Donald Trump’s Pro-Life Achievements (2016-2020)

“For the first time since Roe v. Wade, America has a Pro-Life President, a Pro-Life Vice President, a Pro-Life House of Representatives and 25 Pro-Life Republican State Capitals!”[1]

By Lauren Moustakas, Student at Regent University School of Law (Virginia Beach, VA) and intern at the ECLJ.

Since his election to the executive office, President Trump and his administration have taken consistent action to promote the pro-life movement and protect the sanctity of life. In 2020 President Trump became the first sitting President to address the annual March for Life in person[2] and was also the first sitting President to address the March for Life live through satellite in 2018.[3] These actions alone have earned him the label of “Making History in Condemning Abortion” from abortion providers and advocates of  such as Planned Parenthood.[4] Further, he “made history” by being the first President in United States history to “single out” Planned Parenthood for defunding on the first page of his 2018 budget.[5] President Trump has asked Congress to pass legislation to end late term abortions, reinstated and expanded policies prohibiting international aid from funding oversees abortions, and has issued a ruling reforming Title X family planning funds preventing them from funding entities that provide abortions.[6] Since being elected and sworn in as President of the United States, President Trump’s administration has consistently supported policies that promote and protect life over abortion in the United States as well as internationally.

Foreign Policies

Internationally, President Trump’s administration has protected and promoted human dignity through policies that are pro-life. Such actions include joining twenty-four countries in joint statements before the United Nations General Assembly and other international bodies stating that there is no international right to abortion; efforts to form a coalition to oppose international energies to include “right to abortion” language in international documents; reinstating and expanding the “Mexico City Policy”; and ending U.S. funding to the United Nations Population Fund.[7]

Protecting Life in Global Health Assistance Policy – Formerly the Mexico City Policy

After taking office, President Trump reinstated the Mexico City Policy, which prevents approximately $9 billion of foreign aid from being used to fund abortions internationally.[8] Renamed the “Protecting Life in Global Health Assistance” Policy by the Trump administration, this policy prevents U.S. foreign aid granted to providing health services from being used to provide or promote abortions as a form of family planning.[9] This policy was originally put in place by President Reagan’s administration in 1984, named for Mexico City - the venue of the United Nations International Conference on Population and Development where the policy was announced, and has been either rescinded or reinstated since then depending on the policies of the current President.[10] President Trump’s reinstatement is notable as it also expanded the restriction on U.S. foreign aid being used to promote abortion. Previously, aid was restricted by the policy from being used by recipient NGO’s to promote or perform abortions, but under the Trump administration’s reinstatement foreign NGO’s are now also required to agree to not use any source of funding, including non U.S. funds, for promoting or providing abortions in order to receive any U.S. family planning aid.[11] Prohibited activities under the reinstatement by President Trump also includes providing advice and information about abortion, offering a referral for abortion, lobbying and promoting changes in abortion policy, and conducting campaigns about abortion as a valid form of family planning.[12] Additionally, while United States NGOs are not directly required to adhere to the Mexico City Policy, they do have to agree to ensure that any funds they provide to a foreign NGO recipient of aid is not disqualified under the Mexico City Policy.[13]

Additionally, President Trump’s reinstatement has expanded the scope of health aid that the Mexico City Policy applies to. Previously, the policy covered U.S. aid that went to family planning assistance through the U.S. Agency for International Development (USAID) and family planning assistance through the U.S. Department of State.[14] President Trump’s reinstatement applies to most U.S global health assistance that is provided by agencies and departments including funds designated for family planning and reproductive health, maternal and child health, nutrition, HIV, tuberculosis, malaria, and global health security.[15] Agencies that are subject to the Mexico City Policy in the distribution of aid include USAID, the Department of State, and the Department of Defense.[16]

An assessment of these policies by the U.S. Government Accountability Office found that since the reinstatement of the Mexico City Policy with the additional restrictions, 54 NGO’s had rejected the policy which resulted in an estimated $150 million less in funding.[17] Additionally, the policy had applied to an estimated 1,300 health projects globally.[18]

