20 S. Ill. U. L. J. 205 (1995-1996)
If It's Not Too Much to Ask, Could You Please Shut Up

handle is hein.journals/siulj20 and id is 243 raw text is: IF IT'S NOT Too MUCH TO ASK, COULD YOU PLEASE SHUT
Madsen v. Women's Health Ctr., Inc., 114 S. Ct. 2516 (1994).
Jennifer J. Seibring
David Gunn, 47, was killed March 10, [1993,] shot in the back outside
Pensacola Women's Medical Services.' Gunn was a doctor who performed
abortions at the Pensacola clinic. An anti-abortion protestor was charged with
his murder.2 Additional acts of violence by anti-abortionists across the country
include clinic bombings, arson, death threats, assaults, and kidnappings.3
American courts have responded to these acts of violence by issuing injunctions
that limit the manner in which protests can be conducted. Recently, the United
States Supreme Court addressed the validity of an injunction restricting the
rights of abortion protestors in Madsen v. Women's Health Center, Inc.,4
upholding the injunction in part and striking in part.
In Madsen, the trial court was asked to amend an injunction issued against
abortion protestors in September of 1992 due to repeated violations of the
injunction.6 A modified injunction was issued on April 8, 1993, after the trial
court determined that the original injunction was not adequately protecting the
rights of Brevard and Seminole County women who were seeking medical
services.7  Anti-abortion protestors challenged the amended injunction as
unconstitutional! The Florida Supreme Court affirmed the injunction' The
1.  Patricia Walsh, Abortion Rights March 3,000 Honor Slain Doctor, MIAMI HERALD, May 9, 1993,
at 6B.
2.   Phil Long, Abortion Rights Advocates Seek Protection, MIAMI HERALD, Aug. 30, 1993, at 5B.
3.   Clinton Signs Bill Ensuring Clinic Access, MIAMI HERALD, May 27, 1994. at 6A.
4.   114 S. Ct. 2516 (1994).
5.  Madsen, 114 S. Ct. at 2530.
6.  Id. at 2521. Such violations included an attack on the clinic with butyric acid in December, 1992,
the disablement of the clinic doors with super glue, the stalking and harassment of employees and
staff, and the harassment of patients. James J. Kirkpatrick, Speech and Conduct Clash in
Melbourne Abortion Case, MiAMI HERALD, May 1, 1994, at 3M.
7.   Operation Rescue v. Women's Health Ctr., Inc., 626 So. 2d 664, 667 (Fla. 1993).
8.   Madsen, 114 S. Ct. at 2521.
9.  Id. at 2522.

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