The U.S. Supreme Court's ruling in Dobbs v. Jackson Women's Health Organization,142 S. Ct. 2288 (2022) which overruled the long-standing precedent of Roe v. Wade, 410 U.S. 113 (1973) and held that there was no federally protected constitutional right to an abortion heralded a sea change in the law and has resulted in massive inconsistencies in whether, and under what circumstances, abortions are legal in various states. In this regard, multiple states have enacted either outright bans on abortions or have restricted, considerably, the circumstances under which the procedure can be performed. This inconsistency sometimes results in contiguous states having drastic differences in whether the procedure is legal and, on some occasions, whether the recipient and the provider can be charged with a criminal offense. Currently, 13 states have banned abortion completely and 31 states ban abortion after a certain period or gestation and at least one state (Texas) permits private citizens to file lawsuits against providers who perform abortions. see Guttmacher Institute, State Bans on Abortion Throughout Pregnancy, May 31, 2023.