Skoric v. Vermont Department of Labor: A Federal and State Government Conflict

By: Alexandra Henriquez

Edited by: Lauren Levinson and Micah Sandy

Vermont transit worker Ivo Skoric turned to medical marijuana in the hope of finally alleviating his chronic pain and depression. [1] Skoric had been legally prescribed marijuana in accordance with Vermont state law. When Marble Valley Regional Transit District, his employer, learned of his drug use via a spontaneous drug test, Skoric was terminated and barred from receiving unemployment benefits. Skoric sued his employer and the Vermont Department of Labor for discrimination on the basis of his disability and his means to manage it, which he claimed violated the Americans with Disabilities Act (ADA). The ADA, in 1990, held that no employer “shall discriminate against a qualified individual on the basis of disability in regard to job application procedures … or discharge of employees,” [2] stipulating that a qualified individual “shall not include any employee or applicant who is currently engaging in the illegal use of drugs.” [3] Such illegal use was defined in the ADA as “the use of drugs, the possession or distribution of which is unlawful under the Controlled Substances Act.” [4] Therefore, the Vermont federal district judge ruled that the ADA does not extend to disabilities treated with medical marijuana because the Controlled Substances Act of 1970 federally prohibits marijuana.

While the ruling of the district court seems straightforward, it demonstrates a more complex and longstanding issue of the contradicting legal status of marijuana at the federal and state levels. Marijuana’s legal challenges began in the 1930s, arising with state-level bans, which expanded to a federal crackdown with the Marihuana Tax Act of 1937. Despite initially delaying marijuana regulation due to the growing research on its medicinal use and the booming industry, the federal government soon followed its state government counterparts. [5] By 1970, the Controlled Substances Act federally defined marijuana as a Schedule I drug with “a high potential for abuse,” “no currently accepted medical use in treatment in the United States,” and a “lack of accepted safety for use of the drug or other substance under medical supervision.” [6] Nonetheless, changes to state-level laws have occurred over the last half-century, with 37 states and the District of Columbia legalizing medical marijuana. [7]  This shift is largely attributed to the discovery that medical marijuana could actually have medicinal benefits, which contradicts its original classification under the Controlled Substances Act. Recent studies have highlighted marijuana’s effectiveness in treating a range of conditions, including chronic pain, multiple sclerosis, epilepsy, and the nausea associated with chemotherapy. [8] Research into cannabinoids has led to the FDA's approval of medications that contain cannabinoid chemicals for specific conditions, further legitimizing its medical use. So, while the FDA has “not approved a marketing application for cannabis for the treatment of any disease or condition,” they have approved a cannabis-derived drug product: Epidiolex (cannabidiol). [9] While these new findings have contributed to changes in an overwhelming number of state governments, federally, marijuana still remains a Schedule I drug.

While the scientific and ethical debate on whether marijuana should be legalized and how it should be regulated continues, we must also begin asking the question of the importance of cohesive legislation among the two levels of government. The ongoing discord between federal and state regulations might be more detrimental than beneficial. Concurrent powers, powers guaranteed by the U.S. Constitution that are shared by both the federal government and state governments, have long stood, not inherently producing conflict. Examples of harmonious concurrent powers are the powers to levy taxes, build infrastructure, and create lower courts. The issue arises when concurrent powers, instead of building upon each other like the ability to tax and create infrastructure, directly contradict one another. According to Article VI of the Constitution, the Supremacy Clause stipulates that state laws can not interfere with the execution of federal law. [10] Thus, concurrent powers are not necessarily always concurrent. State government marijuana laws are subordinate to federal law and are essentially left more as a political statement than actual legislation. In his plea for relief, Skoric articulates a significant critique, stating: “Medical cannabis law is a dead letter on paper, and the medical card is worthless if it renders the patient unemployable and uninsurable.” [11] Essentially, Skoric argues that the legal recognition of medical marijuana at the state level does not translate into tangible benefits it seeks to provide due to the conflict with federal law. While the legalization of medical marijuana on the state level should not automatically guarantee federal legalization under the nation’s founding principles of federalism and separation of powers, we should reflect on the costs of a contradictory legal framework.

