Faith-Groups-Amicus-Brief

No. 19-1392 IN THE Supreme Court of the United States

THOMAS E. DOBBS, M.D., M.P.H., in his Official Capacity as State Health Officer of the Mississippi Department of Health, et al., —v.—

Petitioners,

JACKSON WOMEN'S HEALTH ORGANIZATION, on behalf of itself and its patients, et al.,

Respondents.

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

BRIEF OF AMICI CURIAE CATHOLICS FOR CHOICE, NATIONAL COUNCIL OF JEWISH WOMEN, RELIGIOUS COALITION FOR REPRODUCTIVE CHOICE, MUSLIM ADVOCATES, PRESBYTERIANS AFFIRMING REPRODUCTIVE OPTIONS, JEWISH WOMEN INTERNATIONAL, AUBURN THEOLOGICAL SEMINARY, MUSLIMS FOR PROGRESSIVE VALUES, AFRICAN AMERICAN MINISTERS IN ACTION, AND 45 OTHER FAITH-BASED ORGANIZATIONS, IN SUPPORT OF RESPONDENTS

EUGENE M. GELERNTER Counsel of Record SAUL B. SHAPIRO LEIGH E. BARNWELL PATTERSON BELKNAP WEBB & TYLER LLP 1133 Avenue of the Americas New York, New York 10036 (212) 336-2000 emgelernter@pbwt.com Counsel for Amici Curiae

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TABLE OF CONTENTS

TABLE OF AUTHORITIES ii STATEMENT OF INTEREST 1 SUMMARY OF ARGUMENT 1 ARGUMENT 3 I. RELIGIOUS TRADITIONS DO NOT SHARE A UNIFORM VIEW OF WHEN LIFE BEGINS 3 II. RELIGIOUS TRADITIONS AFFIRM WOMEN'S MORAL RIGHT TO DECIDE WHETHER AND UNDER WHAT CIRCUMSTANCES TO TERMINATE A PREGNANCY 9 III. RELIGIOUS TRADITIONS AFFIRM THE IMPORTANCE OF ENSURING REPRODUCTIVE CHOICE FOR WOMEN IN MARGINALIZED COMMUNITIES WHO ARE DISPROPORTIONATELY HARMED BY THE BAN 20 CONCLUSION 25

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TABLE OF AUTHORITIES

Page(s)

Cases

Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833 (1992)...........................8-9, 17, 20, 26 Roe v. Wade, 410 U.S. 113 (1973)........................................4, 8, 9

Statutes

Miss. Code. Ann. § 41-41-191............................2, 9, 18

Other Authorities

144 Cong. Rec. S10491 (daily ed. Sept. 17, 1998)...............................................................16 Abdulaziz Sachedina, Islamic Biomedical Ethics: Principles and Applications (2009)................................................8 Alliance of Baptists, A Statement on Lifelong Sexual Education, Sexual & Reproductive Rights, and Opposing Sexual Justice and Violence (2012), available at http://www.sitemason.com/files/kuGi7v/StatementonLifelongSexualEducation.pdf...........................................................13, 21

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American Baptist Association, Resolution Concerning Abortion and Ministry in the Local Church (1987), available at http://www.abc-usa.org/wp-content/uploads/2012/06/Abortion-and-Ministry-in-the-Local-Church.pdf ............................................................11 Anne Stensvold, A History of Pregnancy in Christianity: From Original Sin to Contemporary Abortion Debates (2015)..................................................................4, 5 Belden Russonello Strategists, 2016 Survey of Catholic Likely Voters (October 2016), available at http://www.rifuture.org/wp-content/uploads/2016-Catholic-Voter-Poll.pdf .......................................................14 Buddhist Churches of America Social Issues Committee, A Shin Buddhist Stance on Abortion , Buddhist Peace Fellowship Newsletter (1984)..............................17 Brief of Amici Curiae Religious Coalition for Reproductive Choice, et al., in Support of Respondent, Stenberg v. Carhart , No. 99-380 (Mar. 29, 2000).....................................................11 Catholics for Choice, Religious Freedom , available at https://www.catholicsforchoice.org/issues/religious-freedom/ ........................................18

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Catholics for Choice, Reproductive Equity , available at https://www.catholicsforchoice.org/issues/reproductive-choice/ ....................................23 Catholics for Choice, Social Justice , available at https://www.catholicsforchoice.org/issues/social-justice/ ................................................23 Connecticut Conference of the United Chuch of Christ, Resolution: Freedom of Choice Concerning Abortion (1971), available at http://www.ctucc.org/files/tables/content/7726678/fields/files/327cad155b9c43dd8a95e03e4179fbe8/1971_freedom_of_choice.pdf ....................................................21 Dalia Fahmy, 8 Key Findings about Catholics and Abortion , Pew Research Center (October 20, 2020), available at https://www.pewresearch.org/fact-tank/2020/10/20/8-key-findings-about-catholics-and-abortion/ ............................15 Dariusch Atighetchi, Islamic Bioethics: Problems and Perspectives (2006).........................8

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Elissa Strauss, When Does Life Begin? It's Not So Simple, Slate (April 4, 2017), available at https://slate.com/human-interest/2017/04/when-does-life-begin-outside-the-christian-right-the-answer-is-over-time.html ...................... passim Episcopal Church, Standing Commission on Human Affairs and Health, Resolution #A087 (1988) available at https://www.episcopalarchives.org/e-archives/gc_reports/reports/1988/bb_1988-R016.pdf ................................................ 10, 12 Evangelical Lutheran Church in America, Social Statement on Abortion (1991), available at http://download.elca.org/ELCA%20Resource%20Repository/AbortionSS.pdf ....................................................................... 6, 13 Frank K. Flinn, Encyclopedia of Catholicism (2007) ................................................. 5 Freedom of Choice Act of 1989: Hearing on S. 1912 Before the S. Comm. on Labor and Human Resources, 101st Cong. 237 (1990) ............................................. 11, 13 Gary Wills, Abortion Isn't a Religious Issue, The Los Angeles Times (November 4, 2007) ................................................ 5

