Misericordia et Misera (Mercy with Misery) was a letter written by Pope Francis and published in Rome, Italy, on 20 November 2016. Through the letter, Pope Francis gives priests the ability to grant forgiveness for abortion. Before Pope Francis’s letter, priests had some ability to grant forgiveness for the Catholic sin of abortion, but bishops had to grant that ability to the priests individually. Prior to the letter, the official rules of the Catholic Church did not state that priests could forgive abortion-related sins. The extension provided in the letter did not change the status of abortion as a grave sin that could result in excommunication. By extending that ability to priests, Pope Francis made forgiveness through the Catholic Church more accessible for women, doctors, and those who take part in an abortion, which started a discussion about the status of abortion in the Catholic Church in the twenty-first century.

In the 1980s, researchers at the pharmaceutical company Roussel-Uclaf in Paris, France, helped develop a biological compound called mifepristone. When a woman takes it, mifepristone interferes with the function of hormones involved in pregnancy and it can therefore be used to terminate pregnancies. In 2000, the US Food and Drug Administration approved mifepristone, also called RU 486, as part of a treatment to induce abortions using drugs instead of surgery, a method called medication abortion. Women can receive medication abortions earlier in their pregnancies than surgical abortions, and medication abortions often result in less severe side-effects than their surgical counterparts. In that capacity, mifepristone has increased women’s access to abortions throughout the world.

On 7 June 1965, in Griswold v. Connecticut (1965), the United States Supreme Court decided, in a seven to two decision, that married couples have the right to purchase and use contraceptives without government restriction. The case considered the constitutionality of a Connecticut state statute from 1879 that prohibited the sale or use of any contraceptive device or medication. In 1961, Estelle Griswold, an executive director of the Planned Parenthood League of Connecticut, hereafter PPLC, and physician Charles Lee Buxton were convicted for selling contraceptives at a pregnancy clinic they opened in New Haven, Connecticut, in violation of state law. Griswold and Buxton challenged the constitutionality of the Connecticut law, claiming it violated the Due Process Clause of the Fourteenth Amendment of the US Constitution, which states that the state government cannot infringe upon rights of citizens without a fair process, such as a trial. Griswold v. Connecticut helped establish an inferred right to privacy within the amendments of the US constitution, granting the right of married couples to access contraceptives and setting the foundation for future cases involving contraception, abortion, anti-sodomy laws, and marriage.

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