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Can We Justify Defunding Planned Parenthood?
Connor Avery
James Madison University



Conservative media these days is constantly attacking abortion and places that provide this
service. Sometimes this is taken to extreme measures. Currently conservatives are attempting to
get funding for a critical women’s care organization; Planned Parenthood; cut. People are
constantly protesting Planned Parenthood because they provide abortion procedures, the protests
even escalating to violence. This essay takes a look at several sources whom use both legal and
statistical methods to combat those whom seek to justify defunding Planned Parenthood. This
paper works as analyses of the arguments made by the authors of the articles that shall be
mentioned with in it, as well as comparing and contrasting the methods used to make the



Background of The Issue
Planned Parenthood has had many recent controversies around it, including a shooting.
Rumors run amuck such as Planned Parenthood selling the organs of aborted fetuses; which
honestly doesn’t make sense because fetuses don’t have well enough developed organs.
Conservatives are calling out that all fetuses are people, claiming a pro-choice stance, and
attempting to shut down all businesses that provide abortions. Something many people seem to
forget is that Planned Parenthood provides so much more than just abortions, examples ranging
from cancer screenings to STD testing along with so many others. A major question I wanted to
research is if defunding Planned Parenthood is justifiable.
The inquiry of the justness of cutting Planned Parenthood from the federal budget is an
important one. The heart of the issue really is “Is it really allowable to base funding off a service
that doesn’t even account for a fourth of the services a group provides?” But this issue extends to
more than just that, it’s one of basic rights and equality. Later on in this essay, there will be
multiple mentions of Tittle X and Supreme Court, as this issue pertains to the rights of all
Americans to equal access and protection under the law. Whether the reader be male or female
this issue brings to sight the continued inequality of the genders.
Introduction to the sources
The first article “Effect of Removal of Planned Parenthood from the Texas Women’s
Health Program” written by Amanda J. Stevenson, Imelda M. Flores-Vazquez, Richard L.
Allgeyer, Pete Schenkkan, and Joseph E. Potter focuses primarily on the statistical effects of
defunding Planned Parenthood within Texas, and uses this information in order to analyze the
reality of defunding. In their analyses they determined that there was decreased access to
contraceptives. In 2016 Stevenson, Flores-Vazquez, Allgeyer, Schenkkan, and Potter state that “



After the Planned Parenthood exclusion, there were estimated reductions in the number of claims
from 1042 to 672 (relative reduction, 35.5%) for long-acting, reversible contraceptives and from
6832 to 4708 (relative reduction, 31.1%) for injectable contraceptives (P<0.001 for both
comparisons)” (p. 1). Stevenson et al. (2016) also determined that within eighteen months from
Texas cutting funding birthrates increased by about twenty-seven percent. From this data
Stevenson et al. (2016) concluded that the removal of Planned Parenthood from the state version
of Medicare programs in Texas are associated with disadvantageous changes in availability of
birth controls.
The second article “The War on Women: Federal Remedies to Fight Back Against the
States that Defund Planned Parenthood” written by David Zoppo comes at the issue at hand from
a moral, legal and statistical standpoint. Zuppo (2012) starts off his article stating that “Medicaid
is the largest single public funding source for family planning services. It provides health
insurance for 37% of all women who are of reproductive age and live below the poverty line.”
(p. 1). Zoppo (2012) subtle attacks the morality of those whom seek to defund family planning
services by saying “The private and public benefit of these services cannot be underestimated.
First, Medicaid and Title X expand access to health care services that would otherwise be
unavailable to low-income women” (p. 1). Zoppo (2012) also shows that Tittle X has great
economic advantages, citing “One study showed that every dollar the federal government spends
on Tittle X, it saves three dollars in avoided in Medicaid and new-born care costs” (p. 1-2).
Zuppo (2012) then goes into ways to help defeat state laws, stating “Under the § 1983
framework, plaintiffs could argue that these de-funding laws impermissibly restrict the right of
Medicaid beneficiaries to choose their provider. Organizations such as Planned Parenthood could
also assert preemption claims against state laws that prohibit them from receiving family



