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This Note examines abortion opposition over the past two centuries and the extent to which recent trends toward violence have followed from the elimination of major nonviolent methods of dissent. Part I explores the history of abortion opposition prior to Roe, noting that opponents during this period relied almost exclusively on legislative action to effect change. Roe removed this principal nonviolent outlet, and the first wave of anti-abortion violence in American history en-sued. Even within this post-Roe violence, an examination of the rise and fall of mass nonviolent civil disobedience in the late i98Os and the dramatic increase in anti-abortion violence beginning in the early 1990s indicates that anti-abortion violence is closely related to the repression of nonviolent outlets for dissent.

Part II of this Note demonstrates that the relationship between the elimination of nonviolent channels for dissent and the onset of violence has enjoyed broad and deep support in legal and social discourse. Judges, journalists, legal scholars, social scientists, and nonviolent activists have all articulated the principle that preserving nonviolent avenues of dissent helps avoid violence. This principle has been virtually ignored in our national abortion discussion" and, if recognized, would have important implications for future lawmaking.



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