David Hagar, an OB/GYN physician and a graduate of evangelical Ashbury College in Kentucky, is famous as a man with a mission. Hager believes emergency contraception (EC) is abortion by any other name, and he refuses to administer it in his own practice, based on his religious beliefs. Like other pro-lifers, he maintains that EC terminates a pregnancy by preventing implantation of a fertilized egg despite the absence of any research that supports such a claim.
A Bush appointee to Food and Drug Administration (FDA) review committees, Hagar wrote a minority opinion in December 2003 that argued against making EC available over-the-counter, arguing that access to the drug would encourage teens to have sex. And as the media has repeatedly reported, his opinion mysteriously influenced the agency’s decision to block over-the-counter access to EC, even though the committee’s experts voted 23 to 4 in favor of access.
Hagar appears to see himself as a mere vehicle for divine intervention. “God took that information,” he reported in a speech at his alma mater, “and He used it through this minority report to influence the decision.”2
But it was politics not divinity that blocked FDA approval. The Southern Baptist Convention, Concerned Women for America, and the Family Research Council were busy lobbying the agency and Congress about EC, and some FDA officials revealed that the agency decided not to approve the drug for over-the-counter use long before the its own staff finished reviewing the application.3 The Right’s victory spurred the resignations of at least two government physicians: Susan Wood, the head of the FDA’s Office of Women’s Health and Frank Davidoff, a consultant to the drug approval process.
Hagar’s role made visible the quasi-scientific industry that peddles faux research about the harmful effects of abortion to a willing audience of the Christian Right and Bush Administration. Although legitimate researchers consistently refute their scientific “evidence,” B.A.D. or “Biased, Agenda-Driven” science, as junk science is more accurately called, retains its power and contributes to the organizing might of a movement determined to make abortion — and premarital sex and condom use — somehow disappear. Abortion’s link to breast cancer and depression are two of the more influential claims of B.A.D. scientists.
“The anti-abortion movement says there is an association between abortion and negative things but never determines an underlying cause because none is plausible,” says Kelly B. Blanchard, president of Ibis Reproductive Health, a research center based in Cambridge, MA. “It may be true that women with less education and less money are more likely to have abortions and it might be true that women with less education and less money are more likely to be depressed. But the depression may have nothing to do with the abortion,” she explains, in response to the overly general B.A.D. claim that abortion causes depression.
The Bush Administration is a master at exploiting such B.A.D science. In the past, it was largely oil, drug, and other corporate giants deploying junk science to head off regulation that could interfere with their profits. Their allies — carefully placed in agencies and on advisory committees — have worked under the radar to alter public policy using industry generated “data.” The Center for Science in the Public Interest has a program dedicated solely to scrutinizing such industry-influenced science and promoting disclosure of conflict of interest when scientists publish in journals, are quoted in the press, or testify before legislative or regulatory agencies.
“Science is not a pure endeavor,” says Merrill Goozner, director of the project. “You can hire scientists to manipulate protocols of studies, if they had a mind to, so that companies can get the results they are looking for. Or, if the scientists get different results than the desired ones, they can make sure the report never sees the light of day.” In deploying B.A.D. science to change policy, the Christian Right merely borrows a tactic perfected by these other power brokers.
How It’s Done
Creating B.A.D. science is simple. In the anti-abortion movement, a handful of scientists with conservative political agendas first publish articles, studies and commentaries in scientific journals, generating scientific “knowledge” about the dangers of abortion with unsubstantiated claims using problematic approaches.
In the 1980s, they tagged onto a scientific debate about abortion and breast cancer that appeared in the journals beginning in the 1950s.4 By repeatedly making the same claims in a variety of publications, they create the appearance of a body of scholarship that can be used to support a political goal of presenting apparently legitimate scientific evidence to influence the abortion debate. Then B.A.D. scientists create their own advocacy groups which in turn inspire new grassroots organizations with an agenda based on the scientists’ claims. Newcomers join online or at the local level, and a movement with serious policy influence is born.
This tactical trajectory mimics the path of researchers who generate their own studies to support a reproductive rights agenda. The Alan Guttmacher Institute, for instance, has generated research on reproductive and sexual health since 1968 by publishing in its own journals, supporting the activist work of many reproductive rights advocacy groups. However, these journals are refereed, meaning the articles are vetted by other scientists.