planning funds under Title -X" arguing these laws impose additional restrictions on abortion
providers that would otherwise be qualified to receive family funding under federal law” (p. 4).
Zoppo continues to make claims about legality of the laws cutting funding from Planned
Parenthood, in the end claiming that the best way to defeat these laws is to claim funding is
denied on “unconstitutional grounds” (p. 30).
The third article “Upholding a 40-Year-Old Promise: Why the Texas Sonogram Act is
Unlawful According to Planned Parenthood v. Casey. Pace Law Review” written by Vicki
Toscano and Elizabeth Reiter (2013) starts of strong comparing the sonogram act to “…the
iconic scene from ‘A Clockwork Orange,’ in which a prisoner has his eyes forcibly pinned open
so he may be forced to watch videos that have been deemed useful in modifying his criminal
behavior” (p. 2-3). Toscano and Reiter quote the Supreme court, saying “Though abortion is
conduct, it does not follow that the State is entitled to proscribe it in all instances. That is because
the liberty of the woman is at stake in a sense unique to the human condition and so unique to the
law” (as cited in Toscano & Reiter, 2013, p. 12). Latter on Toscano and Reiter address the
constitutionality of the forced sonogram law, stating “First, states may affect a woman’s
decision-making process by providing persuasive information meant to influence a woman’s
ultimate decision whether to terminate a pregnancy without violating her rights.164 However, if
a state interferes with a woman’s decision-making process by providing her with false,
misleading, or irrelevant information, it imposes an undue burden upon her decision-making
ability and is, thus, unconstitutional” (p. 27). The authors finish by invoke the powerful
emotional and even patriotic feeling that we must adhere to Supreme Court decisions even if
they are decades old, claiming that Roe decision should be upheld to protect women’s rights.
Source Comparison and Contrast



The first and second sources are alike in their use of statistics to make their claim. While
all of the first source’s argument is based off statistical analyses, the second source is far better
well rounded. An example of source two’s use of statistics is when Zoppo (2012) states that
“Two-thirds of all family planning clinics receive Title X funding, enabling those clinics to serve
millions of women, regardless of age, marital status, income, or insurance coverage” (p. 1).
While statistics are helpful, they need more to back them up.
The second and third sources both use the Supreme court, and other legal sources to
convince their readers to side with them. Zoppo is constantly referencing Tittle X and
constitutionality, while Toscano and Reiter often talk about the Roe and Casey Supreme Court
decisions. Both articles call well into question the legality of states taking away funding from
Planned Parenthood.
All three articles agree on one thing, defunding of any family planning service is
disastrous. The Stevenson et al. claim that statistically defunding of Planned Parenthood has a
negative impact on economic matters, and is has an increase in childbirth afterwards. Zoppo’s
main point aligns well with Toscano and Reiter’s main point. Both of their respective articles talk
about how attempts to defund Planned Parenthood and like family planning services act against
women’s constitutional rights.
Source Evaluation
While the statistical evidence in Stevenson et al.’s article is valid and relevant to the topic
at hand, the lack of other supports to their argument makes their article the weakest link of my
sources. The main strength of this article, and my reason behind using it, is that it was a well
carried out study with a high level of relevance to my question. But the data doesn’t make up for
what it lacks in both logos, and ignoring the legality behind this controversy.



My second source is the strongest of the three. Zoppo successfully combines emotional
appeals along with logical appeals, all the while taking into consideration the laws and court
decisions surrounding the controversy. Zoppo makes an excellent argument, and the length of the
article allows for a large depth of detail. The only weakness I perceive is a general lack of
mention of the reasons behind the opposing view point. All in all, Zoppo’s article makes for an
excellent source.
Toscano and Reiter’s article is a good source, addressing both morality and legality of the
controversy. They make multiple appeals to one’s sensibilities, and use previous Supreme Court
cases to strengthen their argument. Again a major weakness of this source is a lack of mention of
the other side’s views.
From my research I’ve learned two things. One statistically speaking, removing
budgeting towards Planned Parenthood is far more economically damaging then continued
funding for it is. Removing funding seriously damages the ability of lower-class women, and
teenage girls from accessing proper health care, which could lead to both terrible health and
financial situations. The second thing I’ve learned from my research is that taking this funding
away is essentially not constitutionally sound, which means that the legality of State laws taking
away resources from Planned Parenthood is highly questionable. Along with these lessons I’ve
learned, and my previous moral stance on the issue, defunding of family planning services such
as Planned Parenthood is unjustifiable. If my research has done anything to my view on this
issue, it has bolstered it. At the start I was defending continued funding based solely on a moral
platform, now I’ve got both legal and statistical information that gives more backbone. I am
honestly very surprised on the lack of articles available that discussed the opposite’s viewpoints.


My stance on funding of Planned Parenthood is only made stronger by my research, and I
believe I will always defend Planned Parenthood, both because it acts as a force of good in our
society, and to protect the rights of women. As a feminist I will always defend equality. Thanks
to previous research I was able to fill in the background information about Planned Parenthood
pretty well based on my own knowledge at this point in time.





Stevenson, A. J., Flores-Vazquez, I. M., Allgeyer, R. L., Schenkkan, P., & Potter, J. E. (2016).
Effect of Removal of Planned Parenthood from the Texas Women’s Health Program. New
England Journal of Medicine N Engl J Med. Retrieved March 9, 2016.

Toscano, V., & Reiter, E. (2013). Upholding a 40-Year-Old Promise: Why the Texas Sonogram
Act is Unlawful According to Planned Parenthood v. Casey. Pace Law Review, 34(1),
129-184. Retrieved March 9, 2016.

Review, 37(2), 495-525. Retrieved March 9, 2016.