United States Funding for the United Nations Population Fund

One of President Trump’s first acts in Office was to support the State Department’s ending of U.S. funding for the United Nations Population Fund (UNFPA).[19] Funding for the U.N. Population Fund was ended by the Trump administration because the Fund “supports, or participates in the management of, a program of coercive abortion or involuntary sterilization.”[20] The Trump Administration has continued to withhold funding from UNFPA, and most recently on June 16, 2020 the Administration withheld an estimated $32.5 million in support under the Kemp-Kasten amendment.[21]

Enacted by Congress in 1985, the Kemp-Kasten amendment prohibits United States funds from being given to an organization or program that supports or participates in a program of coercive abortion or involuntary sterilization.[22] The determination of whether a program meets this requirement is made by the President of the United States.[23] While funding for UNFPA has been withheld under Kemp-Kasten by previous administrations, it is up to the policies and perspective of each President to choose to do so.[24] As in the Mexico City Policy, since it’s enactment, all Presidents, except President Clinton and President Obama, have determined that UNFPA is not eligible to receive funding under Kemp-Kasten.[25] Under the Clinton and Obama administrations yearly funds granted to UNFPA ranged from $15 million to $51 million.[26]

According to Planned Parenthood, President Trump’s decision to not fund UNFPA, “hurts UNFPA’s ability to promote reproductive health; respond to humanitarian crisis; and prevent unplanned pregnancies, unsafe abortions, and maternal deaths in some of the world’s most vulnerable areas.”[27] This reaction from Planned Parenthood appears to confirm that the United States funding of UNFPA would fund worldwide abortions and affirms that President Trump’s decision to not fund UNFPA is a step in the right direction for the protection of life worldwide.

United States Policies

Since being elected to office, President Trump has enacted pro-life policies. Appointed two Supreme Court Justices, and nearly two hundred Federal Judges -  all of which have made an impact for the protection of human dignity in the United States.

Conscientious Objection

California Universal Abortion Mandate

In January 2020, a Notice of Violation was issued from the Office for Civil Rights (OCR) and the U.S. Department of Health and Human Services (HHS) to the State of California regarding California’s universal abortion coverage mandate.[28] This mandate had required that abortion coverage be included in all insurance plans offered in the state of California which violated federal conscience laws.[29] The  director of OCR stated, “No one in America should be forced to pay for or cover other people’s abortions….We are putting California on notice that it must stop forcing people of good will to subsidize the taking of human life, not only because it is the moral thing to do, but because it is the law.”[30]

Standing up for Pro-Life Pregnancy Resource Centers

In another dispute involving the state of California, in 2019 the OCR notified the state that its law that required pro-life pregnancy centers to provide information on abortions to clients was in violation of federal law.[31] Under the California law, pro-life pregnancy centers were required to post information about abortion in their facilities and provide further information to clients regarding abortion. The State was notified that it was in violation of the Weldon and Coats-Snowe Amendment, which was the first time a state had been found in violation of this Amendment.[32] The Weldon and Coats-Snowe Amendments prevents particular federal funds from going to agency, programs, or local government if they discriminate against a health care entity because that entity does not provide, pay for, cover, or refer clients for abortions.[33] Additionally, in 2018 the United States Supreme Court had found that California’s act, known as the FACT Act, violated pro-life pregnancy resource centers First Amendment Rights by compelling them to speak.[34] Of note, Justice Gorsuch who was nominated by President Trump to the Supreme Court, joined the majority opinion against the state of California.[35]

New Division to Protect Conscience and Religious Freedom

In 2018, under President Trump’s administration, the OCR created a new Conscience and Religious Freedom Division in order to ensure compliance with the enforcement of laws that protects the free exercise of religion and conscientious objection in healthcare.[36] The Conscience and Religious Freedom Division’s purpose is to enforce existing federal law that protects the rights of conscience and religious freedom.[37]