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General Convention, Journal of the General Convention of…The Episcopal Church , Indianapolis, 1994 (New York: General Convention, 1995), available at https://www.episcopalarchives.org/cgi-bin/acts/acts_generate_pdf.pl?resolut ion=1994-A054 ..................................................... 12 Gittin 23b, available at https://www.sefaria.org/sheets/23492 6.8?lang=bi ............................................................ 7 Guttmacher Institute, Characteristics of U.S. Abortion Patients in 2014 and Changes since 2008 (May 2016), available at https://www.guttmacher.org/sites/def ault/files/report_pdf/characteristics-us-abortion-patients-2014.pdf ............................. 15 Guttmacher Institute, Fact Sheet: Induced Abortion in the United States (2019), available at https://www.guttmacher.org/sites/def ault/files/factsheet/fb_induced_aborti on.pdf ............................................................. 15, 23 Hindus in America Speak Out On Abortion Issues , Hinduism Today, (Sept. 1985), available at https://www.hinduismtoday.com/mag azine/september-1985/1985-09-hindus-in-america-speak-out-on-abortion-issues/ .................................................... 17

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The Latter-day Saints Tradition: Religious Beliefs and Healthcare Decisions, (Deborah Abbott ed.) (2002), available at https://www.advocatehealth.com/ass ets/documents/faith/latter-day_saints_tradition.pdf .................................6, 14 Lester E. Bush, Ethical Issues in Reproductive Medicine: A Mormon Perspective, Dialogue: a Journal of Mormon Thought (1985), available at https://www.dialoguejournal.com/arti cles/ethical-issues-in-reproductive-medicine-a-mormon-perspective/ ..........................7 Letter of Jewish Clergy Leaders to the Senate Committee on the Judiciary, dated July 16, 2021, available at https://www.ncjw.org/wp-content/uploads/2021/07/06-16-2021_Jewish-Clergy-Leaders-WHPA-Letter-FINAL-1.pdf ................................16 Mark Cherry, Religious Perspective on Bioethics (2004)...................................................... 8 Metropolitan Community Churches, Statement of Faith on Women's Reproductive Health, Rights, and Justice (March 20, 2013), available at https://www.mccchurch.org/statemen t-of-faith-on-womens-reproductive-health-rights-and-justice/ ....................................11

viii Minutes of the 217th General Assembly of the Presbyterian Church (U.S.A.) (2006)....................................................................10 Mishnah Ohalot 7:6, available at https://www.sefaria.org/sheets/23492 6.8?lang=bi.......................................................8, 16 Mississippi Maternal Mortality Report, 2013-2016, (April 2019), available at https://msdh.ms.gov/msdhsite/index. cfm/31,8127,299.pdf/Maternal_Morta lity_2019_amended.pdf........................................24 Mississippi State Department of Health, Infant Mortality Report, 2018, available at https://msdh.ms.gov/msdhsite/_static /resources/8015.pdf ..............................................24 Mohammad A. Albar, Induced Abortion From An Islamic Perspective: Is It Criminal Or Just Elective, 8 J. Fam. Cmty. Med. 25 (2001)..........................................16 National Council of Jewish Women, Abortion and Jewish Values Toolkit (2020), available at https://www.ncjw.org/wp-content/uploads/2020/05/NCJW_Rep roductiveGuide_Final.pdf...................... 7, 8, 16, 23

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National Council of Jewish Women, Proposed 2020-2023 Resolutions, available at http://www.ncjw.org/wp-content/uploads/2020/05/FINAL-2020-2023-NCJW-RESOLUTIONS.pdf ............................................19 National Council of Jewish Women, Vision for America, available at https://www.ncjw.org/wp-content/uploads/2018/11/Vision-for-America_ONLINE.pdf ........................................19 Peggy Fletcher-Stack, Surprise! The LDS Church can be seen as more 'pro-choice' than 'pro-life' on abortion. Here's why, The Salt Lake Tribune (June 1, 2019), available at https://www.sltrib.com/religion/2019/06/01/surprise-lds-church-can/ .......................6, 14 Pew Research Center, 2014 Religious Landscape Study, available at https://www.pewforum.org/about-the-religious-landscape-study/ ...........................17 Pew Research Center, 2019 Report on Abortion, available at https://www.pewresearch.org/politics/2019/08/29/u-s-public-continues-to-favor-legal-abortion-oppose-overturning-roe-v-wade/ ...............................15, 16

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Pregnancy-Related Maternal Mortality, Mississippi, 2011-2012, available at http://msdh.ms.gov/msdhsite/_static/resources/5631.pdf ..............................................24 Presbyterian Church (U.S.A.), Abortion/Reproductive Choice Issues, available at https://www.presbyterianmission.org/what-we-believe/social-issues/abortion-issues/ ....................................6, 12

Rashi on Sanhedrin 72b:14, available at https://www.sefaria.org/sheets/234926.8?lang=bi .......................................................8, 16 Religious Coalition for Reproductive Choice, Mission Statement, available at https://rcrc.org/mission-statement/ .................19 Sheila Katz, Sara Hutchinson Ratcliffe & Rev. Katey Zeh, Denying Abortion Coverage Is Not a Religious Value, Rewire News Group (Aug. 17, 2020), available at https://rewirenewsgroup.com/article/2020/08/17/denying-abortion-coverage-is-not-a-religious-value/ ........................19 St. Thomas Aquinas, Summa Contra Gentiles 2.88-89 ................................................4, 5 St. Thomas Aquinas, Summa Theologiae 1.118 .....................................................5

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Thirteenth General Synod of the United Church of Christ, Resolution on Freedom of Choice , 81-GS-60 (1981), available at https://www.uccfiles.com/pdf/GS-Resolutions-Freedom-of-Choice.pdf ...............10, 13 Unitarian Universalist Association, General Resolution on the Right to Choose (1987), available at https://www.uua.org/action/statemen ts/right-choose ................................................11, 22 Unitarian Universalist Association, Statement of Conscience on Reproductive Justice , available at https://www.uua.org/action/statemen ts/reproductive-justice ........................................22 United Church of Christ, Statement on Reproductive Health and Justice , available at https://d3n8a8pro7vhmx.cloudfront.n et/unitedchurchofchrist/legacy_url/4 55/reproductive-health-and-justice.pdf?1418423872 ...................................6, 21 Vatican Congregation for the Doctrine of the Faith, Instruction on Respect for Human Life in its Origin and on the Dignity of Procreation , available at https://www.vatican.va/roman_curia/ congregations/cfaith/documents/rc_co n_cfaith_doc_19870222_respect-for-human-life_en.html .............................................14

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Vatican Sacred Congregation for the Doctrine of the Faith, Declaration on Procured Abortion (Nov. 18, 1974), available at https://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_19741118_declaration-abortion_en.html 4 Yevamot 69b, available at https://www.sefaria.org/sheets/234926.8?lang=bi 7

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STATEMENT OF INTEREST

Amici curiae are organizations from a broad range of religious traditions and faiths that are dedicated to protecting a woman's moral authority to terminate a pregnancy in consultation with her faith, values, and conscience, and to safeguarding the Constitution's guarantee of religious liberty. 1

A list of amici appears in Appendix A.

