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10 Wm. & Mary Pol'y Rev. 11 (2019)

handle is hein.journals/wamprev10 and id is 1 raw text is: WILLIAM & MARY POLICY REVIEW [VOL.10 A BITTER PILL: THE UNCONSTITUTIONALITY OF THE TRUMP ADMINISTRATION'S CONTRACEPTIVE COVERAGE EXEMPTIONS Talia E. Sukol Case Western Reserve University School ofLaw I. INTRODUCTION Maureen, 61, says that life before the availability of the birth control pill was starkly different for women: If a woman was pregnant and unmarried, she bore the shame of her actions. That was the way they made you feel.- Families were so ashamed that unmarried daughters who conceived a pregnancy with invisible partners were sent far away to distant relatives or homes for unwed mothers to carry and deliver the child out of sight.! Other women elected to undergo illegal and dangerous abortions performed in back alleys and on kitchen tables without sterile procedure and with inadequate tools, sometimes even by their own hand.3 A long history of dialectical positions has shaped the evolution of ideas about contraception. In 1832, Charles Knowlton published a book for young married couples on birth control practices, and was subsequently charged with obscenity and sentenced to a 3-month jail term.! In the 1870's, a social purity movement attacked contraception, as well 1 Life Before the Pill Was Shockingly Different, REFINERY29.com, https://www.refinery29.com/ life-before-the-pill (last visited March 18, 2018). 2 Unwed Mothers Home, PBS.ORG, http://www.pbs.org/opb/historydetectives/investigation/ unwed-mothers-home/ (last visited March 18, 2018). 3 The Bad Old Days, HUFFINGTONPOST.COM, https://www.huffingtonpost.com/david-a-grimes/ the-bad-old-days-abortion b_63246 10.html (last visited March 18, 2018). 4 John M. Riddle, Eve's Herbs: A History of Contraception and Abortion in the West 226-7 (1999); Peter C. Engelman, A History of the Birth Control Movement in America 7 (2011). 11

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