The case of Ivo Skoric spotlights the intricate and often conflicting legal landscape surrounding marijuana law in the United States. Skoric’s legal battle, which hinged on the interplay between state law, federal legislation, and the Americans with Disabilities Act (ADA), underscores a broader, more systemic issue: the misalignment between state-level and federal initiatives.

Notes:

1. Ivo Skoric v. Vermont Department of Labor (Marble Valley Regional Transit District), No. 2:23-cv-00064-gwc (U.S. Court for the District of Vermont, Feb. 14, 2024).

2. Americans with Disabilities Act of 1990, 42 U.S.C. § 12112 (1990).

3. Americans with Disabilities Act of 1990, 42 U.S.C. § 12114 (1990).

4. Americans with Disabilities Act of 1990, 42 U.S.C. § 12111 (1990).

5. “Did You Know... Marijuana Was Once a Legal Cross-Border Import?” U.S. Customs and Border Protection, December 20, 2019. https://www.cbp.gov/about/history/did-you-know/marijuana. 

6. Drug Abuse Prevention and Control Act of 1970, 21 U.S.C. § 812 (1970).

7. Sacco, Lisa  N., Joanna R. Lampe, and Hassan Z. Sheikh. “The Federal Status of Marijuana and the Expanding Policy ...” Congressional Research Service, March 6, 2023. https://crsreports.congress.gov/product/pdf/IF/IF12270.

8. Arkell TR, Downey LA, Hayley AC, Roth S. Assessment of Medical Cannabis and Health-Related Quality of Life. JAMA Netw Open. 2023 May 1;6(5):e2312522. doi: 10.1001/jamanetworkopen.2023.12522. PMID: 37159196; PMCID: PMC10170337. 

9. “FDA and Cannabis: Research and Drug Approval Process.” U.S. Food and Drug Administration, February 24, 2023. https://www.fda.gov/news-events/public-health-focus/fda-and-cannabis-research-and-drug-approval-process. 

10. U.S. Const. art. VI, cl. 2.

11. Ivo Skoric v. Vermont Department of Labor (Marble Valley Regional Transit District), No. 2:23-cv-00064 (U.S. Court for the District of Vermont, Feb. 14, 2024).

Bibliography:

Americans With Disabilities Act of 1990, 42 U.S.C. § 12101 et seq. (1990)

Arkell TR, Downey LA, Hayley AC, Roth S. Assessment of Medical Cannabis and Health-Related Quality of Life. JAMA Netw Open. 2023 May 1;6(5):e2312522. doi: 10.1001/jamanetworkopen.2023.12522. PMID: 37159196; PMCID: PMC10170337. 

Drug Abuse Prevention and Control Act of 1970, 21 U.S.C. § 812 (1970).“Did You Know... Marijuana Was Once a Legal Cross-Border Import?” U.S. Customs and Border Protection, December 20, 2019. https://www.cbp.gov/about/history/did-you-know/marijuana. 

Ivo Skoric v. Vermont Department of Labor (Marble Valley Regional Transit District), No. 2:23-cv-00064 (U.S. Court for the District of Vermont, Feb. 14, 2024).

“FDA and Cannabis: Research and Drug Approval Process.” U.S. Food and Drug Administration, February 24, 2023. https://www.fda.gov/news-events/public-health-focus/fda-and-cannabis-research-and-drug-approval-process. 

Ivo Skoric v. Vermont Department of Labor (Marble Valley Regional Transit District), No. 2:23-cv-00064 (U.S. Court for the District of Vermont, Feb. 14, 2024).

Sacco, Lisa  N., Joanna R. Lampe, and Hassan Z. Sheikh. “The Federal Status of Marijuana and the Expanding Policy ...” Congressional Research Service, March 6, 2023. https://crsreports.congress.gov/product/pdf/IF/IF12270.

