Meet Joe Scheidler, Patriarch of the Anti-Abortion Movement

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Nearly 30 years later, anti-abortion activists still work from Joe Scheidler’s blueprint. Could Scheidler’s story provide any clues to where the faults might lie in their strategy?

This article appears in PRA’s Winter, 2015 issue of The Public Eye magazine.

Abortion has been legal—with restrictions—in all 50 states for nearly 42 years, and anti-abortion activist Joe Scheidler has been fighting to make it illegal again for just as many of them. Still comfortably ensconced in his Chicago home, Scheidler, at 87 years old, is father, “Godfather,” and leader to generations of zealots. They continue using tactics Scheidler designed as they protest in the legislature, outside clinic doors, and even across the ocean, all with the goal of criminalizing—and removing access to—safe, legal abortion.

Now that the anti-abortion movement has grown more powerful in the last few years than it has been at any point in the history of legal abortion, it is worth examining where Joe Scheidler’s architecture is still being used—and where it might be decaying or vulnerable.1 Although the days of having a clinic door physically blocked by human bodies or of having abortion providers picketed at their own homes are mostly a thing of the past, today’s assault on legal abortion differs only slightly from these methods.

Joe Scheidler

Joe Scheidler

AN ANTI-ABORTION HOW-TO MANUAL

Pro-Life Action League (PLAL), the anti-abortion advocacy group Scheidler founded in 1980, may not have the name recognition of Operation Rescue (the militant anti-abortion group best known in the 1990s for blocking abortion clinics and terrorizing patients and providers), or National Right to Life Committee (an umbrella group for the state and local affiliates of the national pro-life movement). Still, PLAL has had a profound impact on the movement. Scheidler’s 1985 book, Closed: 99 Ways to Stop Abortion2, became the handbook of those hoping to put abortion providers out of business with tactics ranging from creating mild nuisances to outright harassment and borderline stalking.

Those tactics haven’t changed much in the 29 years since the book was published. Some of the book’s tips, like “conduct a blitz”—coordinating a group of anti-abortion activists to enter a clinic and refuse to leave until the police arrive, all the while attempting to talk patients in the waiting room out of undergoing abortion—no longer can be legally attempted. But other tactics detailed in Closed, such as protests at hospitals, medical offices, or other businesses affiliated with abortion providers, still happen with great frequency. Meanwhile, so-called “sidewalk counseling” has become the signature activity of choice for abortion opponents, using scripts that are often based on the “Chicago-style” training method established by Scheidler and his colleagues.

Groups such as 40 Days for Life promote a constant clinic presence, in some cases even at buildings that only refer for, rather than actually offer, abortions on site. Other organizations, either national or local in scope, trade the allegedly silent (but often actually quite audible) prayers for graphic signs, amplified street preaching, and chasing of potential clinic patients and staff all the way to the building’s entrance.

These groups are also gaining the advantage in the courts. For years, local buffer zones were able to provide an element of protection for clinic patients in some cities across the country. But the Supreme Court’s decision in June of 2014 to eliminate Massachusetts’ buffer zone has led to new efforts to tear down remaining patient safety areas, and to even bolder anti-abortion activity outside abortion clinics.

Anti-abortion activists still document license plates at clinics3, as Scheidler encourages in Chapter 60 of Closed. They still gather in large groups, and while they may not physically block the clinic doors, they instead line the sidewalks on each side as near to the door as possible, 4 using their numbers and presence to bar the entrance. They still write complaints about providers and clinics to file with local departments of health, and they still wait on the streets to document a medical emergency on the rare occasion that an ambulance may be called to the building.

INSPIRING ACTIVISTS AND CRIMINALS

The inspiration for much of this activity belongs to Scheidler. Trained first as a Benedictine monk and next as a journalist, Scheidler began his anti-abortion activism career first with Illinois Right to Life Committee and next with another anti-abortion group called Friends for Life. Scheidler claims he was forced out of both positions due to his unwillingness to work with boards or wait for permission from others to engage in his activist stunts. Scheidler used his severance pay to establish Pro-Life Action League, where he could act on his own impulses without being curbed by anyone out of fear of potential lawsuits.

And lawsuits there were. Most famously, Scheidler became the accused in NOW v. Scheidler, 5 a class-action lawsuit filed in 1986 by the National Organization for Women and a large number of abortion providers, declaring that a multi-state activist network called the Pro-Life Action Network (PLAN), also founded by Scheidler, was conspiring with other anti-abortion activists and groups in a plot to close clinics through “racketeering.”