Healthcare Worker’s Conscience Rights

In May of 2019, the Trump administration issued a rule that gave health care workers who conscientiously opposed providing “services” such as abortion, sterilization, or assisted suicide in the course of their work the ability to hold fast to their conscientious objections. This policy allowed both religious and non-religious conscientious objectors the ability to honor their convictions without losing their job or ability to work in the medical field.[38] Specifically, the Director of the HHS Office for Civil Rights stated that the rule “ensures that healthcare entities and professionals won’t be bullied out of the health care field because they decline to participate in the actions that violate their conscience, including the statement of human life.”[39] However, before the rule was scheduled to go into effect, the rule was vacated in its entirety by a New York Federal Judge.[40] Two additional Federal District Judges, one in California and another in Washington state, also vacated the regulation.[41]

Reversing the Redefining of Sex Discrimination under the Affordable Care Act

When enacted, the Affordable Care Act (ACA), also referred to as Obamacare, included in section 1557 of the act a provision prohibiting discrimination on the basis of sex.[42] The issue with the provision however, is that it defined on discrimination “on the basis of sex” was written to include “termination of a pregnancy” expanding the meaning of sex discrimination to include discrimination against individuals who have had an abortion.[43] On June 12, 2020 the Office for Civil Rights of the Department of Health and Human Services issued a final rule that revises the interpretation of this section of the ACA, primarily redefining the meaning of “on the basis of sex” to mean discrimination based on the biological sex of the individual, and nothing more.[44] While this may not seem directly linked to pro-life activity, it is interesting to note that Planned Parenthood has decried this action as scaling back protection for groups such as women who have had an abortion or will have an abortion in the future.[45] With the Supreme Court’s recent decision in Bostock v. Clayton County it will be interesting to see if this change in definition of “on the basis of sex” will be upheld when it is challenged, as it likely will be.[46]

Defunding of Planned Parenthood

Title X Funding Reform

Since being elected President, President Trump has called for the defunding of Planned Parenthood in each of his proposed budgets beginning in 2018.[47] The defunding of organizations that provide and advocate for abortions, such as Planned Parenthood, has been successful through Title X reform. The Family Planning Services and Population Research Act, more often referenced to as Title X, provides funding to family planning services and preventative health services.[48] Serves that fall under these categories include contraception counseling and provision, breast and cervical cancer screenings, testing and treatment for sexually transmitted disease, as well as pregnancy diagnosis and counseling.[49] Administered by the U.S. Department of Health and Human Services, Office of Population Affairs, the program serves those families that are considered low income by providing grants to both public health departments and non profit health centers that operate clinics providing such services.[50] Funding to programs where abortion is offered as a method of family planning is prohibited by the act.[51]

Despite this prohibition, throughout its history Title X has awarded grant money to clinics that also serve as abortion providers, such as Planned Parenthood.[52] While these funds may not have directly given taxpayer funds to cover the cost of abortions, which is prohibited by law in the United States, it indirectly funded abortions by providing funds to groups such as Planned Parenthood which therefore frees up funding for abortions. In order to ensure compliance with the purpose and provisions of Title X, President Trump in coordination with the U.S. Department of Health & Human Services (HHS), authorized a new regulation that prohibits funding for clinics who provide abortions alongside family planning health services.[53] The result is that Title X funding can no longer be granted to organizations who provide family planning services such as contraceptive and counseling in the same location where abortions are also provided.[54] For instance, Planned Parenthood is prevented from receiving funds under Title X unless they were to no longer offer abortions at the clinics that provide other Title X health services.[55] Planned Parenthood decided they would not conform to the requirements of Title X and therefore declined further Title X funding.[56]  Funds that went to organizations that were not eligible to receive them were redistributed to the remaining eligible organizations, including pro-life crisis pregnancy centers.[57] This is noteworthy as the Trump Administration’s reforms broadened the category of those who could receive Title X funding to include state health departments and faith-based organizations.[58]

These reforms have been labeled and referred to as a “Gag rule” by Planned Parenthood and other abortion advocates.[59] In February 2020, the 9^th Circuit Court of Appeals considered a suit brought by several states and abortion providers regarding Title X reforms and upheld the reforms.[60] Of note, the 9^th Circuit Court of Appeals hears appeals from states such as California, Hawaii, Oregon, and Washington.[61]