SUMMARY OF ARGUMENT

Religious traditions espouse myriad views on when a human life begins and the process through which that occurs. Numerous religious traditions posit that life begins at some point during pregnancy or even after a child has been born, while others embrace the view that life begins at the moment of conception. Still other faiths expressly decline to identify a precise moment when life begins. Consistent with these diverse beliefs, numerous religions teach that the decision to terminate a pregnancy is a woman's moral prerogative, and that abortion is morally permissible or even required under certain circumstances. Accordingly, these religious

1 Pursuant to Supreme Court Rule 37.3, all parties have given blanket consent to the filing of this and all other amicus curiae briefs. Pursuant to Supreme Court Rule 37.6, amici state that no counsel for a party authored this brief in whole or in part, and no counsel for a party made a monetary contribution intended to fund the preparation or submission of this brief. In addition, no persons or entities other than amici , their members, or their counsel made a monetary contribution to the preparation or submission of the brief.

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traditions recognize and support the moral right of each woman to make her own decisions about her pregnancy in accordance with her faith, beliefs, and individual conscience, regardless of her income, social status, or other resources. Mississippi's Gestational Age Act (the "Ban"), Miss. Code. Ann. § 41-41-191—which prevents any woman from obtaining an abortion after 15 weeks gestation, with only extremely narrow exceptions, id. § 41-41-191(3)(h),(j); id. § 41-41-191(4)—runs counter to these beliefs. The Ban expressly adopts the view that human life begins at the moment of conception by defining "human being" as "an individual member of the species Homo sapiens, from and after the point of conception ." Miss. Code Ann. § 41-41-191(3)(g) (emphasis added)). And Mississippi has justified this measure, in part, based on its stated purpose of protecting "unborn human being[s]." See Miss. Code Ann. § 41-41-191(2)(b); see also Petrs. Br. at 37 (discussing justification for the Ban as Mississippi's interest in "sav[ing] unborn lives"); Pet. for Cert. at 20 (asserting Mississippi's interest in "safeguarding unborn babies and promoting respect for innocent and vulnerable life").

The view adopted by the Ban is based on neither scientific research nor religious consensus. It is consonant with the view of elements of certain religious traditions, but ignores and contradicts the views of many other religious traditions and individuals of faith, including those of amici . The Ban implicates free exercise rights by imposing the view of certain faiths upon all women in the State, including women whose religious faith supports an approach to

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the beginning of human life and the termination of pregnancy that is at odds with the approach reflected in the Ban. The Ban is of significant concern to amici because it fails to account for the diversity of views within and across religious traditions regarding when and how life begins, the moral implications of terminating a pregnancy, and who is properly empowered to make such determinations. The Ban imposes a particular view of when life begins on all Mississippi women, and deprives women of the right to make decisions about their pregnancies according to the dictates of their own faith and beliefs. For these and the reasons set forth below, amici urge the Court to preserve a woman's right to terminate her pregnancy in accordance with her own personal conscience or religious beliefs and to reject the Ban's encroachment on religious freedom.

ARGUMENT

I. Religious Traditions Do Not Share a Uniform View of When Life Begins There is a diversity of views both within and across religions concerning the nature and timing of the beginning of life. Numerous faith traditions embrace the concept of "ensoulment," or the acquisition of personhood, but have divergent views on when and how this pivotal transformation occurs. For example, contemporary Catholic pronouncements on abortion acknowledge the Catholic

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Church's lack of consistent teaching on this question. 2 In early Catholic thought, St. Augustine drew a distinction between an embryo inanimatus , not yet endowed with a soul, and an embryo animatus , but concluded that it was impossible to pinpoint the moment during fetal development when this transition takes place. 3 Some Medieval Catholic texts endorsed Aristotle's view that human ensoulment takes place 40 days after conception for males and 80 days after conception for females. 4 Other Catholic theologians followed the teaching of St. Thomas Aquinas, who believed that human life does not begin until at or near the time of childbirth, following earlier stages in which the fetus initially had a "nutritive" soul (similar to plant life), and later a "sensitive" soul (similar to animals), only acquiring an "intellectual" human soul infused by God near the final stages of gestation. 5 In 2 See Vatican Sacred Congregation for the Doctrine of the Faith, Declaration on Procured Abortion , at n.19 (Nov. 18, 1974), available at https://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_19741118_declaration-abortion_en.html .

3 See Roe v. Wade , 410 U.S. 113, 134 n.22 (1973) (citing Augustine, De Origine Animae 4.4).

4 See Anne Stensvold, A History of Pregnancy in Christianity: From Original Sin to Contemporary Abortion Debates 45-46 (2015). Using the modern obstetric methodology of counting, this translates to approximately 7-8 weeks gestation for males and 13-14 weeks gestation for females.

5 See St. Thomas Aquinas, Summa Contra Gentiles 2.88-89 (explaining that "the manifestation of the soul's operations goes hand in hand with the development in shape and size of the members of the body, the operation of the nutritive soul appearing first, and afterwards, that of the sensitive soul, and

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the sixteenth century, the Catholic Church's position varied between viewing life as beginning at conception and viewing it as happening later, at the time of "quickening," when the fetus first moves in a woman's womb, which typically occurs around 18-20 weeks. 6 In the view of some contemporary Catholic scholars, the Catholic Church has never defined the moment when life begins, and therefore, as a matter of Catholic dogma, "[t]here is no defined moment of ensoulment." 7 Many Protestant denominations likewise acknowledge and reflect diverse understandings of when life begins. In articulating their religious views on abortion, the Presbyterian Church, Lutheran Church, and the United Church of Christ have lastly, when the bodily development is complete , the operation of the intellective soul" (emphasis added)); id. ("Thus, the vegetative soul, which is present first (when the embryo lives the life of a plant), perishes, and is succeeded by a more perfect soul, both nutritive and sensitive in character, and then the embryo lives an animal life; and when this passes away it is succeeded by the rational soul introduced from without[.]"); Aquinas, Summa Theologiae 1.118 (concluding that "the intellectual soul is created by God at the end of human generation " (emphasis added)); see also Gary Wills, Abortion Isn't a Religious Issue , The Los Angeles Times (November 4, 2007).