The racketeering charges never stuck, but Scheidler’s “Godfather” moniker did, and although it evokes the Mafia’s history of shady activities, he continues to claim it.

PLAN, according to Scheidler, was a coordinated effort to organize other anti-abortion groups from across the country who were willing to take direct, physical action against clinics. Scheidler writes in Chapter 68 of Closed, “Go National: Join the Activist Network,” that activists are encouraged to work in national networks to move from “random picketing and sidewalk counseling” to “blitzes of abortion clinics, picketing of doctors’ and clinic operators’ homes, vigils … a national day of rescue … and a national day of amnesty for the unborn, during which efforts would be made to close down as many abortion clinics across the country as possible.” PLAN’s national conventions occurred annually from 1984 to at least 1997, 6 and Scheidler credits the Atlanta conference in 1987 as being the birthplace of Randall Terry’s Operation Rescue.

Terry was just one of many anti-abortion activists who attended yearly PLAN conventions who would eventually go on to block clinics and harass patients and clinic workers, or worse. As part of PLAN, Scheidler introduced the idea of “regional directors” to coordinate their shared mission to end abortion. Starting with PLAN’s 1985 convention in Appleton, Wisconsin, he only welcomed attendees who espoused “militant” anti-abortion activism, according to James Risen and Judy L. Thomas’s book Wrath of Angels: The American Abortion War. 7

Some of those attendees and their close contacts would become the most notorious and often jailed activists of their time. John Ryan, the original “rescuer” of St. Louis, Missouri, attended the early conventions to explain his tactics in clinic blockading, and eventually formed Pro-Life Direct Action League. 8 Joan Andrews, the movement “martyr” who served years 9 in prison for criminal trespass at clinics in multiple states, 10 attended when she was not in jail. Don Treshman of Rescue America, 11 Andrew Burnett 12 of Advocates for Life Ministries of Portland, Oregon 13 and Chris Slattery,14 who was an Operation Rescue member in New York City before starting a chain of crisis pregnancy centers 15 there, all attended or spoke at the yearly gatherings.

Francis (Franky) Schaeffer, son of evangelical theologian Francis Schaeffer, was not just a PLAN convention speaker; he worked closely with Scheidler and wrote the foreword for the 1993 edition of Closed. In his foreword, Schaeffer praised Scheidler and his use of “direct action” against clinics, comparing him to Mother Theresa in Calcutta or Jesus driving the money changers from the temple. “We cannot wait for the ‘abortion problem’ to be solved for us,” he writes. “Street by street, neighborhood by neighborhood, we must fight this necessary battle until legalized abortion is relegated to the barbaric past, along with slavery and cannibalism!”

Franky Schaeffer has since renounced his role 16 in helping to forge the powerful alliance of Catholics and evangelicals in what is now the social conservative movement, citing his belief that the leaders were more interested in winning and retaining Republican majorities than ending legal abortion.

When members met in 1994, 17 it was to discuss how much violence is acceptable when it comes to stopping abortion and closing clinics. The battle lines were drawn at that Chicago meeting, as the coalition began to fray over whether it was ever justifiable to commit murder 18 to stop a doctor from performing abortions. While members of PLAN like Burnett in Oregon supported the idea of “Defensive Action,”19 Scheidler and others declined to do so.

Scheidler’s book has a chapter called “Violence: Why It Won’t Work,” in which he explains how violence against an abortion provider or building would make the movement look bad. Even so, he hedges: “We must point out for the sake of proper perspective, however, that no amount of damage to real estate can equal the violence of taking a single human life,” in this case referring to abortion.

He also frequently discusses, in both his writing and in-person remarks, about his continuing support for those who have used violence in the past. “We’ve had trouble with other pro-lifers,” Scheidler told me this summer when I met him in his office in Chicago.20 “We had those who went off the deep end, and then started shooting and bombing and all that stuff. We knew these people, and we had meetings with them. We even have met them after they get out of prison, and so on. They’re still pro-life. They just went too far.”

