UPDATED: iPhone, iPad Apps Allow Men to Track Women’s Menstrual Periods. Seriously.

Jodi Jacobson

UPDATED: At first I thought it was a joke. Then I didn't know whether to laugh, cry, scream or call Margaret Atwood.  But this morning I opened the paper to read that new iPhone apps allowing men to track the menstrual periods of their girlfriends or wives are flying off the virtual "shelves."

This article was updated at 10:26 am Saturday, April 24th, 2010 to include details on the features of the iPhone/iPad application, Code Red and to basically change my mind on whether or not this is funny.

At first I thought it was a joke.  Had to be, right?

And then I didn’t know whether to laugh, cry, scream or call Margaret Atwood.

But this morning I opened the paper to read in the Washington Post Style Section (of course) about new iPhone applications that allow men to track the menstrual periods of their girlfriends or wives (or to allow any man to track the menstrual periods of his girlfriends or wives depending on the level of fidelity and cultural milieu applicable).

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And on one hand it could be seen as funny–especially as Monica Hesse relates the story in the Post.  She writes:

Men: We are sorry.

Here we have been assuming that our lady-business skeeved you out, that you heard “menstruation” and you went “lalalalalalala.”

We were wrong.

How else to explain “Code Red,” the new iPhone period app that — and this is really linguistically unfortunate — also works on the iPad?


“Code Red,” writes Hesse, “keeps track of periods.”

It keeps track of them for men. It is, in fact, strong enough for a woman but made for the men who love them, or at least want to monitor their bodies the way that creep-o just might on “Law & Order: SVU” before Detective Benson punched him in the head. Just sayin.’

How it works: Type in the first day of your partner’s cycle for a few months. Then sit back and wait for the helpful reminders to pop up on your Apple device. During PMS time, for example, a female symbol appears sporting devil horns. A frisky ovulation alert tells you when your chances for getting down are looking up.

Menstrual apps for men are a booming market, says Hesse.

“PMSBuddy,” for example, is proudly “saving relationships, one month at a time.” “PMS Meter” features “hilarious sound effects.” And the infamous “IAmAMan,” which is nothing if not unapologetic, allows users to track the menstrual cycles of several women at once, for those special times when you are a big cheater.

At a deep cultural level, she writes, “one might speculate that the proliferation of these apps all ties into some deep fear of womanhood — an attempt by men to make sense of what they do not understand.”

And yet, she notes:

One might offer the possibility that men would chart the life cycle of a fruit fly if they could do it on an iPad, that this is really all about gadgetry. One might also say this is gross.

And the more I looked into it, the less funny and the more gross it became.

Just take a look at the MEDL website at which features of the Code Red app can be found.

First of all, the app is described as “Men’s best defense against the monthly Her-ricane.”  (You know: Women are moody, unpredictable, controlled by their hormones.)

The e-brochure helpfully offers that:

Men no longer need to fear the wrath of menstrual madness. MEDL Mobile is pleased—and very relieved—to introduce Code Red: a simple but powerful menstrual calendar for men to keep track of—and survive—their girlfriend’s/fiancé’s/wife’s monthly cycle.

Menstural madness?  Let’s just reinforce that age-old and completely discredited notion that women are determined by biology and beset by “nervous disorders,” and that any and every response to life or thought a woman has can be traced back to this unfortunate reality.

And the creators of this app make clear they are determined to make the world safer–and more sexually promising–for men.

“Code Red will be a life saver for thousands of guys out there,” said Kevin Harrison, Co-Creator, “Its each guys personal color coded Terror Alert System…”

What makes Code Red so much more valuable than other period tracking apps, they suggest “is the profound simplicity and ease of use.”  Use for what?

When the tracking starts, Code Red will provide special alert messages for every phase in her cycle. There are five different alerts, and each calendar day comes equipped with a wealth of tips and advice to brave even the most violent of storms.

It has the following features:

  • Fully automated menstrual calendar
  • 5 special alerts for each phase of her cycle
  • Dynamic animations for each alert
  • Helpful suggestions to survive each phase
  • Links to local vendors for presents, groceries and goods (via Google Maps)
  • Advanced calendar toggle settings

The special alerts will be particularly helpful to men who apparently can not communicate verbally with their partners:

  • Smooth Sailing Alert — Let’s you know when she’s feeling like a team player.
  • Horny Alert — Let’s you know when you’re able to score.
  • PMS Alert — Let’s you know when to hit the (cold) showers.
  • Ovulation Alert — Let’s you know when to sit on the sidelines (unless you’re ready to start a junior league).
  • Code Red Alert — Let’s you know that it’s game time and you’re way out of bounds.