U.S. Const. Art. VI, Cl. 2.

Artificial Jurisprudence: Might AI Ever Be Tasked With Adjudicating the Law?

By: Jonah Berman

Edited by: Regan Cornelius and Colin Crawford

Artificial intelligence and its inevitable confrontation with established practices across numerous industries have become a fervent topic of discussion lately. The realm of law and legal practice stands out as particularly intriguing in this context given that, traditionally, the sector has depended on the nuanced judgment and expertise of practitioners proficient in the complexities of law. Yet, it now faces the fascinating prospect of transformation through AI. For instance, Large Language Models (LLMs) like ChatGPT are increasingly handling substantial volumes of administrative work. An LLM can meticulously search and analyze case files, compile evidence, and construct legal arguments imbued with strong precedents. A Princeton study identified legal services as one of the most susceptible professions to disruption by the advent of LLMs. It's clear that AI will impact the field of law. But, might it ever evolve to actually adjudicate law itself?

Malcolm Gladwell, in his 2019 book Talking to Strangers, cites a compelling case of man versus machine. A Harvard researcher led a significant study comparing bail decisions made by human judges in New York City with those determined by an AI system. This analysis involved records of over half a million defendants from arraignment hearings between 2008 and 2013, with the AI tasked with selecting 400,000 individuals for release based on the same data judges had. The judges had the advantage of meeting the defendants in person and considering additional courtroom information, unlike the AI, which relied solely on the given data. Astonishingly, those selected by the AI were 25% less likely to re-offend while on bail compared to those chosen by human judges. Furthermore, the AI accurately predicted a high probability of reoffending in over half of a "high-risk" group it identified. In short, the machine won this judicial “face-off”.

The potential of AI in law adjudication offers a range of benefits. AI's capacity for processing vast data impartially may lead to more consistent and precise legal decisions, as demonstrated in Gladwell's case study. An LLM can effortlessly recall any case detail, law, or even recite the entire Constitution word for word. Such comprehensive knowledge grants LLMs a significant advantage in law adjudication, allowing them to consider a broad spectrum of implicit factors and historical contexts with complete objectivity–ideally.

Another aspect worth considering is LLMs’ competence in addressing moral and ethical dilemmas. Remarkably, LLMs have already shown high proficiency in understanding human morals. One study found a .95 Spearman correlation coefficient between GPT 3.5 and human responses to moral queries, indicating an extremely strong correlation between the two sets of responses.

Nonetheless, there are significant concerns about LLMs that would hinder their ability to adjudicate law. Evident biases in AI systems have been a major issue. As AI language models are trained on pre-existing data, they may inadvertently perpetuate and amplify societal biases inherent in that data. The COMPASS system, used in the U.S. criminal justice system, exemplifies this; an investigation highlighted its disproportionate labeling of black defendants as high-risk compared to white defendants, raising questions about racial bias in AI evaluations.

Additionally, LLMs sometimes produce inaccurate responses or can be misled by complex or ambiguous prompts. Whether an LLM can adjudicate law differs from whether it should adjudicate law. I argue that LLMs are—and will soon be even more so—exceptionally equipped for legal judgment. Given that ChatGPT was launched a little over a year ago, LLMs are still in an inchoate phase. AI researchers and industry leaders are well aware of the current flaws facing LLMs; it is clear that the issues of inaccuracy and bias will be properly addressed in time. Once these concerns are mitigated, LLMs will be able to adjudicate law with greater knowledge, impartiality, and efficiency than human judges. However, the inherently subjective nature of law, with its myriad interpretations and evolving viewpoints, remains a critical barrier. The capacity for legal interpretation is not something humans are likely to relinquish. For instance, if an LLM were assigned to decide on the federal legalization of abortion in the U.S., its approach would be multifaceted, considering moral, constitutional, and historical aspects. Nevertheless, people would struggle to adhere to the ruling of a machine. The imperfect, sometimes contradictory nature of law, with its capacity for both justice and failure, is intrinsically human. While AI may in theory soon become a superior alternative for legal judgment, it is hard to imagine its full acceptance in practice. More likely, there will start to be a rise in the use of AI to augment judges’ ability to make the best decisions: a symbiotic relationship that harnesses the breadth and power of AI while still keeping the judiciary human.