6 Anne Stensvold, A History of Pregnancy in Christianity: From Original Sin to Contemporary Abortion Debates 70 (2015); Frank K. Flinn, Encyclopedia of Catholicism 4 (2007); see also Elissa Strauss, When Does Life Begin? It's Not So Simple , Slate (April 4, 2017), available at https://slate.com/human-interest/2017/04/when-does-life-begin-outside-the-christian-right-the-answer-is-over-time.html [hereinafter "Strauss, When Does Life Begin? "). 7 Strauss, When Does Life Begin? (quoting Daniel Sulmasy, Catholic bioethicist and director of the Program on Medicine and Religion at the University of Chicago).

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expressly noted the range of views on this question and have declined to identify a particular moment as the beginning of life. 8

Similarly, the Church of Jesus Christ of Latter-Day Saints (the "LDS Church") has never taken an official position on when a fetus acquires personhood. 9 Some LDS Church scholars embrace the view that the spirit does not enter the body until the moment of first breath, while others believe that it happens when the woman first feels the fetus move. 10 Other scholars note 8 See, e.g. , Presbyterian Church (U.S.A.), Abortion/ Reproductive Choice Issues ("We may not know exactly when human life begins[.]"), available at https://www.presbyterianmission.org/what-we-believe/social-issues/abortion-issues/ ; United Church of Christ, Statement on Reproductive Health and Justice (noting the "many religious and theological perspectives on when life and personhood begin"), available at https://d3n8a8pro7vhmx.cloudfront.net/unitedchurchofchrist/le gacy_url/455/reproductive-health-and-justice.pdf?1418423872 ; Evangelical Lutheran Church in America, Social Statement on Abortion at 1, 3 n.2 (1991) (explaining that embryology provides insight into the "complex mystery of God's creative activity" but that individual interpretation of the scientific information leads to various understandings of when life begins), available at http://download.elca.org/ELCA%20Resource%20Repository/Abo rtionSS.pdf .

9 Peggy Fletcher-Stack, Surprise! The LDS Church can be seen as more 'pro-choice' than 'pro-life' on abortion. Here's why. The Salt Lake Tribune (June 1, 2019), available at https://www.sltrib.com/religion/2019/06/01/surprise-lds-church-can/ . 10 Id. ; see also The Latter-day Saints Tradition: Religious Beliefs and Healthcare Decisions (Deborah Abbott, ed.) at 10 (2002), available at

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that whereas neonatal deaths are recorded in LDS Church records, stillbirths and miscarriages typically are not, suggesting that the body does not become infused with the spirit until after a live birth. 11 In the Jewish tradition, the creation of a human life is generally viewed as something that happens gradually over time. 12 The majority of Jews do not believe that life begins at the moment of conception; rather, Jewish "tradition holds that we enter life in stages and leave in stages," according to Rabbi Elliot Dorff, bioethicist and professor of Jewish theology at the American Jewish University. 13 The Talmud teaches that the fetus is "mere fluid" up to the point of 40 days gestation, see Yevamot 69b, 14 and following this period, the fetus is considered a physical part of the pregnant woman's body, see Gittin 23b, not yet

11 Lester E. Bush, Ethical Issues in Reproductive Medicine: A Mormon Perspective , Dialogue: a Journal of Mormon Thought at 51 (1985), available at https://www.dialoguejournal.com/articles/ethical-issues-in-reproductive-medicine-a-mormon-perspective/ .

12 Strauss, When Does Life Begin?

13 Id.; see also National Council of Jewish Women, Abortion and Jewish Values Toolkit at 16 (2020), available at https://www.ncjw.org/wp-content/uploads/2020/05/NCJW_ReproductiveGuide_Final.pdf (hereinafter, "NCJW, Abortion and Jewish Values "). 14 Available at https://www.sefaria.org/sheets/234926.8?lang=bi . Note that this is understood as 40 days from conception , or approximately 7-8 weeks gestation.

https://www.advocatehealth.com/assets/documents/faith/latter-day_saints_tradition.pdf .

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having a life of its own or independent rights. 15 It is not until the moment of birth when the head has emerged and the baby has breathed outside air that it is considered a living being, see Mishnah Oholot 7:6. 16 Similarly, among Muslims "there is no universally agreed-upon moment when a fetus becomes a person." 17 However, the predominant view is that a fetus acquires personhood 120 days from conception (approximately 19-20 weeks gestation). 18 The Supreme Court has previously recognized the "wide divergence of thinking" about this issue, and expressly declined to resolve "the difficult question of when life begins," where "those trained in the respective disciplines of medicine, philosophy, and theology are unable to arrive at any consensus." Roe v. Wade , 410 U.S. 113, 159, 160 (1970). The diversity of views on this question, and the importance of allowing individuals to answer it for themselves, underlies this Court's jurisprudence affirming the right to obtain abortions pre-viability. As this Court explained in Planned Parenthood of Southeastern

15 See id. ; see also Strauss, When Does Life Begin? , NCJW, Abortion and Jewish Values at 16; Mark Cherry, Religious Perspectives on Bioethics 166-67 (2004). 16 See NCJW, Abortion and Jewish Values at 16; Strauss, When Does Life Begin? ; Rashi on Sanhedrin 72b:14, available at https://www.sefaria.org/sheets/234926.8?lang=bi . 17 Strauss, When Does Life Begin?

18 Mark Cherry, Religious Perspective on Bioethics 196-97 (2004); Abdulaziz Sachedina, Islamic Biomedical Ethics: Principles and Applications 134-35, 140-41 (2009); Dariusch Atighetchi, Islamic Bioethics: Problems and Perspectives 94 (2006); see also Strauss, When Does Life Begin?

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Pennsylvania v. Casey , "[t]hese matters, involving the most intimate and personal choices a person may make in a lifetime, choices central to personal dignity and autonomy, are central to the liberty protected by the Fourteenth Amendment. At the heart of liberty is the right to define one's own concept of existence, of meaning, of the universe, and of the mystery of human life. " 505 U.S. 833, 851 (1992) (emphasis added). The Ban is at odds with the views of the diverse religious traditions that are discussed above. The Ban adopts the view—endorsed by some, but not all, religious traditions—that human life begins at the moment of conception. See Miss. Code. Ann. § 41-41-191(3)(g). Indeed, the stated rationale for the Ban is Mississippi's asserted interest in protecting "unborn life" from that moment. See id. § (2)(b). By taking this approach, the Ban fails to account for—and indeed, disrespects—the diverse religious views of its many citizens whose religious faith leads them to take a very different view of when human life begins. As this Court has previously held, a state may not "by adopting one theory of life . . . override the rights of the pregnant woman that are at stake." Roe , 410 U.S. at 162. Mississippi should not be permitted to do so here. II. Religious Traditions Affirm Women's Moral Right to Decide Whether and Under What Circumstances to Terminate a Pregnancy