“Every month, women go through the same ups and downs, but the men in our lives never seem to catch on,” said Lisi Harrison, Co-Creator and Author of New York Times #1 Bestselling series’ The Clique and Alphas.

Are they really that stupid?

If this is a joke, it’s a lucrative one for the creators. While MEDL Mobile, the company that distributes “Code Red,” will not release sales figures, Hesse says that the application has climbed as high as 35 on the Lifestyle division of the Apple app store — a category that includes hundreds of applications.

The developers told Hesse:

“We were sitting around in a meeting where we go over submissions,” Swartz says, when he mentioned “Code Red.” “About half the people there were young guys, and one said, ‘I will pay $20 for that right now.’ Actually, he said $19.99.”

They decided to price the app at $1.99.

While at first I thought it was a bit funny–we all need to be able to laugh at ourselves and our ingrained stereotypes–it really is sad and also troubling at some deeper level.

I mean, let’s face it.  Women’s menstrual periods have been the subject of fascination, disgust, and control by men for centuries.  Orthodox and Hassidic Jews won’t touch a woman they do not know for fear she may be “unclean” (menstruating).  Women in parts of rural India are sent to sleep with the animals or out in the fields when they are menstruating.  In many societies, girls who reach menarche are married off right away, for fear that they might otherwise become sexual superwomen without the control of a man.  The menstrual cycles of girls and women throughout the world in various cultures–and even in the United States, as noted recently by Bianca Laureano on Rewire–are monitored by their parents and their husbands as a means of figuring out what they might be doing with their bodies, whether they are on birth control, and whether they might be having sex and gotten pregnant.  Women still have to combat the notion that they are “emotional,” “nervous,” “incapable,” “unpredictable.”

So it’s not like there is anything new about the combination of horror, control, and confusion that comes with menstruating.  It’s the ultimate “in-your-face” reminder to men that despite any level of subjugation, we can still do something they can not.

But that it is so popular is a reminder of our cultural schizophrenia around sex, power, and gender. On one hand, despite record numbers of sexually transmitted infections and despite still-too-high levels of teenage pregnancy, we can’t get the federal government to stop spending money on failed abstinence-only-until-marriage programs. Networks and cable stations will sell sex 24-7, but many still refuse to air responsible ads for contraceptive methods or such controversial things as condoms, or information about sexually transmitted infections.  We can’t quite accept socially that there is a spectrum of sexuality inherent in being human and that not everyone is embraced under the culturally constructed “one (heterosexual) man and one (heterosexual) woman” notion of marriage.  We still hide condoms in drugstores and some men still have problems buying tampons for their significant others because its….embarassing.

And it is worth noting the the current wave of laws at the state and federal level and the general level of hysteria around women’s rights to choose pregnancy and childbirth in the United States has a lot to do with control over their bodies. So the notion that an iPhone app marketed specifically to men is flying off the virtual shelves is a bit creepy in more ways than one. I’m thinking if in fact the tea-partiers are right, and the government is going to be implanting microchips in anyone, women will be first.

It is also worth watching how well this app does elsewhere in the world.  I am not kidding.  Yesterday, for example, a story on Apple’s first-quarter profits indicated that sales of the iPhone and iPad are booming in places like China, India, Pakistan and elsewhere.  These are cultures in which women’s periods are indeed more openly the source of control (here, we like to pretend we are protecting “life,” not controlling women’s lives.  In China, the one-child policy still leads to forced sterlization and forced abortion, and in ultra-conservative Islamic cultures women are not only blamed for being raped, they are killed for it).  I’d love to know whether and how such an app sells in these places.  Yeah, I know it is possible to track menstrual cycles otherwise and that technology here only reinforces misogyny, it does not create it.  But nonetheless, the “unintended” applications are worth monitoring. 

(BTW, can we get a misogyny meter app, please?)

So I kind of agree with the response given by Kevin Harrison, “co-conceptualizer” with his wife Lisi of the product, to a question by Hesse who asked: “Isn’t Code Red kind of….funny?”