Notes: 

1. Tawakol, A. (2023, May 25). “Will AI Replace Lawyers?” Forbes. Retrieved from https://www.forbes.com/sites/forbestechcouncil/2023/05/25/will-ai-replace-lawyers/?sh=58271a373124

2. Felten, E., Raj, M., & Seamans, R. (2023). “How will Language Modelers like ChatGPT Affect Occupations and Industries?” Retrieved from https://arxiv.org/pdf/2303.01157.pdf

3. Gladwell, M. (2019). Talking to Strangers. Retrieved from https://www.ericfrayer.com/wp-content/uploads/2019/11/Talking-to-Strangers.pdf

4. Dillon D., Tandon, N., Gu, Y., Gray, K. (2023). Can AI Language Models Replace Human Participants? Trends in Cognitive Sciences. Retrieved from https://www.cell.com/trends/cognitive-sciences/fulltext/S1364-6613(23)00098-0

5. Hao, K. (2019, October 17). AI is fairer than a judge. MIT Technology Review. Retrieved from https://www.technologyreview.com/2019/10/17/75285/ai-fairer-than-judge-criminal-risk-assessment-algorithm/

6. Aboze, J. (2023, August 7). Risks of Large Language Models. DeepChecks. Retrieved from https://deepchecks.com/risks-of-large-language-models/

Bibliography:

Aboze, J. (2023, August 7). Risks of Large Language Models. DeepChecks. Retrieved from https://deepchecks.com/risks-of-large-language-models/

Dillon, D., Tandon, N., Gu, Y., & Gray, K. (2023). Can AI Language Models Replace Human Participants? Trends in Cognitive Sciences. Retrieved from https://www.cell.com/trends/cognitive-sciences/fulltext/S1364-6613(23)00098-0

Felten, E., Raj, M., & Seamans, R. (2023). How will Language Modelers like ChatGPT Affect Occupations and Industries? Retrieved from https://arxiv.org/pdf/2303.01157.pdf

Gladwell, M. (2019). Talking to Strangers. Retrieved from https://www.ericfrayer.com/wp-content/uploads/2019/11/Talking-to-Strangers.pdf

Hao, K. (2019, October 17). AI is fairer than a judge. MIT Technology Review. Retrieved from https://www.technologyreview.com/2019/10/17/75285/ai-fairer-than-judge-criminal-risk-assessment-algorithm/ 

Tawakol, A. (2023, May 25). Will AI Replace Lawyers? Forbes. Retrieved from https://www.forbes.com/sites/forbestechcouncil/2023/05/25/will-ai-replace-lawyers/?sh=58271a373124. 

The Debate over Affirmative Action at West Point and the Fourteenth Amendment

By: Sarah Wejman

Edited by: Valerie Chu and Simon Carr

Within less than fifty years, the Supreme Court of the United States (SCOTUS) first ruled that affirmative action was constitutional and then that it wasn’t. In Students for Fair Admissions v. Harvard (2023), SCOTUS ruled that the purpose and reasoning for Harvard and other institutions’ race-based admissions processes were unable to avoid racial stereotypes and thus did not pass a strict scrutiny test. The case clarified that universities are welcome to consider an applicant’s race, how their lives were impacted by it, and what they could uniquely contribute to the institution. [1] Just last month on January 26, Students for Fair Admissions (SFFA) acted once again by asking SCOTUS to review the race-conscious admissions of West Point. [2] The U.S. Justice Department stated that West Point’s race-based admissions is a “vital pipeline to the officer corps” and is essential to ensuring a diverse class of military officers. [3]

