...by 1900, abortion was all but illegal in every state. Some states did include provisos allowing for abortion in limited circumstances, generally to protect the mother's life or pregnancies due to rape or incest. Abortions continued to occur, however, and increasingly became readily available. Illegal abortions were, however, often unsafe.
In 1967, Colorado became the first state to legalize abortion in cases of rape, incest or in which pregnancy would lead to permanent physical disability of the mother. Similar laws were passed in California, Oregon, and North Carolina. In 1970, New York repealed its 1830 law and allowed abortions up to the 24th week of pregnancy on demand. Similar laws were soon passed in Alaska, Hawaii, and Washington. A law in Washington, DC, which allowed abortion to protect the life or health of the mother, was challenged in the Supreme Court in 1971 in United States v. Vuitch. The court upheld the law, deeming that 'health' meant 'psychological and physical well-being,' essentially allowing abortion on demand. By the end of 1972, 13 states had a law similar to that of Colorado, while Mississippi allowed abortion in cases of rape or incest only and Alabama allowed abortions in cases of the mother's physical health. Thirty-one states still allowed abortion to protect the mother's life only. In order to obtain abortions during this period, women would often travel from a state where abortion was illegal to states where it was legal.
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