A broad range of religious traditions recognize and support the moral right of each woman to make her own decisions about her pregnancy in accordance

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with her faith and her conscience, regardless of the stage of pregnancy. Numerous Protestant denominations expressly affirm that every woman is a moral agent with both the capacity and the ultimate right to determine whether an abortion is justified in her specific circumstances, consistent with her faith. For instance, the Presbyterian Church asserts that "[h]umans are empowered by the spirit prayerfully to make significant moral choices, including the choice to continue or end a pregnancy." 19 Similarly, the United Church of Christ embraces the view that "[e]very woman must have the freedom of choice to follow her personal religious and moral convictions concerning the completion or termination of her pregnancy." 20 The Episcopal Church of America has adopted the position that the "decision to terminate a pregnancy . . . properly belongs to the couple, in consultation with their physician and the Church." 21 Likewise, the Disciples of Christ has resolved that "the place of decision making on abortion [is] not with public legislators, but with the individuals involved with the pregnancy . . . on the basis of ethical and moral

19 Minutes of the 217th General Assembly of the Presbyterian Church (U.S.A.) at 905 (2006). 20 Thirteenth General Synod of the United Church of Christ, Resolution on Freedom of Choice, 81-GS-60 (1981) at 10, available at https://www.uccfiles.com/pdf/GS-Resolutions-Freedom-of-Choice.pdf . 21 Episcopal Church, Standing Commission on Human Affairs and Health, Resolution #A087 at 153 (1988) available at https://www.episcopalarchives.org/e-archives/gc_reports/reports/1988/bb_1988-R016.pdf .

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grounds." 22 And the Unitarian Universalist Association asserts that "the personal right to choose in regard to contraception and abortion" is an important aspect of the "right of individual conscience" and the "inherent worth and dignity of every person." 23 Many other Protestant denominations embrace similar views. 24 In addition, a number of Protestant denominations teach that the decision to terminate a

22 Freedom of Choice Act of 1989: Hearing on S. 1912 Before the S. Comm. on Labor and Human Resources, 101st Cong. 237 (1990) (testimony of John O. Humbert, General Minister and President, Christian Church (Disciples of Christ) in the USA and Canada) (citing General Assembly Resolutions of the Christian Church (Disciples of Christ) Resolution S9854 (1989) and 7524 (1975)). 23 Unitarian Universalist Association, General Resolution on the Right to Choose (1987), available at https://www.uua.org/action/statements/right-choose .

24 See, e.g. , American Baptist Association, Resolution Concerning Abortion and Ministry in the Local Church (1987), available at http://www.abc-usa.org/wp-content/uploads/2012/06/Abortion-and-Ministry-in-the-Local-Church.pdf ; Brief of Amici Curiae Religious Coalition for Reproductive Choice, et al., in Support of Respondent, Stenberg v. Carhart , No. 99-380 (Mar. 29, 2000) (describing views of American Friends Service Committee affirming "a woman's right to follow her own conscience concerning child-bearing, abortion, and sterilization"); Metropolitan Community Churches, Statement of Faith on Women's Reproductive Health, Rights, and Justice (March 20, 2013) (affirming "that all people are entitled to the rights and resources that equip them to make their own decisions about their bodies . . . and their well-being, including the inalienable right of women to control their bodies"), available at https://www.mccchurch.org/statement-of-faith-on-womens-reproductive-health-rights-and-justice/ .

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pregnancy is a morally permissible choice consistent with Christian ethics, at least in certain circumstances, and that the law should not preclude a woman from making the ultimate determination to obtain an abortion according to her own faith and conscience. For instance, the Presbyterian Church affirms that "[t]he considered decision of a woman to terminate a pregnancy can be morally acceptable," and "therefore should not be restricted by law." 25 Similarly, the Episcopal Church of America recognizes "the moral option for termination of [a] pregnancy in specific instances" and expresses a "deep conviction" that any legislation surrounding abortion "must take special care to see that individual conscience is respected," 26 and must not "abridge[] the right of a woman to reach an informed decision about the termination of pregnancy" or limit her access "to safe means of acting on her decision." 27 And the Evangelical Lutheran Church in America affirms that 25 Presbyterian Church (U.S.A.), Abortion/Reproductive Choice Issues , available at https://www.presbyterianmission.org/what-we-believe/social-issues/abortion-issues/ .

26 Episcopal Church, Standing Commission on Human Affairs and Health , Resolution #A087 at 153 (1988) available at https://www.episcopalarchives.org/e-archives/gc_reports/reports/1988/bb_1988-R016.pdf . 27 General Convention, Journal of the General Convention of...The Episcopal Church , Indianapolis, 1994 (New York: General Convention, 1995), pp. 323-25 (expressing "unequivocal opposition to any legislative, executive or judicial action . . . that abridges the right of a woman to reach an informed decision about the termination of pregnancy or that would limit the access of a woman to safe means of acting on her decision"), available at https://www.episcopalarchives.org/cgi-bin/acts/acts_generate_pdf.pl?resolution=1994-A051 .

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"there can be sound reasons for ending a pregnancy through induced abortion," and that there are situations where obtaining an abortion may be a "morally responsible" choice. 28 The Lutheran Church has therefore asserted its opposition to "laws that deny access to safe and affordable services for morally justifiable abortions." 29 Other Protestant denominations, including the United Church of Christ, the Alliance of Baptists, and the Disciples of Christ espouse similar views. 30

28 Evangelical Lutheran Church in America, Social Statement on Abortion (1991), at 6-7, 9-10, available at https://download.elca.org/ELCA%20Resource%20Repository/AbortionSS.pdf?_ga=2.126669897.557303659.1627007329-314140115.1627007329 . 29 Id. 30 See Thirteenth General Synod of the United Church of Christ, Resolution on Freedom of Choice 81-GS-60 (1981), available at https://www.uccfiles.com/pdf/GS-Resolutions-Freedom-of-Choice.pdf ; Alliance of Baptists, A Statement on Lifelong Sexual Education, Sexual & Reproductive Rights, and Opposing Sexual Justice and Violence (2012), available at http://www.sitemason.com/files/kuGj7v/StatementonLifelongSexualEducation.pdf ; Freedom of Choice Act of 1989: Hearing on S. 1912 Before the S. Comm. On Labor and Human Resources, 101st Cong. 237 (1990) (testimony of John O. Humbert, General Minister and President, Christian Church (Disciples of Christ) in the USA and Canada) (citing General Assembly Resolutions of the Christian Church (Disciples of Christ) Resolution S9854 (1989) and 7524 (1975)).