The reason that West Point was not included in the ruling of the 2023 case is because of a footnote that Chief Justice Roberts wrote in the majority opinion: “No military academy is a party to these cases, however, and none of the courts below addressed the propriety of race-based admissions systems in that context.” [4] A lower court declined to grant a preliminary injunction, so SFFA, while awaiting the Second Circuit’s ruling, filed an emergency appeal to SCOTUS due to West Point’s approaching January 31 application deadline. [5]

The SFFA v. Harvard case effectively overturned the precedent of Regents of the University of California v. Bakke (1978), an affirmative action case involving a white student denied admission from the Medical School of the University of California at Davis (UCD). The UCD race-based admissions were more involved than Harvard’s because they used racial quotas by setting aside sixteen seats in their class of one hundred members for minorities. SCOTUS ruled that racial quotas are unconstitutional, but universities are permitted to use race-based classifications to ensure an ethnically diverse institution. [6]

Both of these cases relied on the Fourteenth Amendment’s Equal Protection Clause, which protects against discrimination by the states based on one’s race, ethnicity, gender, religion, and other identifying factors. Racial-based classifications receive the highest level of scrutiny, strict scrutiny, which requires that the state proves that the discrimination is furthering an important government interest and that the law is substantially related to such interests. [7] While Bakke ruled that ethnic diversity was a compelling interest for the state, the Court in Harvard ruled that this standard was not met since racial stereotypes permeated the admissions system, creating a substantial disadvantage for many minority applicants.

The Fourteenth Amendment applies to states, meaning education-wise it affects publicly owned schools. However, precedent holds that violations against Title VI of the Civil Rights Act of 1964 are also violations of the Equal Protection Clause. Title VI applies to all institutions that receive any sort of federal funding, which most private schools including Harvard do. Thus through indirect means, the Fourteenth Amendment does apply.

Whether SCOTUS will even accept this case is still uncertain. However, based on their recent rulings, it seems unlikely that West Point will be able to continue to consider race to the extent that they do.

Notes:

1. Students for Fair Admissions, Inc. v. Harvard, 600 U.S. (2023)

2. Kruzel, John , and Andrew Chung. “US Supreme Court Is Asked to Stop West Point from Considering Race in Admissions.” Reuters, January 26, 2024. https://www.reuters.com/world/us/us-supreme-court-is-asked-stop-west-pointconsidering-race-admissions-2024-01-27/.

3. Kruzel and Chung, “US Supreme Court Is Asked”

4. Reichmann, Kelsey. “Supreme Court Asked to Halt Use of Race in Admissions at West Point.” Courthouse News Service, January 26, 2024. https://www.courthousenews.com/supreme-court-asked-to-halt-use-of-race-inadmissions-at-west-point/.

5. Reichmann, “Supreme Court Asked”

6. Regents of the University of California v. Bakke, 438 U.S. 265 (1978)

7. Cornell Law School Legal Information Institute. “Strict Scrutiny.” Accessed January 28, 2024. https://www.law.cornell.edu/wex/strict_scrutiny.

Bibliography:

Cornell Law School Legal Information Institute. “Strict Scrutiny.” Accessed January 28, 2024. https://www.law.cornell.edu/wex/strict_scrutiny.

Kruzel, John , and Andrew Chung. “US Supreme Court Is Asked to Stop West Point from Considering Race in Admissions.” Reuters, January 26, 2024.https://www.reuters.com/world/us/us-supreme-court-is-asked-stop-west-point-considering-race-admissions-2024-01-27/.Regents of the University of California v. Bakke, 438 U.S. 265 (1978)

Reichmann, Kelsey. “Supreme Court Asked to Halt Use of Race in Admissions at West Point.” Courthouse News Service, January 26, 2024.https://www.courthousenews.com/supreme-court-asked-to-halt-use-of-race-in-admissions-at-west-point/.Students for Fair Admissions, Inc. v. Harvard, 600 U.S. (2023)