And I think it probably is funny, to the Harrisons and MEDL, who must be laughing all the way to the bank.

Analysis Abortion

Legislators Have Introduced 445 Provisions to Restrict Abortion So Far This Year

Elizabeth Nash & Rachel Benson Gold

So far this year, legislators have introduced 1,256 provisions relating to sexual and reproductive health and rights. However, states have also enacted 22 measures this year designed to expand access to reproductive health services or protect reproductive rights.

So far this year, legislators have introduced 1,256 provisions relating to sexual and reproductive health and rights. Of these, 35 percent (445 provisions) sought to restrict access to abortion services. By midyear, 17 states had passed 46 new abortion restrictions.

Including these new restrictions, states have adopted 334 abortion restrictions since 2010, constituting 30 percent of all abortion restrictions enacted by states since the U.S. Supreme Court decision in Roe v. Wade in 1973. However, states have also enacted 22 measures this year designed to expand access to reproductive health services or protect reproductive rights.

Mid year state restrictions

 

Signs of Progress

The first half of the year ended on a high note, with the U.S. Supreme Court handing down the most significant abortion decision in a generation. The Court’s ruling in Whole Woman’s Health v. Hellerstedt struck down abortion restrictions in Texas requiring abortion facilities in the state to convert to the equivalent of ambulatory surgical centers and mandating that abortion providers have admitting privileges at a local hospital; these two restrictions had greatly diminished access to services throughout the state (see Lessons from Texas: Widespread Consequences of Assaults on Abortion Access). Five other states (Michigan, Missouri, Pennsylvania, Tennessee, and Virginia) have similar facility requirements, and the Texas decision makes it less likely that these laws would be able to withstand judicial scrutiny (see Targeted Regulation of Abortion Providers). Nineteen other states have abortion facility requirements that are less onerous than the ones in Texas; the fate of these laws in the wake of the Court’s decision remains unclear. 

Ten states in addition to Texas had adopted hospital admitting privileges requirements. The day after handing down the Texas decision, the Court declined to review lower court decisions that have kept such requirements in Mississippi and Wisconsin from going into effect, and Alabama Gov. Robert Bentley (R) announced that he would not enforce the state’s law. As a result of separate litigation, enforcement of admitting privileges requirements in Kansas, Louisiana, and Oklahoma is currently blocked. That leaves admitting privileges in effect in Missouri, North Dakota, Tennessee and Utah; as with facility requirements, the Texas decision will clearly make it harder for these laws to survive if challenged.

More broadly, the Court’s decision clarified the legal standard for evaluating abortion restrictions. In its 1992 decision in Planned Parenthood of Southeastern Pennsylvania v. Casey, the Court had said that abortion restrictions could not impose an undue burden on a woman seeking to terminate her pregnancy. In Whole Woman’s Health, the Court stressed the importance of using evidence to evaluate the extent to which an abortion restriction imposes a burden on women, and made clear that a restriction’s burdens cannot outweigh its benefits, an analysis that will give the Texas decision a reach well beyond the specific restrictions at issue in the case.

As important as the Whole Woman’s Health decision is and will be going forward, it is far from the only good news so far this year. Legislators in 19 states introduced a bevy of measures aimed at expanding insurance coverage for contraceptive services. In 13 of these states, the proposed measures seek to bolster the existing federal contraceptive coverage requirement by, for example, requiring coverage of all U.S. Food and Drug Administration approved methods and banning the use of techniques such as medical management and prior authorization, through which insurers may limit coverage. But some proposals go further and plow new ground by mandating coverage of sterilization (generally for both men and women), allowing a woman to obtain an extended supply of her contraceptive method (generally up to 12 months), and/or requiring that insurance cover over-the-counter contraceptive methods. By July 1, both Maryland and Vermont had enacted comprehensive measures, and similar legislation was pending before Illinois Gov. Bruce Rauner (R). And, in early July, Hawaii Gov. David Ige (D) signed a measure into law allowing women to obtain a year’s supply of their contraceptive method.