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The LDS Church likewise "ultimately defers to [the] moral agency" of the pregnant woman in making this decision. 31 There are also diverse views within the Catholic Church on the moral propriety of obtaining an abortion. While the official stance of the Catholic Church is that abortion is impermissible, 32 the majority of American Catholics believe that abortion can be a morally acceptable choice, 33 that abortion

31 Peggy Fletcher-Stack, Surprise! The LDS Church can be seen as more 'pro-choice' than 'pro-life' on abortion. Here's why. The Salt Lake Tribune (June 1, 2019) (citing the work of Courtney Campbell, a Mormon professor of religion and culture at Oregon State University) available at https://www.sltrib.com/religion/2019/06/01/surprise-lds-church-can/ ; see also The Latter-day Saints Tradition: Religious Beliefs and Healthcare Decisions (Deborah Abbott, ed.) at 10-11 (2002) (affirming the "right of a woman to make her own decision" in the matter of whether to have an abortion), available at https://www.advocatehealth.com/assets/documents/faith/latter-day_saints_tradition.pdf . 32 Vatican Congregation for the Doctrine of the Faith, Instruction on Respect for Human Life in its Origin and on the Dignity of Procreation, available at https://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_19870222_respect-for-human-life_en.html . 33 Belden Russonello Strategists, 2016 Survey of Catholic Likely Voters, at 5 (October 2016) ("Sixty percent of Catholic likely voters overall say that 'deciding to have an abortion can be a morally acceptable position.'"), available at http://www.rlfuture.org/wp-content/uploads/2016-Catholic-Voter-Poll.pdf .

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should be legal in all or most cases, 34 and that Roe v. Wade should not be overturned. 35 Moreover, Catholic women in this country have abortions at approximately the same rate as do women of other (or no) faith traditions. 36 Traditional Jewish teachings view abortion as permissible and even as required when abortion is necessary to safeguard the well-being of the mother, at 34 Dalia Fahmy, 8 Key Findings about Catholics and Abortion , Pew Research Center (October 20, 2020) (56% of Catholics believe abortions should be legal in all or most circumstances), available at https://www.pewresearch.org/fact-tank/2020/10/20/8-key-findings-about-catholics-and-abortion/ ; see also Pew Research Center, 2019 Report on Abortion , available at https://www.pewresearch.org/politics/2019/08/29/u-s-public-continues-to-favor-legal-abortion-oppose-overturning-roe-v-wade/ . 35 Dalia Fahmy, 8 Key Findings about Catholics and Abortion , Pew Research Center (October 20, 2020) (68% of Catholics say they do not want the Supreme Court to overturn Roe v. Wade ), available at https://www.pewresearch.org/fact-tank/2020/10/20/8-key-findings-about-catholics-and-abortion/ ; see also Pew Research Center, 2019 Report on Abortion , available at https://www.pewresearch.org/politics/2019/08/29/u-s-public-continues-to-favor-legal-abortion-oppose-overturning-roe-v-wade/ .

36 Guttmacher Institute, Characteristics of U.S. Abortion Patients in 2014 and Changes since 2008 , at 1, 6-7 (May 2016), available at https://www.guttmacher.org/sites/default/files/report_pdf/characteristics-us-abortion-patients-2014.pdf ; see also Guttmacher Institute, Fact Sheet: Induced Abortion in the United States , at 1 (2019), available at https://www.guttmacher.org/sites/default/files/factsheet/fb_induced_abortion.pdf .

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any stage of pregnancy. See Mishnah Ohalot 7:6. 37 Reform, Reconstructionist, and Conservative Judaism all adopt the view that "women are capable of making moral decisions, often in consultation with their clergy, families and physicians, on whether or not to have an abortion." 38 Moreover, hundreds of Jewish leaders have recently reaffirmed the importance of ensuring women's access to reproductive healthcare, including abortion, as an essential matter of religious freedom. 39 Other major religions likewise teach that abortion is both permissible and moral under certain circumstances and embrace the ultimate authority of a woman to make the decision whether to terminate a pregnancy, consistent with her faith and values. For instance, many schools of Islamic thought permit abortion, under certain circumstances, at any point up to 120 days from conception, or approximately 19-20 weeks gestation. 40 The Buddhist Churches of America assert that "it is the woman carrying the fetus; and no one else, who must in the end make this most difficult 37 See Strauss, When Does Life Begin? ; NCJW, Abortion and Jewish Values at 16; Rashi on Sanhedrin 72b:14, available at https://www.sefaria.org/sheets/234926.8?lang=bi .

38 144 Cong. Rec. S10491 (daily ed. Sept. 17, 1998) (quoting Letter of 729 Rabbis in Support of President Clinton's Veto of H.R. 1122 (Sept. 10, 1998)). 39 Letter of Jewish Clergy Leaders to the Senate Committee on the Judiciary, dated July 16, 2021, available at https://www.ncjw.org/wp-content/uploads/2021/07/06-16-2021_Jewish-Clergy-Leaders-WHPA-Letter-FINAL-1.pdf .

40 Mohammad A. Albar, Induced Abortion From An Islamic Perspective: Is It Criminal Or Just Elective , 8 J. Fam. Cmty. Med. 25, 29-32 (2001); see also Strauss, When Does Life Begin? .

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decision." 41 And while there are various views within Hinduism on the propriety of abortion, many Hindus adopt the position that "each case [of abortion] requires unique consideration" and that the "final decision will be based on a long series of choices made by the woman on her lifestyle, morals, and values." 42 Consistent with this view, the majority of Hindus in the United States believe that abortion should be legal. 43 The Constitutional protection for abortion respects this diversity of religious views by ensuring that before the point of viability, every woman has ultimate moral agency over the decision to end her pregnancy and should be able to make that decision based on her own spiritual and religious convictions. As this Court explained in Casey , "[t]he destiny of the woman must be shaped to a large extent on her own conception of her spiritual imperatives and her place in society." 505 U.S. at 852 (emphasis added). But the Ban prevents women from doing so, and instead resolves "these philosophic questions in such a definitive way that a woman lacks all choice in the matter." Id. at 850.

41 Buddhist Churches of America Social Issues Committee, A Shin Buddhist Stance on Abortion at 6, Buddhist Peace Fellowship Newsletter 6 (1984). 42 Hindus in America Speak Out On Abortion Issues , Hinduism Today, (Sept. 1985), available at https://www.hinduismtoday.com/magazine/september-1985/1985-09-hindus-in-america-speak-out-on-abortion-issues/ .