H.J. Res. 43

In 2017 President Trump signed H.J. Res. 43 into law,[62] overturning a regulation enacted by the Obama Administration two days before President Trump took office.[63] The law prohibited States from defunding certain abortion facilities in their federally-funded family planning programs. H.J. Res. 43 overturned this rule and thus allowed states to withhold federal funds from Planned Parenthood clinics in their states.[64]

Originalist Judges

President Trump has appointed numerous Pro-life federal judges including two Justices of the United States Supreme Court. Both Justice Gorsuch[65] and Justice Kavanaugh[66] have been classified by the pro-life movement leaders as being pro-life with both Justices’ dissenting in a June 2020 Supreme Court case involving abortion regulation in Louisiana (discussed below). Further, Planned Parenthood has labeled both Justices’ as being part of “the Supreme Court’s conservative majority” and that “they have long records of opposing abortion.”[67] Justice Kavanaugh, in his previous role as a 10^th District Court Judge dissented in a decision that granted a 17-year-old unaccompanied minor who entered the United States illegally the right to an abortion.[68]

As of June 24, 2020, President Trump has had 200 judicial nominees confirmed by the Senate – including Supreme Court Justice’s Gorsuch and Kavanaugh.[69] This number includes 53 Federal Appeals Court Judges, 143 District Court Judges, two United States Court of International Trade Judges, alongside the two Supreme Court Justices.[70] NARAL, a Pro-Choice organization listed 18 of the nominated and confirmed federal judges as “anti-choice” meaning that these nominated and confirmed individuals would likely support a pro-life agenda.[71]

June Medical Services L.L.C. v. Russo

Despite the celebratory appointment of pro-life judges across the country, the Supreme Court issued a ruling on a Louisiana state policy that required all abortion procedures to be done by individuals who have admitting privileges at a nearby hospital.[72] The U.S. Supreme Court struck down the Louisiana policy in June 2020.[73] Both recent President Trump appointees Justice Kavanaugh and Justice Gorsuch joined Justices Alito and Thomas in dissenting from the five Justice majority vote which included Chief Justice Roberts.[74] The White House and President Trump issued a press release stating that it was an unfortunate ruling that, “devalued both the health of mothers and the lives of unborn children.”[75]

Addressing the Funding of Research Involving Human Fetal Tissue from Elective Abortions:

In 2019, the Trump administration restricted the use of human fetal tissue procured from abortions in medical research.[76] Under this new restriction, federal scientists that work at the National Institutes of Health are prevented from using or receiving new “samples” of fetal tissue that is the byproduct of abortions.[77] These restrictions did not effect grants from the National Institutes of Health that have been given to universities, although researchers who need to renew their projects or apply for a grant for a project that involves human fetal tissue are required to be reviewed by an ethics advisory board.[78] This restriction is notable as the National Institute of Health spent approximately $115 million on human fetal tissue research in 2018.[79] While this is a small portion of its overall spending on clinical research, which was about $14 billion in 2018,[80] this is a significant amount of funding given to a practice that devalues and commodifies human life. This restriction does not affect private research using fetal tissue from abortions except that it prevents federal funding for such projects.[81] However, it is an affirmative act for protecting the dignity of all human life from President Trump’s administration.

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[1] Donald Trump, President of the United States, March 2018 tweet, found on www.plannedparenthoodaction.org/tracking-trump/player/donald-trump, last accessed June 30, 2020.

[2] Sarah Mccammon, President Trump Faces Friendly Crowd at March for Life, NPR, January 24, 2020, www.npr.org/2020/01/24/798994515/president-trump-to-face-friendly-crowd-at-march-for-life, last accessed June 30, 2020.

[3] White House Briefings, President Donald J. Trump is Standing Up for the Sanctity of Life, whitehouse.gov, January 19, 2018, www.whitehouse.gov/briefings-statements/president-donald-j-trump-standing-sanctity-life/.

[4] Planned Parenthood, Tracking Donald Trump, www.plannedparenthoodaction.org/tracking-trump/player/donald-trump, last accessed June 30, 2020.