071midyearstatecoveragetable

But the Assault Continues

Even as these positive developments unfolded, the long-standing assault on sexual and reproductive health and rights continued apace. Much of this attention focused on the release a year ago of a string of deceptively edited videos designed to discredit Planned Parenthood. The campaign these videos spawned initially focused on defunding Planned Parenthood and has grown into an effort to defund family planning providers more broadly, especially those who have any connection to abortion services. Since last July, 24 states have moved to restrict eligibility for funding in several ways:

  • Seventeen states have moved to limit family planning providers’ eligibility for reimbursement under Medicaid, the program that accounts for about three-fourths of all public dollars spent on family planning. In some cases, states have tried to exclude Planned Parenthood entirely from such funding. These attacks have come via both administrative and legislative means. For instance, the Florida legislature included a defunding provision in an omnibus abortion bill passed in March. As the controversy grew, the Centers for Medicare and Medicaid Services, the federal agency that administers Medicaid, sent a letter to state officials reiterating that federal law prohibits them from discriminating against family planning providers because they either offer abortion services or are affiliated with an abortion provider (see CMS Provides New Clarity For Family Planning Under Medicaid). Most of these state attempts have been blocked through legal challenges. However, a funding ban went into effect in Mississippi on July 1, and similar measures are awaiting implementation in three other states.
  • Fourteen states have moved to restrict family planning funds controlled by the state, with laws enacted in four states. The law in Kansas limits funding to publicly run programs, while the law in Louisiana bars funding to providers who are associated with abortion services. A law enacted in Wisconsin directs the state to apply for federal Title X funding and specifies that if this funding is obtained, it may not be distributed to family planning providers affiliated with abortion services. (In 2015, New Hampshire moved to deny Title X funds to Planned Parenthood affiliates; the state reversed the decision in 2016.) Finally, the budget adopted in Michigan reenacts a provision that bars the allocation of family planning funds to organizations associated with abortion. Notably, however, Virginia Gov. Terry McAuliffe (D) vetoed a similar measure.
  • Ten states have attempted to bar family planning providers’ eligibility for related funding, including monies for sexually transmitted infection testing and treatment, prevention of interpersonal violence, and prevention of breast and cervical cancer. In three of these states, the bans are the result of legislative action; in Utah, the ban resulted from action by the governor. Such a ban is in effect in North Carolina; the Louisiana measure is set to go into effect in August. Implementation of bans in Ohio and Utah has been blocked as a result of legal action.

071midyearstateeligibilitytable

The first half of 2016 was also noteworthy for a raft of attempts to ban some or all abortions. These measures fell into four distinct categories:

  • By the end of June, four states enacted legislation to ban the most common method used to perform abortions during the second trimester. The Mississippi and West Virginia laws are in effect; the other two have been challenged in court. (Similar provisions enacted last year in Kansas and Oklahoma are also blocked pending legal action.)
  • South Carolina and North Dakota both enacted measures banning abortion at or beyond 20 weeks post-fertilization, which is equivalent to 22 weeks after the woman’s last menstrual period. This brings to 16 the number of states with these laws in effect (see State Policies on Later Abortions).
  • Indiana and Louisiana adopted provisions banning abortions under specific circumstances. The Louisiana law banned abortions at or after 20 weeks post-fertilization in cases of diagnosed genetic anomaly; the law is slated to go into effect on August 1. Indiana adopted a groundbreaking measure to ban abortion for purposes of race or sex selection, in cases of a genetic anomaly, or because of the fetus’ “color, national origin, or ancestry”; enforcement of the measure is blocked pending the outcome of a legal challenge.
  • Oklahoma Gov. Mary Fallin (R) vetoed a sweeping measure that would have banned all abortions except those necessary to protect the woman’s life.

071midyearstateabortionstable

In addition, 14 states (Alaska, Arizona, Florida, Georgia, Idaho, Indiana, Iowa, Kentucky, Louisiana, Maryland, South Carolina, South Dakota, Tennessee and Utah) enacted other types of abortion restrictions during the first half of the year, including measures to impose or extend waiting periods, restrict access to medication abortion, and establish regulations on abortion clinics.

Zohra Ansari-Thomas, Olivia Cappello, and Lizamarie Mohammed all contributed to this analysis.

Analysis Law and Policy

Justice Kennedy’s Silence Speaks Volumes About His Apparent Feelings on Women’s Autonomy

Imani Gandy

Justice Anthony Kennedy’s obsession with human dignity has become a hallmark of his jurisprudence—except where reproductive rights are concerned.

Last week’s decision in Whole Woman’s Health v. Hellerstedt was remarkable not just for what it did say—that two provisions in Texas’s omnibus anti-abortion law were unconstitutional—but for what it didn’t say, and who didn’t say it.

