UC Law Journal


In 1999, a federal jury, in the case of Planned Parenthood v. American Coalition of Life Activists, returned a verdict in plaintiff's favor to the tune of $100 million. At issue was whether the Web site known as The Nuremberg Files, as well as printed "wanted style" posters dubbed The Deadly Dozen, both listing personal information regarding abortion physicians, were "threats" under The Freedom of Access to Clinic Entrances Act of 1994 (FACE).

FACE imposes liability on any person who intimidates or attempts to intimidate by force or threat of force any person because that person provides reproductive health services. The author examines the First Amendment constitutionality of FACE in the context of Internet postings of personal information about health care providers. She argues that the contemporary atmosphere of violence directed at abortion providers was properly considered by the district court in Planned Parenthood; thus both the decision and FACE survive constitutional dissection.

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