But the most important issue to consider about researchers on both sides of this polarized issue is not that scientists may have agendas. It is that the quality of the science produced by B.A.D. scientists is unmistakably shoddy. In the case of antiabortion B.A.D. scientists, their strongly held Christian Rightist beliefs have interfered with their ability to practice reputable science. Despite this deficiency, and despite vehement challenges by mainstream researchers, the “knowledge” that abortion harms women has successfully become part of the vocabulary of antiabortion activists.
Abortion Breast-Cancer Syndrome
The most prominent advocate of the position that abortion is linked to breast cancer is a good example of an agenda-driven scientist. Joel Brind, a Baruch College professor, identifies his conversion from Judaism to Christianity as the turning point in his career which until that time had been focused on general endocrinology. After his conversion experience, he joined the National Right to Life Committee.5 “With a new belief in a meaningful universe, I felt compelled to use science for its noblest, life-saving purpose,” he wrote in a magazine published for a medical audience by the Christian Right group Focus on the Family.6
By entering into the Christian Right’s anti-abortion philosophy, Brind embraced religious beliefs rooted in Catholicism, Calvinism, and the modern Evangelical movement. This theology identifies abortion as a sin, because it is the willful murder of a person; but it can be forgiven by the grace of God. To warn against sin and to forgive transgressions are two hallmarks of Christian thought, and they translate into simultaneously condemning and showing apparent compassion for women who have had abortions. While the Christian Right is committed to opposing abortion, its anti-abortion campaign has the added value of bolstering the power of politicians who also find raising the topic beneficial.
To come to his conclusion linking breast cancer and abortions, Brind undertook an epidemiological study measuring the level of risk for contracting disease across groups of people. Although not an epidemiologist himself, Brind reviewed existing studies on abortion and breast cancer, which as a collection were inconsistent. To mainstream scientists, this suggests there is no relationship. According to Phyllis Wingo, chief of the cancer surveillance branch for the Center for Disease Control, “In epidemiology, if there’s a true relationship, you’d expect to find the majority of studies would show some consistency.”7
While Brind does not conduct basic research himself, he reviews data collected and analyzed by others, while adding his own analysis. With the help of co-authors, he reviewed the studies statistically and concluded there was a relative risk of 1.3 on a scale where 1.0 means no risk of breast cancer and 2.0 means demonstrated risk. Even though 1.3 is too low to show risk by generally accepted standards, Brind felt this justified his hunch, and he published the results, claiming that having an abortion puts a woman at risk for breast cancer.8 In his mind, this evidence would some day prevent women from making the wrong choice, either through deterrence or by legal prohibition.
Within months, Danish authors issued a better study that refuted his conclusions, at least to most of the scientific community.9 By 2003, the National Cancer Institute concluded that, “Having an abortion or miscarriage does not increase a woman’s subsequent risk of developing breast cancer.”10 But Brind’s prior belief in the link was fervent, and he energetically brought his message beyond the world of scientific journals by placing no less than nine popular articles in The National Right to Life News.11
In an additional review of studies published since 1996, Brind displays his uncompromising tone in criticizing what he sees as their methodological flaws:
It is only reasonable to conclude, from all extant evidence, that induced abortion is indeed a risk factor for breast cancer, despite the strong and pervasive bias in the recent literature in the direction of viewing abortion as safe for women… It is deplorable that in an era in which women’s rights appear so prominently on the political and public health landscape, women should be denied the right to know about the breast cancer risk-increasing effect of such a common matter of choice as induced abortion.12
For over 20 years Brind has waged his campaign to make the abortion-breast cancer link (ABC) common knowledge with an approach he calls “woman-centered.” He has written letters to medical journals, contributed to nonscientific publications such as National Review and testified in many courtrooms and statehouses. He appeared before a Pennsylvania court in support of a billboard campaign by one of the advocacy groups he has nurtured that wanted to broadcast the message of the abortion/breast cancer link; in his testimony before state legislatures from Alaska to Massachusetts, he called for laws requiring clinics to warn women of the risks of abortion. He founded the Breast Cancer Prevention Institute and his name has become a household word among antiabortion advocates in groups like the National Right to Life Committee, the Coalition on Abortion/Breast Cancer, and Christ’s Bride Ministries.