In the lead-up to the decision, many court watchers were deeply concerned that Justice Anthony Kennedy would side with the conservative wing of the court, and that his word about targeted restrictions of abortion providers would signal the death knell of reproductive rights. Although Kennedy came down on the winning side, his notable silence on the “dignity” of those affected by the law still speaks volumes about his apparent feelings on women’s autonomy. That’s because Kennedy’s obsession with human dignity, and where along the fault line of that human dignity various rights fall, has become a hallmark of his jurisprudence—except where reproductive rights are concerned.

His opinion on marriage equality in Obergefell v. Hodges, along with his prior opinions striking down sodomy laws in Lawrence v. Texas and the Defense of Marriage Act in United States v. Windsor, assured us that he recognizes the fundamental human rights and dignity of LGBTQ persons.

On the other hand, as my colleague Jessica Mason Pieklo noted, his concern in Schuette v. Coalition to Defend Affirmative Action about the dignity of the state, specifically the ballot initiative process, assured us that he is willing to sweep aside the dignity of those affected by Michigan’s affirmative action ban in favor of the “‘dignity’ of a ballot process steeped in racism.”

Meanwhile, in his majority opinion in June’s Fisher v. University of Texas, Kennedy upheld the constitutionality of the University of Texas’ affirmative action program, noting that it remained a challenge to this country’s education system “to reconcile the pursuit of diversity with the constitutional promise of equal treatment and dignity.”

It is apparent that where Kennedy is concerned, dignity is the alpha and the omega. But when it came to one of the most important reproductive rights cases in decades, he was silent.

This is not entirely surprising: For Kennedy, the dignity granted to pregnant women, as evidenced by his opinions in Planned Parenthood v. Casey and Gonzales v. Carhart, has been steeped in gender-normative claptrap about abortion being a unique choice that has grave consequences for women, abortion providers’ souls, and the dignity of the fetus. And in Whole Woman’s Health, when Kennedy was given another chance to demonstrate to us that he does recognize the dignity of women as women, he froze.

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He didn’t write the majority opinion. He didn’t write a concurring opinion. He permitted Justice Stephen Breyer to base the most important articulation of abortion rights in decades on data. There was not so much as a callback to Kennedy’s flowery articulation of dignity in Casey, where he wrote that “personal decisions relating to marriage, procreation, contraception, family relationships, child rearing, and education” are matters “involving the most intimate and personal choices a person may make in a lifetime, choices central to personal dignity and autonomy.” (While Casey was a plurality opinion, various Court historians have pointed out that Kennedy himself wrote the above-quoted language.)

Of course, that dignity outlined in Casey is grounded in gender paternalism: Abortion, Kennedy continued, “is an act fraught with consequences for others: for the woman who must live with the implications of her decision; for the persons who perform and assist in the procedures for the spouse, family, and society which must confront the knowledge that these procedures exist, procedures some deem nothing short of an act of violence against innocent human life; and, depending on one’s beliefs, for the life or potential life that is aborted.” Later, in Gonzales, Kennedy said that the Partial-Birth Abortion Ban “expresses respect for the dignity of human life,” with nothing about the dignity of the women affected by the ban.

And this time around, Kennedy’s silence in Whole Woman’s Health may have had to do with the facts of the case: Texas claimed that the provisions advanced public health and safety, and Whole Woman’s Health’s attorneys set about proving that claim to be false. Whole Woman’s Health was the sort of data-driven decision that did not strictly need excessive language about personal dignity and autonomy. As Breyer wrote, it was a simple matter of Texas advancing a reason for passing the restrictions without offering any proof: “We have found nothing in Texas’ record evidence that shows that, compared to prior law, the new law advanced Texas’ legitimate interest in protecting women’s health.”

In Justice Ruth Bader Ginsburg’s two-page concurrence, she succinctly put it, “Many medical procedures, including childbirth, are far more dangerous to patients, yet are not subject to ambulatory-surgical-center or hospital admitting-privileges requirements.”

“Targeted Regulation of Abortion Providers laws like H.B. 2 that ‘do little or nothing for health, but rather strew impediments to abortion,’ cannot survive judicial inspection,” she continued, hammering the point home.