SHIFTING TACTICS AT THE CLINICS

For himself, however, Scheidler prefers the “direct action” tactics he enthusiastically embraced, such as “blitzes.” Clinics had great difficulty in fending off activists such as Scheidler, other PLAN members, and eventually Operation Rescue. During the 1980s and ’90s, clinic “blitzes,” “rescues,” and barricading became so common that eventually the federal government passed the federal Freedom of Access to Clinic Entrances (FACE) Act, ensuring that anti-abortion activists could no longer use “rescue” style tactics to keep clinics closed and patients from passing through the doors.

Ann Scheidler, Joe Scheidler’s wife, helps run PLAL’s office and organizational operations. Photo courtesy of Wendi Kent.

Ann Scheidler, Joe Scheidler’s wife, helps run PLAL’s office and organizational operations. Photo courtesy of Wendi Kent.

While FACE was a blow to PLAL, Scheidler’s manual still offered many other ways to shut down a clinic. Scheidler encouraged hospital pickets 21 for those facilities that either offered abortion care themselves or had doctors on staff that provided those services at unaffiliated clinics. He developed another chilling tactic called “adopting abortionists,” his term for sending cards to a provider or supporter’s home, calling them to try to talk, dropping off business cards at their offices, or, as he suggested in his book, even what many would call stalking.

In one chapter of Closed, Scheidler crows about an activist’s success in using “adoption” tactics:

He accompanied her on lobbying missions to Springfield, following her from one legislator’s office to another and all the time praying for her conversion. He attended her seminars and encouraged his friends to fill up the front rows at every lecture she gave. He challenged her to public debates, organized people to question her at her talks, sent her pro-life literature, and took every opportunity to try to get her to stop promoting abortion. He succeeded.

Decades later, Scheidler’s advice for establishing direct contact with those who perform or support abortion has been mostly discarded, but some of his ideas occasionally reappear. In 2013, Dr. Cheryl Chastine, a reproductive health and abortion provider at South Wind Women’s Center in Wichita, Kansas, received two pieces of mail to her home address, both sent from Pro-Life Action League. The first was a letter from Joe’s wife Ann, Pro-Life Action League’s Vice President, asking her to meet for a cup of coffee to discuss why Dr. Chastine performs abortions. Later, she received an invitation to the League’s Christmas party.

Both mailings came just months after PLAL systematically and methodically pressured 22 Dr. Chastine’s private practice into severing ties with her. PLAL’s tactics included protests, letters to other businesses sharing the space, and threats of more public actions against the building if their professional relationships continued.

Scheidler and PLAL helped design tactics such as pressuring providers, blocking clinics, so-called “sidewalk counseling,” and clinic pickets. But even more current anti-abortion tactics, like conducting public relations campaigns “exposing” Planned Parenthood, have roots in Scheidler’s work.

Scheidler and PLAL helped design tactics such as pressuring providers, blocking clinics, so-called “sidewalk counseling,” and clinic pickets. But even more current, popular anti-abortion tactics, like conducting public relations campaigns “exposing” Planned Parenthood, have roots in Scheidler’s work. As early as the 1980s, PLAL smeared Planned Parenthood as a “threat to children,” and claimed the organization had sinister aims in providing information about sexuality, pregnancy prevention, and “contraceptive drugs and devices.” PLAL also accused Planned Parenthood of potentially giving abortion referrals to young teens without the consent of parents.

Such talking points echo in current campaigns by Live Action,23 a youth-based anti-abortion and anti-birth control movement that primarily engages in hidden camera “gotcha” videos purporting to “expose” Planned Parenthood affiliates and other providers of reproductive health care services. Live Action has been a leader in efforts to pressure Congressional lawmakers into defunding the family planning agency and works with other anti-abortion conservative political organizations like Susan B. Anthony List,24 Students for Life,25 Americans United for Life,26 and others, including PLAL.

THOSE GRAPHIC FETUS IMAGES

Today, Scheidler’s organization may be more the base of the anti-abortion movement than the face of it, but when it does don its public face, it likes to use graphic imagery. PLAL still commits to “counseling” outside clinics in Chicago, as well as training “sidewalk counselors” at yearly national conventions, such as the one held in Minnesota, in 2013, or Alabama, in 2014.27 However, its most public events are the “Face the Truth” tours, which take place for one full week each year during the summer, as well as for one day each month during the spring and fall.