If increased restrictions on abortion access are any indication, the results of his campaign are impressive. By 2005, lawmakers in every state legislature in the country have filed bills that either require women to receive biased counseling about the risks of abortion or impose mandatory waiting periods. Thirty-one legislatures have passed such laws, which state courts in seven states have found unconstitutional.13
Uncertainty is built into scientific inquiry, but Brind is very certain he is right. Polly Newcomb, a cancer researcher has said, “Circumspection, unfortunately, is what you have to do to practice epidemiology. That’s something Brind is incapable of doing. He has such a strong belief in the association that he just can’t evaluate the data critically.”14
David Reardon, founder of the antiabortion Elliot Institute in Springfield, Illinois, joins Brind in analyzing impressively complex statistics to support his antiabortion stance. Reardon has been the most outspoken advocate of “post-abortion syndrome,” or PAS, the idea that women who have abortions suffer socially, psychologically, and physically from their after effects.
Beginning in 1987, he has written seven books for a general audience and dozens of scientific articles in both agenda-driven and more reputable publications claiming that abortion is linked to higher rates of mental illness, traumatic stress, and death. He says he hopes that exposing the prevalence of PAS will convince the courts to reverse Roe v. Wade because the case was decided in part on medical facts known at the time of the decision — that a first trimester abortion does not pose a health risk. “A demonstration that key factual assumptions in Roe were actually false might justify a complete repudiation of Roe,” he wrote.15
Trained as an electrical engineer, Rear-don decided to pursue further education in biomedical ethics, receiving a doctorate in 1995 from Pacific Western University. Reardon apparently hoped that he would gain credibility in the field he saw as hostile to his work — even though Pacific Western is an on-line, unaccredited institution. “I was advised by several university professors that I would face tremendous obsta-cles in pursuing my research interests at most of the large universities where cultural biases against any researcher who dares to question ‘the sacred right to abortion’ would provoke hostility, harassment, and obstruction,” Reardon explained.16
Rather than trying to enter academia, he founded the Elliot Institute which specializes in generating papers on PAS and advocating compassion for women who are “abortion survivors.” His also calls his approach “woman-centered.” Other organizations now champion the cause of post-abortion syndrome, including the Catholic Project Rachel, the Evangelical Operation Outcry, and Christian “crisis pregnancy centers” affiliated with networks like Heartbeat International and Carenet that offer post-abortion counseling.
Reardon often is at odds with the peer review process in scientific publishing that is designed to maintain standards and further the discovery of scientific truth. The process involves a sometimes lengthy give-and-take between authors and reviewers before a study or article is accepted for publication. Then subsequent review, commentary, and new research add to a shared understanding of the topic at hand. While not perfect, peer review depends on the scrupulous critique of fellow researchers, especially ones in the same field.
Like Brind, Reardon places similar material in different journals, referring back on his own previous articles or even letters to the editor, generating the conversation almost single-handedly. Most scientists are not convinced, describing his work as marred by unwarranted claims and methodological shortcomings.
In a 2004 letter to the editors of the Journal of Anxiety Disorders, two researchers critiqued a paper by Reardon and his associates Phyllis Coleman and Jesse Cougle. “We believe that Cougle, et al., operate with strong political views regarding abortion, and unfortunately their biases appear to have resulted in serious methodological flaws in the analysis published in your journal,” they wrote. Of Reardon and his colleagues they added: “All are involved in building a literature to be used in efforts to restrict access to abortion.”17
Anti-abortion advocates produce data they insist are persuasive. They are aided in their beliefs by the structure of science itself. For instance, it is impossible to design an ethically acceptable study that shows definitively there is no harm. Researchers would have to prove the “null hypothesis” — that something cannot happen — a notoriously tough challenge.
B.A.D. have taken advantage of this lack of definitiveness and jumped into the opening, filling the gap with their own conclusions.
Yet B.A.D. scientists ignore a vital caution in statistics that demands researchers to show a link between two trends, say breast cancer and abortion. Merely showing that two trends exist parallel to one another does not prove they are related. Researchers need to take the next step and identify the data that demonstrates the causal link. The methodological problems of B.A.D. science go beyond this fallacy. In the parlance of basic statistics courses, they don’t “control” for other things that might influence their results, like economic, social, or psychological factors. They set up faulty “apples and oranges” comparison groups such as comparing the mental health of women who give birth to those who have abortions, instead of looking at women who had abortions and comparing them to those who, through lack of access, carry unwanted pregnancies to term. They also overlook problems with self-reporting of stigmatized events like abortions and ignore studies that refute their claims.
