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In the nineteenth century, obstetricians in Europe began to construct devices to incubate infants in increasingly controlled environments. The infant incubator is a medical device that maintains stable conditions and a germ free environment for premature infants born before the thirty-seventh week of pregnancy. Records show that physicians had used infant incubators since 1835. However, Jean-Louis-Paul Denuce, a physician who worked in Bordeaux, France, first published about incubator technology in 1857.
In the 1973 court case Doe v. Bolton, the US Supreme Court in Washington, D.C., ruled that a Georgia law regulating abortion was unconstitutional. The Georgia abortion law required women seeking abortions to get approval for the procedure from their personal physician, two consulting physicians, and from a committee at the admitting hospital. Furthermore, under the statutes, only women who had been raped, whose lives were in danger from the pregnancy, or who were carrying fetuses likely to be seriously, permanently malformed were permitted to receive abortions.