On a Face the Truth tour, members of PLAL place large, graphic images of fetal and embryonic remains along a street or public venue, ranging from abortion clinics to major sidewalks in downtown Chicago. The tours, which PLAL said it began in 2000, are similar to the Center for Bio-Ethical Reform’s (CBR) Genocide Awareness Project, which mounts graphic aborted-fetus displays on campuses and universities, or those of Created Equal, a newer Ohio campaign from Mark Harrington, formerly with CBR.

The goal of such projects, according to Eric Scheidler, Joe’s son and the current executive director of PLAL, is to make people recognize the realities of abortion. The tactic represents an escalation from the early days of picketing at abortion clinics, when Joe Scheidler and others tried to stop patients from entering the building by handing out pamphlets that would often contain similar images.

The images are of grisly post-abortion remains that Scheidler says are real. He often obtained the subjects himself. In Abandoned: The Untold Story of the Abortion Wars,28 author and anti-abortion activist Monica Migliorino Miller details how she and Scheidler, along with a few other activists in Chicago, would remove the remains from a dumpster behind a local clinic, after which Miller would take them home to photograph.29 Later, they would take the remains to churches and ask to hold burials, a ritual that has eventually led to the National Day of Remembrance for Abortion Victims.30

PLAL’S WIDENING SCOPE

For all its influence and reach, PLAL remains a rather lean operation. On its tax documents, it claims only about $1 million 31 in revenue in 2013, mostly from donors it chooses not to disclose, and less than $13,000 in sales from sidewalk counseling tools and other anti-abortion activism products.32 In the same year, PLAL spent about $450,000 on compensation, not including benefits, with over $200,000 of that going to Joe, his wife Ann, and their son Eric. The organization’s biggest expenses are printing, shipping, and postage (perhaps not surprising considering the leaflets, pamphlets, large graphic photos, and other materials PLAL uses in its events).

Considering PLAL’s activism that purposefully pushes the lines of legality, it is surprising that it reported a mere $15833 in legal expenses in 2013.

PLAL’s influence in today’s legal abortion battle landscape isn’t felt only in the U.S. PLAL has long been supportive 34 of Youth Defence, an Irish anti-abortion group that “has been criticized by politicians for adopting the militant tactics of American antichoice activists,” according to Allie Higgins of Catholics for a Free Choice,35 who also reports that Scheidler’s book is used as a handbook for activist tactics by the group. Eric Scheidler joined the group in Ireland 36 for an international pro-life youth event in 2010. This year, the international pro-life youth conference was held in California 37 with Youth Defence, PLAL, and others.

Speaking at this year’s event 38 was Bernadette Smyth of Northern Ireland’s Precious Life. Smyth, who appears to emulate Scheidler’s tactics in her own country, once dismissed criticism of Scheidler’s activities, stating, “Joseph is not guilty of anything but saving women and unborn babies from abortion.”39 In November of 2014,40 a judge found Smyth guilty of harassing the head of the Marie Stopes clinic in Belfast, Ireland.

SCHEIDLER’S LEGACY

Now, 30 years after Scheidler published the definitive handbook on how to close an abortion clinic, there are fewer than 800 abortion clinics left in the country. Those clinics that remain have become even more susceptible to harassment, financial pressure, frivolous lawsuits, medical complaints, and massive anti-abortion PR campaigns.

30 years after Scheidler published the definitive handbook  on how to close an abortion clinic, there are fewer than 800 abortion clinics left in the country. Those clinics that remain are still susceptible to harassment, financial pressure, frivolous lawsuits, medical complaints, and massive anti-abortion public relations campaigns. In other words, they remain susceptible to almost every tactic Joe Scheidler first outlined in 1985.

In other words, they remain susceptible to almost every tactic Joe Scheidler first outlined in 1985. The defensive stance of giving Kevlar vests to clinic providers and forming clinic defense teams has had little positive impact.

With the right to a legal, safe abortion increasingly in jeopardy, the need to proactively fight the evolving tactics of the anti-abortion movement is critical. In the 1980s and 1990s, the threat that Scheidler and his cohorts posed to legal abortion access led to a federal lawsuit that managed to distract and hold off the pro-life movement for more than a decade. That lawsuit also led to the drafting and passage of the FACE Act. Today, abortion rights supporters must consider how to take similar bold action to exploit weaknesses in the anti-abortion movement and stop it from continuing to cut off what legal access remains.

