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3 Years Since Dobbs

  • Writer: Janene Oleaga, Esq.
    Janene Oleaga, Esq.
  • Jun 25
  • 4 min read

It's been 3 years since SCOTUS issued the Dobbs opinion overturning Roe v. Wade and ending the constitutional right to abortion that had been the standard in America for 50 years.

What have we seen since the fall of Roe? What is to come in an America without a constitutional right to access abortion?


Dobbs decision by SCOTUS

3 Years by the Numbers

(per the Guttmacher Institute)


As of June 25, 2025:


13 states have complete abortion bans (Alabama, Arkansas, Idaho, Indiana, Kentucky, Louisiana, Mississippi, Missouri, Oklahoma, South Dakota, Tennessee, Texas, and West Virginia).


4 states have 6 week abortion bans (Florida, Georiga, Iowa, and South Carolina).


25 states introdued 68 bills to restrict abortion medication as the Trump administration is working towards revoking the FDA's approval of mifepristone.


When Roe Fell - A Timeline of Events


June 24, 2022 - Supreme Court Issues Dobbs

  • Supreme Court issues Dobbs: The Court overturned Roe v. Wade, ending federal abortion protections and delegating the authority to regulate abortion to individual states

  • West Coast Shield Laws Initiative: Governors of California, Oregon, and Washington launch a coalition to protect abortion providers and patients from out-of-state legal actions.


July–October 2022

  • Massachusetts and other states enact shield provisions—legal protections for providers and patients against out-of-state enforcement.

  • Indiana and South Carolina courts block post-Dobbs trigger bans, invoking state constitutions.

  • Colorado codifies abortion access: executive orders and laws protect visitors seeking abortion care and expand insurance coverage.


August 2022

  • Michigan ends its dormant abortion prohibition: Democrats repeal a 1931 ban and embed reproductive rights in civil rights law.


November 2023

  • Ohio’s Issue 1 passes (Nov 7): State referendum amends the constitution to guarantee reproductive and abortion rights up to fetal viability

  • Texas legal challenge in Zurawski v. Texas: Plaintiffs sue over medical-exception deficiencies; Texas Supreme Court upholds ban in May 2024. Watch a documentary about the plaintiffs in this case here: Zurawski v. Texas on Jolt.


April–May 2024

  • FDA v. Alliance for Hippocratic Medicine (June 13, 2024): Supreme Court unanimously restores FDA approval and nationwide access to mifepristone.

  • Moyle v. US (June 27, 2024): Court dismisses Idaho case, remanding back to lower courts.

  • Blackmon v. Tennessee (April 2024): Court evaluates medical exceptions to Tennessee's abortion restrictions.

  • Florida 6-week ban takes effect (May 1, 2024) after the Floria Supreme Court lifts stay.


November 5, 2024

  • Missouri Amendment 3 approved: Missouri Constitutional amendment enshrines abortion rights until fetal viability.


December 2024 – January 2025

  • HHS Reproductive Privacy Rule (effective Dec 23, 2024): HIPAA revisions block use of reproductive health data for prosecutions

  • Legal backlash begins:

    • Texas sues a New York doctor over telemedicine abortion services.

    • Louisiana demands extradition of a New York doctor for providing abortion medication via telemedicine. Governor Kathy Hochul refuses to comply with extradition request.


May 2025

  • Kansas legal challenge (May 29, 2025): Patients and providers sue over state law invalidating advance medical directives during pregnancy

  • Alabama midwife birth center ruling (April–May 2025): Court halts overregulation of midwifery/birth centers.

  • Isaacson v. Arizona: Doctors challenge non‑medical abortion restrictions under state constitution (ongoing as of May 2025).

    keep abortion legal and safe and pro-roe

    The States Solidify Their Positions

    While states like California, Michigan, Ohio and Missouri enacted shield laws and took protective measures through constitutional amendments, Florida, Texas, and Tennesse advanced further bans and narrowed medical exceptions.

    Legal battles continue in June 2025 over access to medical abortion through telemedicine, the use of mifepristone, what qualifies as a medical exception, and the right to reproductive privacy.

    Voices in support of the fight for reproductive autonomy, including access to contraception, IVF, surrogacy, end-of-life care during pregnancy, and midwifery are emerging throughout the United States.


On the Federal Stage

SCOTUS issues the decision in U.S. v. Skrmetti (June 18, 2025) upholding Tennessee's SB1 legigslation. SBI bans puberty blockers and hormone therapy for minors seeking gender‑affirming care— but explicitly allows the same treatments for other medical purposes including precocious puberty. While this case focused on trans healthcare, the decision tests how Dobbs may extend state power in regulating medical care beyond abortion. Federal contraceptive protection legislation stalled in Senate after passing House.


What is Next?

  • The next battles for reproductive autonomy and access to care will play out in the following cases:

    • FDA v. Alliance for Hippocratic Medicine - Will the FDA's approval and regulation of mifepristone be overturned?

      • Why it matters: A decision limiting FDA authority could roll back telehealth access, tighten dispensing rules, and reduce availability nationwide.


    • Idaho v. United States - Will federal EMTALA requirements mandating emergency stabilization (including abortion) override Idaho's near-complete abortion ban in the instance of a medical emergency?

      • Why it matters: A decision affirming EMTALA’s reach would protect emergency abortions in restrictive states. A contrary ruling would leave providers and patients exposed to state bans.


    • National Family Planning & Reproductive Health Association v. Kennedy (Title X) - Will cuts in TItle X family planning funds impact access to contraception?


    • South Carolina v. Planned Parenthood South Atlantic (Kerr v. PP) - Can South Carolina exclude Planned Parenthood from Medicaid?

      • Why it matters: A ruling against Planned Parenthood would limit Medicaid patients’ choice and could ripple through reproductive and general healthcare access.


    • First Choice Women's Resource Centers v. New Jersey - What's the deal with crisis pregnancy centers? Can they continue doing what they are doing? Another incredible documentary to watch: Preconceived

      • Why it matters: A key test of free speech rights for abortion counselors and scope for state-level regulation of “crisis pregnancy centers.”


 
 
 

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