye Magazine. http://www.publiceye.org/magazine/v20n2/chamberlain_politicized_science.html
 Ministry of Truth. Nov 17, 2010. Dorries’ Abortion Risk ‘Plethora’. http://www.ministryoftruth.me.uk/2010/11/17/dorries-abortion-risk-plethora/
 National Cancer Institute. 2010. Abortion, Miscarriage, and Breast Cancer Risk. http://www.cancer.gov/cancertopics/factsheet/risk/abortion-miscarriage
 American Cancer Society. Sept. 2011. Is Abortion Linked to Breast Cancer? http://www.cancer.org/Cancer/BreastCancer/MoreInformation/is-abortion-linked-to-breast-cancer
 Canadian Cancer Society. October 2011. Abortion and breast cancer. http://www.cancer.ca/Canada-wide/About%20us/CW-Our%20positions%20and%20perspectives/Abortion%20and%20breast%20cancer.aspx?sc_lang=en
 Udry, J. Richard, Gaughan M, Schwingl PJ, van den Berg BJ. Sept/Oct 1996. A Medical Record Linkage Analysis of Abortion Underreporting. Family Planning Perspectives. Volume 28, Number 5. http://www.guttmacher.org/pubs/journals/2822896.html
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