43 Pew Research Center, 2014 Religious Landscape Study at 110, available at https://www.pewforum.org/about-the-religious-landscape-study/ .

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While the view adopted by the Ban—that life begins from the moment of conception, see Miss. Code Ann. § 41-41-191(3)(c),(g)—reflects the stance of certain religious traditions, it is at odds with the teachings of other faiths, as discussed above. The Ban then uses this distinct, faith-based view as the predicate for its sweeping prohibition on pre-viability abortion after 15 weeks. In doing so, the Ban disregards the diversity of religious viewpoints on when life begins. It divests women of their capacity to make personal decisions about abortion according to their own consciences and moral and religious beliefs. By elevating a particular religious viewpoint and restricting the ability of women to act according to their own faith traditions and beliefs, the Ban threatens the freedom of all religious communities.

The Ban offends the values of religious pluralism and religious freedom, which are enshrined in the U.S. Constitution and embraced by amici and the numerous faith traditions they represent. See, e.g., Statement of Catholics for Choice (affirming that "As Catholics, . . . [we] value religious pluralism" and believe that "[e]veryone has the right to live according to their own beliefs and consciences, and they also have the right to live free from having the religious beliefs of others imposed on them") 44 ; Religious Coalition for Reproductive Choice Mission Statement ("RCRC values and promotes religious liberty which upholds the human and constitutional rights of all people to exercise their conscience to make their own reproductive health decisions without shame and

44 Catholics for Choice, Religious Freedom , available at https://www.catholicsforchoice.org/issues/religious-freedom/ .

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stigma") 45 ; National Council of Jewish Women (affirming belief that "[r]eligious liberty . . . must be protected" and that "protecting an individual's ability to make their own health care decisions in accordance with their needs and personal beliefs is tied to religious freedom"). 46 As several of the amici recently stated in reaffirming that "[r]eligious freedom is an essential shared principle undergirding [their] support of policies that ensure equitable access to abortion": The United States is home to people of many different faiths as well as people with no religious affiliation. We cannot limit an individual's religious liberty by enshrining one set of beliefs into law and restricting their ability to make personal decisions about their pregnancy, health, and family according to their own religious or moral beliefs and conscience. No government committed to human rights and democracy can privilege one religion over another. 47

45 Religious Coalition for Reproductive Choice, Mission Statement , available at https://rcrc.org/mission-statement/ . 46 National Council of Jewish Women, Proposed 2020-2023 Resolutions at 1, available at http://www.ncjw.org/wp-content/uploads/2020/05/FINAL-2020-2023-NCJW-RESOLUTIONS.pdf ; National Council of Jewish Women, Vision for America at 5, available at https://www.ncjw.org/wp-content/uploads/2018/11/Vision-for-America_ONLINE.pdf . 47 Sheila Katz, Sara Hutchinson Ratcliffe & Rev. Katey Zeh, Denying Abortion Coverage Is Not a Religious Value , Rewire News Group (Aug. 17, 2020), available at

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This Court should not countenance Mississippi's elevation of one set of religious beliefs into law at the expense of others. At the core of religious and personal liberty is the "right to define one's own concept of existence, of meaning, of the universe, and of the mystery of human life." Casey , 505 U.S. at 851. As this Court has previously recognized, it is each woman's prerogative to form her own views about these subjects in accordance with her own religious beliefs without interference from the state. Id. (explaining that "[b]eliefs about these matters could not define the attributes of personhood were they formed under compulsion of the State"). But the Ban prevents women from doing precisely this by imposing upon them one particular religious view concerning the beginning of life. III. Religious Traditions Affirm the Importance of Ensuring Reproductive Choice for Women in Marginalized Communities Who Are Disproportionately Harmed by the Ban

A broad array of religions embrace as a central tenet of their faith the importance of serving and supporting vulnerable and marginalized communities. Many of these traditions teach that people of faith have a moral obligation to protect, succor, uplift, and advocate on behalf of those who are poor and low-income and those who have historically been disenfranchised and discriminated against, including people of color, people with disabilities, immigrants, and LGBTQ individuals. And numerous religions

https://rewirenewsgroup.com/article/2020/08/17/denying-abortion-coverage-is-not-a-religious-value/ .

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expressly affirm that this charge includes ensuring that individuals from these communities have the same access to health care and the same freedom to make decisions concerning their reproductive health, including the right to abortion. For example, the Alliance of Baptists has called for a "faith-based commitment to sexual and reproductive rights, including access to voluntary contraception and abortion," consistent with their mission to "side with those who are poor" and "[p]ursue justice with and for those who are oppressed," regardless of "sex, gender, color, age, bodily condition, marital status or sexual orientation." 48 Similarly, the United Church of Christ has adopted resolutions supporting measures to ensure that "women with limited financial means" are able to "exercise [their] legal right to the full range of reproductive health services," and affirming that "[w]hat is legally available to women must be accessible to all women." 49 48 Alliance of Baptists, A Statement on Lifelong Sexual Education, Sexual & Reproductive Rights, and Opposing Sexual Justice and Violence (2012), available at http://www.sitemason.com/files/kuGi7v/StatementonLifelongSexualEducation.pdf .

49 United Church of Christ, Statement on Reproductive Health and Justice , available at https://d3n8a8pro7vhmx.cloudfront.net/unitedchurchofchrist/legacy_url/455/reproductive-health-and-justice.pdf?1418423872 ; see also Connecticut Conference of the United Church of Christ, Resolution: Freedom of Choice Concerning Abortion (1971), available at http://www.ctucc.org/files/tables/content/7726678/fields/files/327cad155b9c43dd8a95e03e4179fbe8/1971_freedom_of_choice.pdf (affirming that laws that "severely limit[] access to safe abortions

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And the Unitarian Universalist Association has affirmed its support for the reproductive justice movement as an extension of its core theological teachings, acknowledging the ways that an individual's right to make reproductive choices is shaped by "social and political systems as well as by factors such as racial/cultural identity, economic status, immigration/citizenship status, relationship with the justice system, health status, and ability." 50 Consistent with these teachings, the Unitarian Universalist Association seeks to ensure "control of personal reproductive decisions" for people of "all genders, sexual orientations, abilities, gender identities, ages, classes, and cultural and racial identities," and "especially the most vulnerable and marginalized," 51 and has condemned attempts "to restrict access to birth control and abortion by overriding individual decisions of conscience" which "often result in depriving poor women of their right to medical care." 52 In addition, many Catholics believe that protecting the right of poor and vulnerable women to choose whether to end their pregnancies is a natural and necessary outgrowth of core principles of Catholic . . . have the effect of discriminating against the poor" and are therefore "neither just nor enforceable"). 50 Unitarian Universalist Association, Statement of Conscience on Reproductive Justice , available at https://www.uua.org/action/statements/reproductive-justice.

