 In its more recent cases the US Supreme Court has held that the state interest in protecting potential life may begin at the moment of conception even though the mother’s interest outweighs it  (Planned Parenthood v. Casey,  505 US 833 (1992)). The Court’s continuing jurisprudence bears out initial feminist concerns that saw this formulation as the tip of a wedge (e.g. Peach 2002). For example, the 2007 decision of  Gonzales v. Carhart  (550 U.S. 124 (2007)) upheld the constitutionality of the Partial Birth Abortion Ban Act of 2003. The Act bans what it terms partial birth abortion—language freighted with the imagery of a live-born person—except when necessary to save the life of the mother. In the decision, the Court weighed substantial state interests in protecting the health of the mother and in preserving fetal life as interests present all along during pregnancy against the burden placed on the woman’s right of reproductive liberty. Opponents of the Act claimed that its partial birth label concealed the extent of its restriction on pre-viability abortion choices. The decision has spurred state efforts to enact the TRAP laws described above. These state statutes have placed increasing burdens on abortion providers; many have closed and abortion is practically unavailable for women in many areas of the United States despite the Supreme Court’s decision in Whole Woman’s Health v. Hellerstedt. 