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Robin Marty is a freelance writer, speaker, and activist, and the author of Crow After Roe: How Women’s Health is the New “Separate But Equal” and How to Change That. Robin’s articles have appeared at Bitch Magazine, Rolling Stone, Ms. Magazine, Truthout, AlterNet, BlogHer, RH Reality Check, and Care2.org, and she has spoken at national trainings and conference for NOW, NARAL, the National Conference for Media Reform, and Netroots Nation.

Footnotes

1. See, for example: Janet Reitman, “The Stealth War on Abortion,” Rolling Stone, Jan. 15, 2014, http://www.rollingstone.com/politics/news/the-stealth-war-on-abortion-20140115.
2. Joseph M. Scheidler, Closed: 99 Ways to Stop Abortion (Charlotte: Tan Books, 1984).
3. Robin Marty, “Tracking License Plates at Abortion Clinics? It’s Not Just Happening in Texas,” Talking Points Memo, Aug. 18, 2014, http://talkingpointsmemo.com/cafe/tracking-license-plates-at-abortion-clinics-it-s-not-just-happening-in-texas.
4. Robin Marty, “Running the Gauntlet,” Politico, June 11, 2014, http://www.politico.com/magazine/story/2014/06/abortion-supreme-court-mccullen-v-coakley-107739.html#.VHyonWTF_38.
5. National Organization for Women, Inc. v. Scheidler, 510 U.S. 249 (S.C. 1994), No. 92-780.
6. “PLAN holds 1997 Convention in Milwaukee,” Life Advocate Nov./Dec., Vol. XII No. 9 (1997), http://www.lifeadvocate.org/11_97/nation.htm.
7. Judy Lundstrom Thomas, “Wrath of Angels Descends,” Interview with Anne Bower, The Body Politic, Vol. 7, No. 11, Dec. 1997, 17.
8. Josh Glasstetter, “Todd Akin Arrested on May 9, 1987 with Radical Anti-Abortion Group,” Right Wing Watch, Oct. 22, 2012, http://www.rightwingwatch.org/content/todd-akin-arrested-may-9-1987-radical-anti-abortion-group.
9. “Pro-Life Leader Joan Andrews Released from Prison,” The Forerunner, Nov. 1, 1988, http://www.forerunner.com/forerunner/X0446_Joan_Andrews_release.html.
10. Brian Caulfield, “Joan Andrews Bell Freed on Unsupervised Parole,” National Catholic Register, Apr. 5, 1998, http://www.ncregister.com/site/article/joan_andrews_bell_freed_on_unsupervised_parole.
11. William Booth, “Doctor Killed During Abortion Protest,” Washington Post, Mar. 11, 1993, http://www.washingtonpost.com/wp-srv/national/longterm/abortviolence/stories/gunn.htm.
12. “Advocates for Life Ministries to Close,” Ms., Nov. 29, 1999, http://www.msmagazine.com/news/uswirestory.asp?id=1195.
13. “Andrew Burnett Biography,” Life Advocate, http://www.lifeadvocate.org/bio/andrew/bioandrw.htm.
14. “250 Arrested at Jersey Anti-Abortion Protest,” New York Times, Sept. 18, 1988, http://www.nytimes.com/1988/09/18/nyregion/250-arrested-at-jersey-anti-abortion-protest.html.
15. Cynthia L. Cooper, “N.Y. Launches Probe of Crisis-Pregnancy Centers,” Women’s E-News, Jan. 31, 2002, http://womensenews.org/story/health/020131/ny-launches-probe-crisis-pregnancy-centers.
16. Frank Schaeffer, “How My Dad and I Helped Create the Tea Party GOP and Terrorist Extremism,” Patheos, Nov. 15, 2014, http://www.patheos.com/blogs/frankschaeffer/2014/11/how-my-dad-and-i-helped-create-the-tea-party-gop-and-terrorist-extremism.
17. Tamar Lewin, “Death of a Doctor: the Moral Debate–Abortion Doctor and Body Guard Slain in Florida; A Cause Worth Killing For? Debate Splits Abortion Foes,” New York Times, July 30, 1994, http://www.nytimes.com/1994/07/30/us/death-doctor-moral-debate-abortion-doctor-bodyguardslain-florida-cause-worth.html.
18. Joe Scheidler, “Paul Hill Executed,” Pro-Life Action League, Sept 5, 2003, http://prolifeaction.org/hotline/2003/30905.