[5] Leila Ettachfini, Trump is the First President to Single Out a Health Care Provider in Budget, Vice, May 23, 2017, www.vice.com/en_us/article/ywmjzm/for-first-time-in-history-the-president-singled-out-a-health-care-provider-in-budget, last accessed June 30, 2020.

[6]White House Fact Sheets, President Donald J. Trump is devoted to Protecting American Freedoms and Promoting American Values, February 4, 2020, www.whitehouse.gov/briefings-statements/president-donald-j-trump-is-devoted-to-protecting-american-freedoms-and-promoting-american-values/, last accessed July 1, 2020.

[7] President Donald J. Trump is Standing Up for the Sanctity of Life, supra note 3.

[8] Id.

[9] Kaiser Family Foundation, The Mexico City Policy: An Explainer, June 29, 2020, www.kff.org/global-health-policy/fact-sheet/mexico-city-policy-explainer/#endnote_link_210899-2, last accessed July 1, 2020.

[10] Id. Since being enacted by President Reagan all subsequent President’s have reinstated the policy except President’s Obama and Clinton.

[11] Id.

[12] Id.

[13] Id.

[14] George W. Bush Administration, “Subject: Assistance for Voluntary population Planning,” Memorandum for the Secretary of State, August 29, 2003, Bush Administration White House Archives, georgewbush-whitehouse.archives.gov/news/releases/2003/08/20030829-3.html, last accessed July 1, 2020.

[15] The Mexico City Policy: An Explainer, supra note 9.

[16] Id.

[17] U.S. Government Accountability Office, Global Health Assistance: Awardees’ Declinations of U.S. Planned Funding Due to Abortion-Related Restrictions, www.gao.gov/products/GAO-20-347?source=ra March 18, 2020, last accessed July 1, 2020.

[18]Id.

[19] Reuters, U.S. withdraws funding for U.N. Population Fund, www.reuters.com/article/us-usa-un-populattionfund-idUSKBN17600T, April 2, 2017, last accessed July 2, 2020.

[20] Id.

[21] Kaiser Family Foundation, UNFPA Funding and Kemp-Kasten: An Explainer, July 1, 2020, www.kff.org/global-health-policy/fact-sheet/unfpa-funding-kemp-kasten-an-explainer/, last accessed July 2, 2020.

[22] Id.

[23] Id.

[24] Id.

[25] Id.

[26] Id.

[27]Tracking Donald Trump, supra note 4.

[28] HHS Press Office, HHS Issues Notice of Violation to California for its Abortion Coverage Mandate, January 24, 2020, www.hhs.gov/about/news/2020/01/24/hhs-issues-notice-of-violation-to-california-for-its-abortion-coverage-mandate.html#:~:text=OCR%20is%20issuing%20a%20Notice,that%20did%20not%20cover%20elective, last accessed July 2, 2020.

[29] Id.

[30] Id.

[31] HHS, OCR Finds the State of California Violated Federal Law in Discriminating Against Pregnancy Resource Centers, www.hhs.gov/about/news/2019/01/18/ocr-finds-state-california-violated-federal-law-discriminating-against-pregnancy-resource-centers.html#:~:text=The%20Weldon%20and%20Coats%2DSnowe,perform%20or%20refer%20for%20abortions., last accessed July 2, 2020.

[32] Id.

[33] Id.

[34] Nat'l Inst. of Family & Life Advocates v. Becerra, 138 S. Ct. 2361 (2018).

[35] Id.

[36] HHS Press Office, Trump Administration Actions to Protect Life and Conscience Title X Reforms, January 24, 2020, www.hhs.gov/about/news/2020/01/23/trump-admin-actions-to-protect-life-and-conscience-factsheet-released-01-23-20.html, last accessed June 30, 2020.

[37] Id.

[38] Alison Kodjak, New Trump Rule Protects Health Care Workers Who Refuse Care For Religious Reasons, NPR, May 2, 2019, www.npr.org/sections/health-shots/2019/05/02/688260025/new-trump-rule-protects-health-care-workers-who-refuse-care-for-religious-reason, last accessed July 1, 2020.