Cox v. Texas is the First Pushback Since Roe v. Wade

By: Ana Cucalon

Edited by: Maddy Bennett and Olivia Paik

In a Texas state court, the Center for Reproductive Rights filed a case on behalf of Kate Cox, a pregnant woman requesting an urgent abortion. A week before the filing of this case requesting a legal abortion in the state of Texas, Cox discovered she had Trisomy 18, a prenatal disorder that causes several structural defects in the fetus and ultimately leads to fetal death. Cox had already had two cesarean procedures. A third cesarean section would be required if she continued her pregnancy. Her physicians cautioned her that going full-term could endanger her life and future fertility, as a third C-section would put her at a higher risk of developing several major health issues. Therefore, Cox and her husband decided an abortion would be the best option for their family. Cox sought the court's temporary overturn of the state's abortion prohibitions to obtain the urgent care she needed and avoid the grave risks to her life and health associated with remaining pregnant. [1] In light of Roe vs. Wade being recently overturned, this trial garnered national recognition as Texas's first case on behalf of a pregnant woman seeking legal emergency abortion care.

Texas has some of the strictest abortion laws in the country, and except for medical emergencies, all abortions beyond six weeks of pregnancy are illegal under current law. Additionally, The Texas Heartbeat Bill forbids healthcare providers from performing an abortion if they detect a fetal heartbeat. Because abortion is illegal, doctors and hospitals that perform abortions are criminally liable and may face dire consequences, including up to ninety-nine years in prison and fines exceeding ten thousand dollars. Doctors can only perform abortions to save a life or to avoid damage to major bodily functions. Only if doctors demonstrate reasonable medical judgment in treating medical complications can they avoid conviction (but not prosecution). [2] The problem is that because this legislation is so new and famously vague, medical providers and legal scholars alike are unsure of what constitutes a legal abortion. 

In the trial, Kate Cox’s lawyer sought to convince the judge that Kate needed an abortion to avoid critical damage to critical bodily functions. To do so, her attorney made two primary arguments. First, her pregnancy was putting her in serious medical risk. Kate had already been to the emergency room several times the week of the case, and her doctors cautioned that Kate’s condition would keep getting worse as the pregnancy continued. Second, Kate’s fertility was at serious risk. Kate’s fetus would not survive longer than a few days out of the womb, and carrying out the non-viable pregnancy would put the Texas mother, who was hoping for another child, in danger of not being able to conceive again. The plaintiff argued that by allowing Kate this abortion, the judge would be saving the lives of any future children. [3]

In response, the attorney representing the state of Texas laid out his claim. He argued that the standard for abortions is very clear and objective, and that Kate Cox is simply not allowed an abortion based on it. Specifically, he said that this argumental case is hypothetical; because Kate Cox isn’t at immediate risk, the Texas law of medical emergencies does not apply. [4] In response, the plaintiff argued that the law is not clear, as there are many cases of doctors being unable to decide what medical exemptions warrant legal abortions. Cox’s attorney implored the court that the state needs to at least clarify the law, because until that is done, the state can always find a doctor to say that the medical judgment of a health provider who gave an abortion was not “reasonable”, putting doctors at risk whenever they try to make that decision. [5]

Surprisingly, the judge quickly made a decision; she granted Kate Cox temporary permission to receive an abortion, stating that “the idea that Ms. Cox wants desperately to be a parent and that this law might actually cost her to lose that ability is shocking and would be a genuine miscarriage of justice”. [6]

Yet, that was not the end of Kate Cox’s fight with Texas. State attorney Ken Packson immediately appealed the ruling, sending letters to the hospitals where Kate Cox had admittance, saying that even though she was allowed to get the abortion, were any Texas doctor to perform it, they would be criminally charged. The Texas Supreme Court formally followed in this threat, blocking the restraining order and declaring the lower court ruling to be an error. Since her time was limited, Kate Cox decided she needed to cross state borders to get her abortion before it was too late. [7]