51 Id.

52 Unitarian Universalist Association, General Resolution on the Right to Choose (1987), available at https://www.uua.org/action/statements/right-choose.

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social justice. 53 Similarly, many believers from the Jewish tradition expressly link the Jewish teaching of tzedek tzedek tirdof —i.e., to pursue justice for all—to the obligation to advocate for the reproductive rights of all persons as a matter integral to religious liberty, so that each individual can make their own moral or faith-based decisions about their body, health, and family. 54 The Ban will have a devastating impact on women from precisely these vulnerable communities. See generally, e.g. , Br. of Amici Curiae The Lawyers Committee for Civil Rights Under Law, the Leadership Conference on Civil and Human Rights and other Civil Rights Organizations (discussing the impact of the Ban on low-income and Black women in Mississippi); Br. of Amici Curiae Organizations Dedicated to the Fight for Reproductive Justice (discussing barriers in accessing reproductive healthcare faced by people of color, low-income people, people with disabilities, immigrants and indigenous persons, and LGBTQ individuals, and the impact the Ban will have on these marginalized groups). As the District Court observed in this case, the Ban would "disproportionately impact poor women." Petition Appendix ("Pet. App.") 49a. The majority of abortion patients nationwide are either poor or low-income, 55 and Mississippi "has a greater

53 See Catholics for Choice, Social Justice , available at https://www.catholicsforchoice.org/issues/social-justice/ ; Catholics for Choice, Reproductive Equity , available at https://www.catholicsforchoice.org/issues/reproductive-choice/ .

54 See NCJW, Abortion and Jewish Values at 13-14. 55 See Guttmacher Institute, Fact Sheet: Induced Abortion in the United States , at 1 (2019), available at

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population of poor women than any other state in the country." Pet. App. 49a. Mississippi is also the state with the "most medical challenges for women, infants, and children," Pet. App. 46a, and has among the highest rates of infant and maternal mortality in the country—rates that are disproportionately higher among women of color. 56 Moreover, poor women are "less likely to be able to leave the state to obtain the care they need," Pet. App. 49a, meaning that the Ban would leave them with little recourse if they seek to terminate a pregnancy beyond 15 weeks, increasing the chances women will attempt unsafe methods of self-induced abortion, or be forced to take on the risks of continued pregnancy, regardless of their religious convictions or personal circumstances. By placing a disproportionate burden on the most vulnerable women, and effectively denying them the freedom to make determinations about their reproductive health and family formation in accordance with their own beliefs, the Ban further undermines religious liberty. https://www.guttmacher.org/sites/default/files/factsheet/fb_indu ced_abortion.pdf .

56 See Pregnancy-Related Maternal Mortality, Mississippi, 2011-2012, available at http://msdh.ms.gov/msdhsite/_static/resources/5631.pdf ; Mississippi Maternal Mortality Report, 2013-2016, at 12 (April 2019), available at https://msdh.ms.gov/msdhsite/index.cfm/31,8127,299,pdf/Mater nal_Mortality_2019_amended.pdf ; Mississippi State Department of Health, Infant Mortality Report, 2018, at 2, available at https://msdh.ms.gov/msdhsite/_static/resources/8015.pdf .

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CONCLUSION

Being forced to carry a pregnancy to term against her wishes is an affront to a woman's moral authority to make decisions about her own life and body in keeping with her religious faith and values. As the Fifth Circuit observed in the decision below, "[u]ntil viability, it is for the woman, not the state . . . to consider [her] personal values and beliefs in deciding whether to have an abortion." Pet. App. 13a (citing Casey , 505 U.S. at 879). By prohibiting abortions beyond 15 weeks gestation, the Ban precludes women from making that choice in accordance with their own moral, spiritual, and religious beliefs, which this Court has recognized as a constitutional right. See Casey , 505 U.S. at 879 (holding that "a State may not prohibit any woman from making the ultimately decision to terminate her pregnancy before viability").

This Court should affirm the Fifth Circuit's decision. Respectfully submitted,

EUGENE M. GELERNTER Counsel of Record SAUL B. SHAPIRO LEIGH E. BARNWELL PATTERSON BELKNAP WEBB & TYLER LLP

1133 Avenue of the Americas New York, New York 10036 (212) 336-2000 emgelernter@pbwt.com

Counsel for Amicus Curiae

September 2021

1a

APPENDIX A: LIST OF AMICI CURIAE

Catholics for Choice National Council of Jewish Women Religious Coalition for Reproductive Choice Muslim Advocates African American Ministers In Action Ameinu American Jewish Congress Auburn Theological Seminary (Auburn) Avodah Call To Action DFW Muslim Bar Association DignityUSA Florida Interfaith Coalition for Reproductive Health and Justice Habonim Dror North America HEART Women & Girls Interfaith Alliance of Colorado

2a

Jewish Alliance for Law and Social Action Jewish Orthodox Feminist Alliance Jewish Women International (JWI) Jewish Women's Foundation of New York Judson Memorial Church KARAMAH: Muslim Women Lawyers for Human Rights Keshet Metropolitan Community Churches, Global Justice Institute Moving Traditions MASGD (Muslim Alliance for Sexual and Gender Diversity) Muslim Bar Association of New York Muslims for Progressive Values National Council of Jewish Women, Austin Section National Council of Jewish Women, Greater Dallas Section National Council of Jewish Women, Greater Houston Section

3a

National Council of Jewish Women, Greater New Orleans Section National Council of Jewish Women, San Antonio Section Nebraska Religious Council for Reproductive Freedom (NE-RCRF) New Jersey Muslim Lawyers Association New York Jewish Agenda NM Religious Coalition for Reproductive Choice Ohio Religious Coalition for Reproductive Choice PA Religious Coalition for Reproductive Justice Partnership to End Gendered Islamophobia Presbyterians Affirming Reproductive Options (PARO) Quixote Center Rabbinical Assembly Reconstructionist Rabbinical Association Religious Coalition for Reproductive Choice California Rhode Island Religious Coalition for Reproductive Freedom

4a

Sikh Coalition Society for Humanistic Judaism Student Coalition for Reproductive Justice T'ruah: The Rabbinical Call for Human Rights Teen JUST-US Unitarian Universalist Association Unitarian Universalist Women's Federation Women's Alliance For Theology, Ethics, And Ritual (WATER)