Although professional epidemiologists may succumb to such mistakes, the peer review process usually points these shortcomings out, and further work in the area benefits from their scrutiny. B.A.D. scientists take advantage of this drawn out process to move the debate into public view before they are discredited by scientists.
At times, Reardon and his co-authors acknowledge the limitations of some of his data, visible in one paper suggesting a link between previous abortion and substance use during pregnancy.
“All of the above interpretations [substance use using pregnancy is the result of grief, remorse and depression over a past abortion] are speculative at this point.”
“The data were derived through the exclusive use of self-reported interview data, and subsequent research should incorporate information derived from other sources of information.”
“The generalizability of the findings is necessarily limited,” and “The limitations of the design preclude causal assumptions.”18
Still, Reardon insists that his analysis demonstrates that abortion is harmful to women. He spends a good deal of time refuting his critics in the journals, responding to criticisms of his work and challenging the results of others, which on one level looks as if he were following the protocol of peer review. Nevertheless, many scientists continue to dismiss his work as biased and agenda driven.19 But in propelling the debate off the pages of scholarly publications into a more receptive public forums by public speaking and popular writing directed at anti-abortion audiences, he in some ways makes the failure to pass peer review irrelevant.
Scientific inquiry is a highly specialized form of scholarship, and only a very few are trained in the rigor of the scientific method as it is practiced with today’s standards. Many of us cannot follow the arguments raised and countered by B.A.D. scientists and their critics, and we rely on others to explain what is going on. Most scientific writing is highly technical, with its own vocabulary, tone, and style, and it is not intended for a general audience.
The inaccessibility of much scientific writing has several effects. It reinforces the notion that its content is too difficult for the average person to grasp. While it increases the value of science and the stature of scientists in our culture, the necessary posture of uncertainty renders the process vulnerable to papers that appear to challenge that uncertainty but which embody bias. This has become highly problematic for the cause of abortion access.
Mainstream media coverage of Reardon and Brind’s contentious claims often describe them as part of legitimate scientific debate. The general public then harbors some vague awareness of a possible controversy. Critics of B.A.D. science are irritated that their scholarly arguments have little influence in the court of public opinion. Reproductive rights advocates become incensed that logic and science have not served them well. And the anti-abortion audience eagerly accepts what they see as proof to reinforce their beliefs that abortion must be stopped. Through the positioning of ideological beliefs as supported by what appears to be scholarly research, B.A.D. science can be uncannily effective. Arkansas, Nevada, and Wisconsin all require pre-abortion counseling about abortion’s psychological effects, and South Dakota’s counseling law was overruled in court.20
Anti-abortion advocates like Brind and Reardon, ones who wear the lab coats but not the respect of scientists, have not been deterred by the response of the scientific community. Even though a panel at the National Cancer Institute has concluded, “Induced abortion is not associated with an increase in breast cancer risk,”21 and the American Psychiatric Association does not recognize PAS as a legitimate syndrome, such high status pronouncements are irrelevant to the followers of B.A.D. scientists. The success of their performances relies on volume before a general audience, not on the fidelity of their technical merits.
In the eyes of many anti-abortion followers, challenges to their spokespeople’s credentials and professionalism are beside the point. Those who count, the grassroots voters, financial supporters and government officials of the movement, may value this work more for its zeal and impact than for its legitimacy, especially if it can further the anti-abortion cause. Eventually B.A.D. scientists will be repudiated in the public sphere, not just in the halls of science, but meanwhile their voices carry a lot of weight. These men (and some women, see sidebar) can readily be cast as crusaders in a righteous war, one their supporters are convinced they will win. The reluctance of many to engage in dialogue with B.A.D. scientists has only served to allow their biased claims to be broadcast without interference. “There has never been a debate on the ABC link,” claims the Coalition on Abortion/Breast Cancer, “because our opponents know they would lose.”22
B.A.D. science seems to invite sarcasm among its critics, which is both under-standable and unfortunate. The agenda-driven quality of their scholarship coupled with their sometimes nontraditional resumes may seem laughable or infuriating to some. But to dismiss these advocates as cynics or dispassionate tacticians who crassly manipulate unthinking anti-abortion masses would be a mistake. It might be better to see them as efficient cogs in the machinery that drives the current movement to limit women’s reproductive health and freedom.
Joel Brind, Ph.D.
In his off-work time from teaching general biology and endocrinology at Baruch College in New York, Brind has focused on showing that having an abortion increases a women’s risk of getting breast cancer.