This case is important for several reasons. First, this case called out Texas’s bluff: the state had previously claimed that rather than the abortion law itself being problematic, the issue was with how physicians were applying the legal standard warranting lawful abortions. During a July hearing, a Texas state attorney questioned several women who were suing the state for abortion denials, questioning why they were suing Texas instead of their doctors. The state's attorney repeatedly questioned, “Did Attorney General Ken Paxton tell you you couldn’t get an abortion? Did anyone, working in any capacity for the state, tell you you couldn’t get an abortion?”. Despite Cox having been granted a temporary restraining order that permitted her to receive a legal abortion on an individual case basis, Texas state attorneys used every possible resource to circumvent Cox's ability to use the restraining order granted to obtain a lawful abortion in lieu of the state's legal standard. Second, this case highlighted serious issues with the law itself. Due to the case, the state is now forced to answer a difficult question: How much of a risk to your health does there have to be for a doctor to say that, in their reasonable medical judgment, you need an abortion? [8]

Finally, this case fundamentally shifted the discourse surrounding abortion, irrespective of party affiliation. Kate’s story counters the generalization that only irresponsible young girls or adolescent females use abortions as a form of birth control. It sets a precedent for the future, one in which people are now considering all the cases where patients may need abortions that are medically necessary beyond the use of abortion as an emergency method for pregnancy termination or contraception. Most importantly, it challenges the polarity of politics around abortion and urges the legal system to consider female autonomy as a nonpartisan fundamental right warranting protection amidst the backdrop of increasingly polarized conservative and liberal discourse. 

Notes:

1. Center for Reproductive Rights. 2017. “Cox v. Texas: The Case in Depth.” https://reproductiverights.org/case/cox-v-texas/cox-v-texas-case-in-depth/.

2. Varghese, Benson. 2023. “What is the Texas Abortion Law? (Dec 2023 Update).” Varghese Summersett. https://versustexas.com/texas-abortion-law/.

3. The Daily, The New York Times. 2023. “The Woman Who Fought the Texas Abortion Ban” (The New York Times, December 14, 2023).https://www.nytimes.com/2023/12/14/podcasts/the-daily/texas-abortion-ban.html.

4. (The Daily, The New York Times 2023)

5. (The Daily, The New York Times 2023)

6. (The Daily, The New York Times 2023)

7. Smith, Tracy. 2024. “Texas mother Kate Cox on the outcome of her legal fight for an abortion: "It was crushing."” (CBS News, January 14, 2024). https://www.cbsnews.com/news/kate-cox-on-her-legal-fight-for-abortion-trisomy-18/.

8. “Kate Cox's case tests Texas abortion laws.” (The Texas Tribune, December 13, 2023). https://www.texastribune.org/2023/12/13/texas-abortion-lawsuit/.

Bibliography:

“Cox v. Texas: The Case in Depth.” 2017. Center for Reproductive Rights. https://reproductiverights.org/case/cox-v-texas/cox-v-texas-case-in-depth/.

The Daily, The New York Times. 2023. “The Woman Who Fought the Texas Abortion Ban” The New York Times, December 14, 2023.

https://www.nytimes.com/2023/12/14/podcasts/the-daily/texas-abortion-ban.html.

Smith, Tracy. 2024. “Texas mother Kate Cox on the outcome of her legal fight for an abortion: "It was crushing."” CBS News, January 14, 2024. https://www.cbsnews.com/news/kate-cox-on-her-legal-fight-for-abortion-trisomy-18/.

The Texas Tribune. 2023. “Kate Cox's case tests Texas abortion laws.” December 13, 2023. https://www.texastribune.org/2023/12/13/texas-abortion-lawsuit/.

Varghese, Benson. “What is the Texas Abortion Law? (Dec 2023 Update).” Varghese Summersett. Accessed January 26, 2024. https://versustexas.com/texas-abortion-law/.