[39] Id.

[40] Peter Sullivan, Judge strikes down Trump rule on health care ‘conscience’ rights, The Hill, November 6, 2019, thehill.com/policy/healthcare/469259-judge-strikes-down-trump-rule-on-health-care-conscience-rights, last accessed July 1, 2020.

[41] Katie Keith, Third Court Rules Against Provider Conscience Rule, Health affairs, November 20, 2019, www.healthaffairs.org/do/10.1377/hblog20191120.14018/full/, last accessed July 1, 2020.

[42] Katie Keith, HHS Strips Gender Identity, Sex Stereotyping, Language Access Protections From ACA Anti-Discrimination Rule, Health Affairs, June 13, 2020, www.healthaffairs.org/do/10.1377/hblog20200613.671888/full/, last accessed July 2, 2020.

[43] Id.

[44] Id.

[45] Planned Parenthood, Trump Administration Release Final Rule Encouraging Health Care Discrimination Against LGBTQ+ People, Immigrants, Women, and More, June 12, 2020, www.plannedparenthood.org/about-us/newsroom/press-releases/trump-administration-releases-final-rule-encouraging-health-care-discrimination-against-lgbtq-people-immigrants-women-and-more, last accessed July 2, 2020.

[46] Bostock v. Clayton Cty., 28 Fla. L. Weekly Fed. S. 294 (U.S. 2020). “In Title VII, Congress adopted broad language making it illegal for an employer to rely on an employee’s sex when deciding to fire that employee. We do not hesitate to recognize today a necessary consequence of that legislative choice: An employer who fires an individual merely for being gay or transgender defies the law.”

[47] Planned Parenthood, Planned Parenthood was forced out of Title X, www.plannedparenthoodaction.org/tracking-trump/policy/planned-parenthood, last accessed June 30, 2020.

[48] 42 U.S.C. § 300(a).

[49] Id.

[50] 42 U.S.C. § 300a-4.

[51] 42 U.S.C. § 300a-6.

[52] U.S. Department of Health and Human Services Office of Population Affairs, Title X Grantees Title X Directory Archive, www.hhs.gov/opa/title-x-family-planning/title-x-grantees/archive/index.html, last accessed June 30, 2020.

[53] White House, Statement from the Press Secretary Regarding the Proposed Title X Family Planning Program Rule from the Department of Health and Human Services, May 18, 2018, www.whitehouse.gov/briefings-statements/statement-press-secretary-regarding-proposed-title-x-family-planning-program-rule-department-health-human-services/, last accessed June 30, 2020.

[54] HHS Press Office, Trump Administration Actions to Protect Life and Conscience Title X Reforms, January 24, 2020, www.hhs.gov/about/news/2020/01/23/trump-admin-actions-to-protect-life-and-conscience-factsheet-released-01-23-20.html, last accessed June 30, 2020.

[55] Id.

[56] Alice Miranda Ollstein and Rachel Roubein, Trump administration begins enforcing abortion ‘gag rule’, Politico, July 16, 2019, www.politico.com/story/2019/07/16/trump-administration-abortion-gag-rule-1593665, last accessed June 30, 2020.

[57] Trump Administration Actions to Protect Life and Conscience Title X Reforms, supra note 36.

[58] Id.

[59] Tracking Donald Trump, supra note 4.

[60] California v. Azar, 950 F.3d 1067 (9th Cir. 2020).

[61] United States Courts for the Ninth Circuit, Map of the Ninth Circuit, www.ca9.uscourts.gov/content/view.php?pk_id=0000000135, last accessed June 30, 2020.

[62] White House Statements & Releases, President Donald J. Trump Signs H.J. Res. 43 into Law, April 13, 2017, www.whitehouse.gov/briefings-statements/president-donald-j-trump-signs-h-j-res-43-law/, last accessed July 2, 2020.

[63] BBC News, House votes to enable states to defund Planned Parenthood, February 17, 2017, www.bbc.com/news/world-us-canada-39008136, last accessed July 2, 2020.