So by silently signing on to the majority opinion, Kennedy may simply have been expressing that he wasn’t going to fall for the State of Texas’ efforts to undermine Casey’s undue burden standard through a mixture of half-truths about advancing public health and weak evidence supporting that claim.

Still, Kennedy had a perfect opportunity to complete the circle on his dignity jurisprudence and take it to its logical conclusion: that women, like everyone else, are individuals worthy of their own autonomy and rights. But he didn’t—whether due to his Catholic faith, a deep aversion to abortion in general, or because, as David S. Cohen aptly put it, “[i]n Justice Kennedy’s gendered world, a woman needs … state protection because a true mother—an ideal mother—would not kill her child.”

As I wrote last year in the wake of Kennedy’s majority opinion in Obergefell, “according to [Kennedy’s] perverse simulacrum of dignity, abortion rights usurp the dignity of motherhood (which is the only dignity that matters when it comes to women) insofar as it prevents women from fulfilling their rightful roles as mothers and caregivers. Women have an innate need to nurture, so the argument goes, and abortion undermines that right.”

This version of dignity fits neatly into Kennedy’s “gendered world.” But falls short when compared to jurists internationally,  who have pointed out that dignity plays a central role in reproductive rights jurisprudence.

In Casey itself, for example, retired Justice John Paul Stevens—who, perhaps not coincidentally, attended the announcement of the Whole Woman’s Health decision at the Supreme Court—wrote that whether or not to terminate a pregnancy is a “matter of conscience,” and that “[t]he authority to make such traumatic and yet empowering decisions is an element of basic human dignity.”

And in a 1988 landmark decision from the Supreme Court of Canada, Justice Bertha Wilson indicated in her concurring opinion that “respect for human dignity” was key to the discussion of access to abortion because “the right to make fundamental personal decision without interference from the state” was central to human dignity and any reading of the Canadian Charter of Rights and Freedoms 1982, which is essentially Canada’s Bill of Rights.

The case was R. v. Morgentaler, in which the Supreme Court of Canada found that a provision in the criminal code that required abortions to be performed only at an accredited hospital with the proper certification of approval from the hospital’s therapeutic abortion committee violated the Canadian Constitution. (Therapeutic abortion committees were almost always comprised of men who would decide whether an abortion fit within the exception to the criminal offense of performing an abortion.)

In other countries, too, “human dignity” has been a key component in discussion about abortion rights. The German Federal Constitutional Court explicitly recognized that access to abortion was required by “the human dignity of the pregnant woman, her… right to life and physical integrity, and her right of personality.” The Supreme Court of Brazil relied on the notion of human dignity to explain that requiring a person to carry an anencephalic fetus to term caused “violence to human dignity.” The Colombian Constitutional Court relied upon concerns about human dignity to strike down abortion prohibition in instances where the pregnancy is the result of rape, involves a nonviable fetus, or a threat to the woman’s life or health.

Certainly, abortion rights are still severely restricted in some of the above-mentioned countries, and elsewhere throughout the world. Nevertheless, there is strong national and international precedent for locating abortion rights in the square of human dignity.

And where else would they be located? If dignity is all about permitting people to make decisions of fundamental personal importance, and it turns out, as it did with Texas, that politicians have thrown “women’s health and safety” smoke pellets to obscure the true purpose of laws like HB 2—to ban abortion entirely—where’s the dignity in that?

Perhaps I’m being too grumpy. Perhaps I should just take the win—and it is an important win that will shape abortion rights for a generation—and shut my trap. But I want more from Kennedy. I want him to demonstrate that he’s not a hopelessly patriarchal figure who has icky feelings when it comes to abortion. I want him to recognize that some women have abortions and it’s not the worst decision they’ve ever made or the worst thing that ever happened to him. I want him to recognize that women are people who deserve dignity irrespective of their choices regarding whether and when to become a mother. And, ultimately, I want him to write about a woman’s right to choose using the same flowery language that he uses to discuss LGBTQ rights and the dignity of LGBTQ people.  He could have done so here.

Forcing the closure of clinics based on empty promises of advancing public health is an affront to the basic dignity of women. Not only do such lies—and they are lies, as evidenced by the myriad anti-choice Texan politicians who have come right out and said that passing HB 2 was about closing clinics and making abortion inaccessible—operate to deprive women of the dignity to choose whether to carry a pregnancy to term, they also presume that the American public is too stupid to truly grasp what’s going on.

And that is quintessentially undignified.