In 2010, US Congress enacted section 3509 of the Patient Protection and Affordable Care Act or ACA, to target issues relating to women’s health. The ACA, signed into law by US President Barack Obama, aimed to increase people’s access to high-quality healthcare in the United States. Section 3509, titled “Improving Women’s Health,” established the Office on Women’s Health within the US Department of Health and Human Services and in four of its agencies, the Agency for Healthcare Research and Quality, the Center for Disease Control and Prevention, the Food and Drug Administration, and the Health Resources and Services Administration. Section 3509 of the ACA exemplified a federal effort to improve women’s health in the US by increasing the amount of research and programs focused on the health concerns of American women.

On 1 July 1976, the US Supreme Court decided in the case Planned Parenthood v. Danforth that provisions of a Missouri law regulating abortion care were unconstitutional. That law, House Bill 1211, restricted abortion care by requiring written consent for each abortion procedure from the pregnant woman as written consent of the woman’s husband if she was married, or the written consent of her parents if she was unmarried and younger than eighteen. House Bill 1211 also required that physicians make efforts to preserve the lives of aborted fetuses. Following the passage of House Bill 1211 in 1974, two physicians and Planned Parenthood of Central Missouri challenged the law. Following the decisions by several lower courts, the US Supreme Court ruled on the case. The US Supreme Court struck down parts of a law that violated the US Constitution and the prior court case Roe v. Wade, and in doing so, they expanded access to abortion care in the US.

In the 1971 court case United States v. Milan Vuitch, hereafter US v. Vuitch, the US Supreme Court ruled that a Washington, DC law was constitutional by overturning a 1969 district court decision. Beginning in the early twentieth century, Washington, DC, prohibited abortions except for abortions performed to preserve the life or health of the pregnant woman. In 1969, Milan Vuitch, a physician in Washington, DC, was convicted of criminal abortion for providing an abortion when the woman’s life was not endangered. In his defense, Vuitch argued that the Washington abortion law was unconstitutionally vague, meaning it failed to define health in terms clear enough so that doctors could be sure what actions violated the law. Though a lower district court agreed with Vuitch and struck down the law as unconstitutional, the Supreme Court later disagreed and overturned the decision. US v. Vuitch was one of the first US Supreme Court cases that challenged the constitutional validity of laws regulating abortion and set a precedent that helped determine future abortion cases, like Roe v. Wade in 1973, which made abortions more accessible and gave women more control over their bodies.

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