Jesse Cougle, M.Sc.
Cougle, a co-author with Rear-don and Coleman on nine published papers, has been a clinical psychology doctoral student at University of Texas at Austin since 2001 in the Laboratory for the Study of Anxiety Disorders.
Priscilla Coleman, Ph.D.
A frequent coauthor with David Reardon, Coleman lists “postabortion emotional sequelae” on her list of interests in her vita for Bowling Green University, where she is Assistant Professor in the School of Family and Consumer Sciences.
Philip G. Ney, M.D.
Ney is a child and family psychiatrist Victoria, British Columbia. His early work on the connection between abortion and child abuse has been quoted in the Pro-Life Encyclopedia and regularly cited by other B.A.D. researchers.
David Reardon, Ph.D.
Author of numerous books on PAS, Reardon founded the Elliot Institute in Springfield, Illinois, to oppose abortion by demonstrating that it is harmful to women.
Vincent Rue, Ph.D.
The founder of the now-inactive Institute for Pregnancy Loss, Rue has written about PAS with Anne Speckhard. His 1987 paper cowritten with Speckhard and Wanda Franz, the head of the National Right to Life Committee, was presented to Congress as a white paper in 1987. He has made a living as an independent consultant and expert witness for anti-abortion issues.
Anne Speckhard, Ph.D.
A scholar of psychological trauma, Speckhard wrote an article in the Journal of Social Issues in 1992 that defined PAS as a form of post-traumatic stress disorder. She has also done studies interviewing Russian women who have had abortions, finding a high percentage (80%) of her interviewees had PAS.
Corporate Junk Science
Junk Science runs rampant in the Bush Administration. Merrill Goozner, director of the Integrity in Science project of the Center for Science in the Public Interest tracks the problem. First, the 200-plus science-based advisory committees that support such federal entities as the Environmental Protection Agency, Food and Drug Administration and Occupational Safety and Health Administration are being stacked with people Goozman dubs pro-corporate “scientists for hire.” This means that people with overt conflicts of interest are being allowed to foment public policy, potentially undermining our health and safety.
Take hexavalent chromium as an example. When the chemical’s safety was being evaluated in New Jersey, pro-industry Environmental Toxicologist Dennis Paustenbach, a man described by the Star Ledger as someone who “rarely met a chemical he didn’t like,” was called in as an expert. Although OSHA once classified hexavalent chromium as a “potential lung carcinogen” and warned users that exposure could cause permanent eye damage and irritation to the nose, throat and lungs, Paustenbach told a state EPA panel that the chemical poses no risk to human health.
As a result, by 2004 the New Jersey EPA had relaxed its limits on the toxin, from 10 parts per million in soil to 6100 parts per million. In addition, the chemical companies were able to walk away from numerous polluted sites without doing any clean-up whatsoever.
While this is a particular heinous example, Goozner says that similar scenarios are becoming increasingly common. “It comes up all the time in medicine, too. A drug company goes to the FDA to get approval for a new drug. The drug company funds a trial to prove that the drug is safe and effective and it then goes before an FDA advisory committee. What they don’t disclose is that some of the specialists on the committees are in the pay of the companies whose products are being evaluated or are working for their competitors. In the last two years alone there have been several dozen examples of these types of conflicts of interest.”
Three of the nine members of an FDA panel currently evaluating an insulin inhaler for use by Type I diabetics have direct ties to either Pfizer Pharmaceuticals or its technological partner, NEKTAR Therapeutics. The Cox-2 inhibitor scandal in 2004, in which the FDA pulled the anti-inflammatory drugs Bextra, Celebrex and Vioxx from the shelves after first overlooking evidence of cardiovascular risk, seems to have had little impact on the agency or the drug masters that fill electoral coffers.
The distortion of drug research goes beyond the FDA. Goozner cites the National Academy of Sciences, a supposedly independent body that provides data to a host of federal agencies, as an offender. “Very often the people on evaluation panels have consulting jobs with the companies they are going to evaluate. When they are reviewing something like the level of pollution we should tolerate, the health and safety of the American people is put at risk.” One example: the National Academy of Sciences was told to study the safety of mercury levels in fish and one of the panelists was discovered to have previously worked for the fish industry. Although the exact extent of his influence is unclear, warnings on albacore tuna now tell pregnant women to reduce their intake of the mercury-containing fish to 12 ounces per week. Prior to 2001, pregnant consumers were told to avoid tuna completely.