19. Adam Guasch-Melendez, “Grand Jury Won’t Issue Indictment for Abortion Conspiracy,” The Public Eye, March 1996, http://www.publiceye.org/ifas/fw/9603/conspiracy.html.
20. Robin Marty, “On the Sidewalks of a Chicago Clinic: A battle about how to End Abortion,” Clinic Stories, http://www.clinicstories.com.
21. Andrew Fegelman and Jean Latz Griffin, “Public Funds’ Use Key to Abortion Fight,” Chicago Tribune, Dec. 16, 1992, http://articles.chicagotribune.com/1992-09-16/news/9203240474_1_anti-abortion-pro-life-action-league-cook-county-hospital.
22. Robin Marty, “Working As an Abortion Doctor in the Town Where Dr. Tiller Got Shot,” Think Progress, Feb. 7, 2014, http://thinkprogress.org/health/2014/02/07/3266341/cheryl-chastine-abortion-harassment.
23. “Live Action News,” http://liveactionnews.org/about.
24. “Top 12 Reasons to Defund Planned Parenthood Now,” Susan B. Anthony List, Apr. 8, 2011, http://www.sba-list.org/suzy-b-blog/top-12-reasons-defund-planned-parenthood-now.
25. “Live Action and Students for Life of America Release Winner of “Tell Congress” Video Contest,” Expose Planned Parenthood, Mar. 15, 2011, http://exposeplannedparenthood.net/newsroom/press-releases.
26. “Planned Parenthood Exposed Partners,” http://plannedparenthoodexposed.com/partners.
27. Anne Scheidler, “Scheidlers Headline at Fourth Annual National Sidewalk Counseling Symposium,” Pro-Life Action League, Aug. 15, 2014, http://prolifeaction.org/hotline/2014/nscs2014.
28. Monica Migliorino Miller, Abandoned: The Untold Story of the Abortion Wars (Charlotte: St. Benedict Press, 2012).
29. Priest For Life Image Collection, http://www.priestsforlife.org/resources/monica.
30. Robin Marty, “Let’s Get Visceral: Anti-abortion Activists Plan Memorial Services for Unborn Fetuses, Complete with Tiny Coffins,” In These Times, Sept. 13, 2013, http://inthesetimes.com/article/15615/lets_get_visceral.
31. Pro-Life Action League, Guide Star Report, p.2, http://www.guidestar.org/ViewPdf.aspx?PdfSource=0&ein=36-3081086.
32. “Pro-Life Action Store Products,” Pro-Life League, https://pro-life-action-league-store.myshopify.com/collections/all.
33. U.S. Department of the Treasury, Internal Revenue Service, Form 990, (Washington, DC: 2012), p.10, http://www.guidestar.org/FinDocuments/2013/363/081/2013-363081086-0a0988d5-9.pdf.
34. Angela Nagel, “Why American Pro-Life Dollars Are Pouring Into Ireland,” Atlantic, Jan. 9, 2013, http://www.filmyboxoffice.com/news/why-american-pro-life-dollars-are-pouring-into-ireland.html.
35. Allie Higgins, “Recruiting the Next Generation: How Conservative Groups Influence and Enlist Young People,” Catholics for a Free Choice, 2005, http://www.thefreelibrary.com/Recruiting+the+next+generation%3A+how+conservative+groups+influence+and…-a0136262288.
36. Eric Scheidler, “Eric Visits Ireland to Encourage Pro-Life Youth,” Pro-Life Action League, Nov. 12, 2010, http://prolifeaction.org/hotline/2010/vivalavida.
37. Kristina Garza, “Best Conference Yet,” Survivors of the Abortion Holocaust Blog, Nov. 12, 2014, http://www.survivors.la/blog/2014/11/12/best-conference-yet.
38. “Program Schedule,” Survivors of the Abortion Holocaust Blog, 2014, http://www.survivors.la/-program-schedule.
39. Anne Donald, “Guardian of the Right to Life,” The Herald Scotland, Nov. 19, 1999, http://www.heraldscotland.com/sport/spl/aberdeen/guardian-of-the-right-to-life-1.261598.
40. Henry McDonald, “Anti-Abortion Activist Found Guilty of Harassing Belfast Marie Stopes Boss,” Guardian, Nov. 19, 2014, http://www.theguardian.com/uk-news/2014/nov/19/abortion-activist-guilty-harassing-belfast-marie-stopes.