The Pre-Roe Pro-Life Movement in Minnesota and New York

Chapter 3: The Post-Roe Shift: Minnesota Citizens Concerned for Life
Redirect and Progress at Home, While Founders Move Onward and
Upward
The New Wave of a Post-Roe Debate:
MCCL’s Accomplishments After a “Day of Infamy in American
History” 1
The United States Supreme Court handed down the Roe v. Wade and Doe v.
Bolton decisions on January 22, 1973, changing American law and the abortion debate
for nearly forty years, and counting. The justices who held the majority opinion in Roe v.
Wade argued the Texas abortion statute that prevented first trimester abortions violated
the Due Process Clause of the Fourteenth Amendment of the Constitution. 2 Additionally,
the less familiar Doe v. Bolton decision ruled the multiple requirements in Georgia’s
abortion statute (that abortions must be conducted in hospitals, approved by the hospital’s
board committee, and that the woman seeking the abortion must be a citizen of Georgia)
all violated the Due Process Clause of the Fourteenth Amendment as well. 3 With these
decisions came a great wave of many more to come, and with increasing frequency.
While the twentieth century Supreme Court heard and ruled on only five cases relating to
abortion prior to 1973, it saw three in 1973 alone, fourteen more in the remaining years of
1 Marjory Mecklenburg, quoted in “Court’s Ruling on Abortion Hit,” UPI, Seattle Post
Intelligencer, A5, 29 April 1974, ACCL Records, Box 27, Folder: ACCL Admin File: M. Mecklenburg
1973-76 (1), Gerald R. Ford Presidential Library.
2 Palmer, 321.
3 Ibid., 91.
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