Editing Roe v. Wade (section)

===''Whole Woman's Health v. Jackson''===
In 2021, the state of Texas devised a legal workaround to ''Roe'' that allowed it to successfully outlaw abortion at six weeks of pregnancy despite the continued existence of ''Roe'' and ''Casey''. In the [[Texas Heartbeat Act]], the legislature created a novel enforcement mechanism that bars state officials from enforcing the statute and authorizes private individuals to sue anyone who performs or assists an illegal abortion.<ref>{{Cite web|url=https://statutes.capitol.texas.gov/docs/hs/htm/hs.171.htm#171.207 |title=Texas Health and Safety Code §§ 171.207–171.208|website= statutes.capitol.texas.gov|access-date=24 December 2021}}</ref><ref name="Tavernise">{{Cite web|url= https://www.nytimes.com/2021/07/09/us/abortion-law-regulations-texas.html|title=Citizens, Not the State, Will Enforce New Abortion Law in Texas|last=Tavernise|first=Sabrina|date=9 July 2021|website=www.newyorktimes.com|access-date=24 December 2021}}</ref> Because the Act is enforced by private citizens rather than government officials, there are no state officials that abortion providers can sue to stop the enforcement of the law, and they cannot obtain judicial relief that will stop private lawsuits from being initiated against them.<ref name="Jackson">{{cite web | title=Whole Woman's Health v. Jackson, No. 21-463 | url=https://www.supremecourt.gov/opinions/21pdf/21-463_3ebh.pdf | date=December 10, 2021 | website=supremecourt.gov | access-date=December 26, 2021}}</ref> This has produced an end-run around ''Roe'' because the threat of private civil-enforcement lawsuits has forced abortion providers to comply with the Act despite its incompatibility with the Supreme Court's abortion pronouncements.<ref name="Gershman3">{{cite web | last1=Gershman | first1=Jacob | title=Behind Texas Abortion Law, an Attorney's Unusual Enforcement Idea | url=https://www.wsj.com/articles/behind-texas-abortion-law-an-attorneys-unusual-enforcement-idea-11630762683 | date=September 4, 2021 | work=[[The Wall Street Journal]] | access-date=December 24, 2021}}</ref><ref>{{Cite news|url=https://www.houstonchronicle.com/politics/texas/article/Austin-judge-blocks-enforcement-of-Texas-six-week-16425384.php|last=Blackburn|first=Jeremy|title=Abortion providers scramble to respond to patients before new Texas law takes effect|date=31 August 2021|newspaper=Houston Chronicle|access-date=24 December 2021}}</ref> Other states have copied this enforcement mechanism to sidestep ''Roe'' and immunize their anti-abortion statutes from judicial review.<ref name="HB4327">{{cite web |title=Text of HB 4327 |url= https://legiscan.com/OK/text/HB4327/id/2587278/Oklahoma-2022-HB4327-Enrolled.pdf |publisher=legiscan.com|access-date=May 25, 2022}}</ref><ref>{{cite web | url = https://www.nytimes.com/2022/05/25/us/oklahoma-abortion-ban-law-governor.html | title = Oklahoma Governor Signs Bill That Bans Most Abortions| first1 = Luke | last1 = Vander Ploeg | date=  May 25, 2022| access-date = May 25, 2022| work = [[New York Times]] }}</ref><ref>{{cite web | url = https://www.nytimes.com/2022/03/14/us/idaho-abortion-bill-texas.html| title = Idaho Is First State to Pass Abortion Ban Based on Texas' Law | first1 = Kate | last1 = Zernike | date= March 14, 2022| access-date = June 15, 2022| work = The New York Times}}</ref> This maneuver has weakened ''Roe'' and undercut the federal judiciary's ability to protect abortion rights from state legislation.<ref>{{cite web | url = https://www.conservativedailynews.com/2022/06/roe-v-wade-is-already-dead | title = Roe v. Wade Is Already Dead | first1 = Josh | last1 = Hammer | date= June 5, 2022| access-date = June 15, 2022| work = CDN}}</ref>