[64] Id.

[65] Jeanne Mancini, Neil Gorsuch Will Strengthen the Fight Against Abortion Rights, March 20, 2017, time.com/4705897/neil-gorsuch-anti-abortion/, last accessed June 30, 2020. Jeanne Mancini at the time of the writing of the article was President of March for Life, a pro-life organization in the United States. 

[66] Jeanne Mancini, Why the pro-life movement should support Judge Kavanaugh, August 6, 2018, www.washingtonexaminer.com/opinion/op-eds/why-the-pro-life-movement-should-support-judge-brett-kavanaugh?utm_source=MFL+Action&utm_campaign=fddf79b855-EMAIL_CAMPAIGN_2018_08_14_08_10_COPY_01&utm_medium=email&utm_term=0_819d2c62c4-fddf79b855-102287281, last accessed on June 30, 2020. Jeanne Mancini at the time of the writing of the article was President of March for Life, a pro-life organization in the United States

[67] Planned Parenthood, Tracking Trump Federal Judges, www.plannedparenthoodaction.org/tracking-trump/policy/federal-judges, last accessed June 30, 2020.

[68] Garza v. Hargan, 874 F.3d 735, 752 (D.C. Cir. 2017). “Today's majority decision, by contrast, "substantially" adopts the panel dissent and is ultimately based on a constitutional principle as novel as it is wrong: a new right for unlawful immigrant minors in U.S. Government detention to obtain immediate abortion on demand, thereby barring any Government efforts to expeditiously transfer the minors to their immigration sponsors before they make that momentous life decision.”

[69] Devan Cole and Ted Barret, Senate confirms Trump’s 200^th judicial nominee, updated June 24, 2020, www.cnn.com/2020/06/24/politics/trump-200-judicial-appointments-cory-wilson/index.html, last accessed June 30, 2020.

[70] Id.

[71] NARAL, Trump’s Anti Choice Judicial Nominees, www.prochoiceamerica.org/laws-policy/trumps-anti-choice-judicial-nominees/, last accessed July 1, 2020.

[72] June Medical Services L.L.C. v. Russo, No. 18-1323 (U.S. Jun. 29, 2020). Available at casetext.com/case/june-medical-services-l-l-c-v-russo.

[73] Id.

[74] Nina Totenberg and Brian Naylor, Supreme Court Hands Abortion-Rights Advocates A Victory in Louisiana Case, June 29, 2020, www.npr.org/2020/06/29/874458692/supreme-court-hands-abortion-rights-a-victory-in-louisiana-case, last accessed June 30, 2020.

[75] White House, Statement from the Press Secretary Regarding Today’s Supreme Court Ruling on Abortion, June 29, 2020, www.whitehouse.gov/briefings-statements/statement-press-secretary-regarding-todays-supreme-court-ruling-abortion/, last accessed June 30, 2020.

[76] Bill Chappell, Trump Administration Restricts Federal Research Involving Human Fetal Tissue, NPR, June 5, 2019, www.npr.org/2019/06/05/729983644/trump-administration-bars-federal-research-involving-human-fetal-tissue, last accessed July 2, 2020.

[77] Id.

[78] HHS Press Office, Statement from the Department of Health and Human Services, June 5, 2019, www.hhs.gov/about/news/2019/06/05/statement-from-the-department-of-health-and-human-services.html, last accessed July 2, 2020.

[79] Michelle Andrews, How Trump’s fetal-tissue policy impacts medical research, Spectrum News, June 12, 2019, www.spectrumnews.org/news/trumps-fetal-tissue-policy-impacts-medical-research/, last accessed July 2, 2020.

[80] Id.

[81] Joshua Cohen, Where Politics Trumps Science: Ban On Federal Funding Of Research Using Fetal Tissue, Forbes, June 12, 2019, www.forbes.com/sites/joshuacohen/2019/06/12/where-politics-trumps-science-ban-on-federal-funding-of-research-using-fetal-tissue/#41d28a8c5548, last accessed July 2, 2020.