— Eleanor J. Bader
1. Conard LAE, Gold MA, “Emergency Contraceptive Pills: a Review of the Recent Literature,” Current Opinion in Obstetrics & Gynecology 2004; 16:389-395.
2. Ayelish McGarvey, “Dr. Hagar’s Family Values,” The Nation, May 30, 2005, http://www.thenation .com/doc/20050530/mcgarvey, at April 26, 2006.
3. Brian Alexander, “Whose Body is it, Anyway?” Glamour, May 2006, 298. “Government Accountability Office, “Report to Congressional Requesters: Decision Process to Deny Initial Over-The Counter Marketing of the Emergency Contraceptive Drug Plan B Was Unusual,”, GAO06-109 (Washington, D.C.:U.S. GAO, November, 2005) 21.
4. See Patricia Jasen, “Breast Cancer and the Politics of Abortion in the United States,” Medical History, 2005, 49: 42344, at 425.
6. Brind quoted in Chris Mooney, “Research and Destroy: How the Religious Right Promotes its Own “Experts” to Combat Mainstream Science,” Washington Monthly, October 2004, 34.
7. Barry Yeoman, “The Scientists Who Hated Abortion,” Discover, February 2003. At http://www.discover. com/issues/feb-03/features/feathated/April 19, 2006.
8. Joel Brind et al., “Induced Abortion as an Independent Risk Factor for Breast Cancer: A Comprehensive Review and Meta-analysis,” Journal of Epidemiology and Community Health, 1996, 50:481-96.
9. Mads Melbye, “Induced Abortion and the Risk of Breast Cancer,” New England Journal of Medicine, 9 January 1997, 336:81-85.
10. National Cancer Institute Fact Sheet, “Abortion, Miscarriage, and Breast Cancer,” March 21, 2003, at http://cancer.gov/cancertopics/factsheet/Risk/abortionmiscarriage, at May 2, 2006.
11. http://www.baruch.cuny.edu/wsas/departments/natural_science/faculty/brind.html , at April 24, 2006.
12. Joel Brind, “Induced Abortion as an Independent Risk Factor for Breast Cancer: A Critical Review of Recent Studies Based on Prospective Data,” Journal of American Physicians and Surgeons, Vol 10, No. 4, Winter 2005, 109.
13. “Nationwide Trends: Biased Counseling and Mandatory Delay,” NARAL Pro-Choice America, at http://www.prochoiceamerica.org/choice-action-center/ in_your_state/who-decides/nationwide-trends/ biased_counseling.html , April 19, 2006.
14. Barry Yeoman, “The Scientist Who Hated Abortion and Did Something About it,” Discover, February 2003, 24: 54-9, republished at http://www.barryyeoman.com/articles/hatedabortion.html at April 19, 2006.
15. David C. Reardon, T.W. Strahan, J.M. Thorp, and M.W. Shuping, “Deaths Associated with Abortion Compared to Childbirth — A Review of New and Old Data and the Medical and Legal Implications,” Journal of Contemporary Health Law and Policy, 2003-2004; 280(20); 283.
16. David Reardon in June 8, 2005 email correspondence with Noel Diamond at http://www.noahdiamond .com/reardon.html.
17. Correspondence between Jillian Henderson and Katharine Miller and journal editors Michel Hersen and Cynthia Last, January 13, 2004 on file at PRA.
18. Priscilla K. Coleman, David C. Reardon, Jesse R. Cougle, “Substance Use Among Pregnant Women in the Context of Previow Reproductive Loss and Desire for Current Pregnancy,” British Journal of health Psychology, (2005), 10, 264, 265.
19. See for instance, Brenda Major, “Psychological Implications of Abortion — Highly Charged and Rife with Misleading Research,” Canadian Medical Association Journal, May 13, 2003; 168 (10) 1257-1258.
20. “Nationwide Trends: Biased Counseling and Mandatory Delay,” NARAL Pro-Choice America, at http://www.prochoiceamerica.org/choice-action-center/ in_your_state/who-decides/nationwide-trends/ biased_counseling.html , April 19, 2006.
21. http://www.cancer.gov/cancerinfo/ere-workshop-report, at April 24, 2006.
22. Press Release, Coalition on Abortion/Breast Cancer, “Glamour Magazine Challenged to a Debate on Abortion-Cancer Link,” April 20, 2006, at http://www.abortionbreastcancer.com/start/ on April 24, 2006.