Jackson Women's Health Organization v. Amy: Complaint


Plaintiff, by and through its undersigned attorneys, brings this complaint against the defendants, their agents and successors in office, and in support thereof avers the following:

1. This is a facial and as-applied challenge to a prohibition on the performance of second-trimester abortions in Mississippi except in licensed hospitals or Ambulatory Surgical Facilities (“ASF”). House Bill 1038 (“An Act to amend Section 41-75-1, Mississippi Code of
1972, to provide that abortion procedures after the first trimester shall be performed only at an ambulatory surgical facility or hospital licensed to perform that service; and for related purposes.”) (“Act”) (attached to Complaint as Exhibit A)...