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60-569: NAF was established in 1977 with the merger of the National Association of Abortion Facilities (NAAF), founded by Merle Hoffman , and the National Abortion Council (NAC). One of its founders was Frances Kissling , later president of Catholics for a Free Choice . As of 2024, Brittany Fonteno is president and CEO of the organization. NAF publishes Clinical Policy Guidelines for Abortion Care (CPGs), which set

120-676: A church-funded organization which called for people to have adoptions over abortions. In 2015, the organization sued the Center for Medical Progress (CMP), an anti-abortion organization, for making secret recordings that CMP alleged depicted abortion providers engaging in criminal activity. Orrick subsequently issued a temporary restraining order blocking the CMP from releasing the videos. The CMP had earlier released heavily edited videos , which purported to show that Planned Parenthood had been inappropriately selling fetal tissue. In his decision granting

180-875: A concert pianist, she attended the High School of Music and Art in New York City and graduated from Chatham Square Music School . After living and studying music in Paris, Hoffman returned to the United States and graduated from Queens College , Phi Beta Kappa and magna cum laude in 1972. She attended the Social Psychology Doctoral Program at the City University of New York Graduate Center from 1972 to 1975. In her 2012 memoir, Intimate Wars: The Life and Times of

240-456: A detailed list of abortion clinics by province and the maximum gestational period that the clinic will provide abortion up to. The website also has other resources, including information on referrals and how to obtain financial support for travel expenses, after-treatment supplies, child care and various other needs. NAF was established in 1977 with the merger of the National Association of Abortion Facilities (NAAF), founded by Merle Hoffman , and

300-428: A dispute than the injunction. In the state of New South Wales , a court may grant an apprehended violence order (AVO) to a person who fears violence, harassment, abuse, or stalking . The order prohibits the defendant from assaulting, harassing, threatening, stalking, or intimidating the person seeking the order. Other conditions may be included, such as a prohibition against contacting the person or attempting to find

360-621: A federal court in the 1920s effectively barred the United Mine Workers of America from talking to workers who had signed yellow dog contracts with their employers. Unable to limit what they called "government by injunction" in the courts, labor and its allies persuaded the United States Congress in 1932 to pass the Norris-LaGuardia Act , which imposed so many procedural and substantive limits on

420-530: A net cost on consumers, thus obviating the role of antitrust enforcement. Interim injunctions or interim orders are granted as a means of providing interim relief while a case is being heard, to prevent actions being implemented which potentially may be barred by a final ruling. In England and Wales, injunctions whose existence and details may not be legally reported, in addition to facts or allegations which may not be disclosed, have been issued; they have been informally dubbed "super-injunctions". An example

480-421: A party seeks injunctive relief to enforce the grievance arbitration provisions of a collective bargaining agreement . Second, injunctions were crucial to the second half of the twentieth century in the desegregation of American schools. Federal courts gave injunctions that carried out the command of Brown v Board of Education to integrate public schools in the United States, and at times courts took over

540-439: A positive moral value.'" Kirkus Reviews called it "An inspiring story of a woman who participated in 'one of the greatest revolutions in history'—and is still at the forefront of the struggle." Hoffman was one of the first activists to criticize Operation Rescue , an organization dedicated to ending access to abortion by blockading clinics. When Operation Rescue announced it would shut down abortion services in New York City for

600-497: A preliminary injunction tend to be the same as for a permanent injunction, with the additional requirement that the party asking for the injunction is likely to succeed on the merits. Permanent injunctions are issued after trial. Different federal and state courts sometimes have slightly different requirements for obtaining a permanent injunction. The Supreme Court enumerated the traditional four-factor test in eBay Inc. v. MercExchange, L.L.C. as: The balance of hardships inquiry

660-492: A proper motion to the court) if circumstances change in the future. These features of the injunction allow a court granting one to manage the behavior of the parties. That is the most important distinction between the injunction and another non-monetary remedy in American law, the declaratory judgment . Another way these two remedies are distinguished is that the declaratory judgment is sometimes available at an earlier point in

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720-717: A reproductive rights coalition based in New York City. Hoffman received the "Bella" Award from the Bella Abzug Leadership Institute, founded by Liz Abzug, daughter of the late Congresswoman, Bella Abzug, in 2015. The Newswomen's Club of New York awarded Hoffman the Front Page Award for her article "Selecting the Same Sex," published in On The Issues. The essay about the complex issues of sex selection and abortion appeared in

780-542: A restraining order, Orrick wrote that the order was necessary to prevent irreparable harm to NAF "in the form of harassment, intimidation, violence, invasion of privacy, and injury to reputation, and the requested relief is in the public interest." In subsequent proceedings, Orrick reviewed hundreds of hours of videos and found no evidence of wrongdoing on NAF's behalf, and concluded that the CMP, led by anti-abortion activist David Daleiden , had "misleadingly edited videos to make it appear as though abortion providers were breaking

840-449: A sacrament.'" In her memoir, Hoffman recalls that her first exposure to abortion had been when she was about ten: "I overheard my parents' discussion of a Philadelphia physician whose patient had died while he was performing an illegal procedure. To cover for himself, he cut her up in pieces and put her remains down the drain." Hoffman co-founded and helped run Flushing Women's Medical Center (forerunner of Choices Women's Medical Center) in

900-701: A super-injunction but also including an order that the injunction must not be discussed with members of Parliament, journalists, or lawyers. One known hyper-injunction was obtained at the High Court in 2006, preventing its subject from saying that paint used in water tanks on passenger ships can break down and release potentially toxic chemicals. This example became public knowledge in Parliament under parliamentary privilege. By May 2011, Private Eye claimed to be aware of 53 super-injunctions and anonymised privacy injunctions, though Lord Neuberger's report into

960-459: A trip of physicians and counselors from Choices on a well-publicized educational exchange there. In 1974 she began working with Russian hospitals and doctors to develop CHOICES East, the first feminist outpatient medical center in Russia, and organized Russian feminists to deliver an open letter to Boris Yeltsin on the state of women's health care. In 1982, Hoffman produced, directed, and wrote

1020-483: A week in the spring of 1988, the New York Pro-Choice Coalition, founded by Hoffman, responded by rebranding those days "Reproductive Freedom Week," organizing a counter protest that drew 1,300 activists and supporters, and dispatching supporters to ensure that every clinic or doctor's offices Operation Rescue targeted remained open. During the 1989 New York City Mayoral Race, shortly after

1080-718: Is a Necessity – The Impact of Recession on Abortion," was updated in 2011, and the results were presented at the National Press Club in Washington, D.C., on January 19, 2012. Hoffman began a newsletter for Choices in 1982 which developed into On the Issues : The Progressive Women's Quarterly , an acclaimed national magazine with an international following, featuring interviews by Hoffman with notable activists and thinkers, including Andrea Dworkin , Congressman John Lewis , Kate Millett , and Elie Wiesel . In 2008, On

1140-475: Is also sometimes called the "undue hardship defense". A stay pending appeal is a mechanism allowing a losing party to delay enforcement of an injunction while appeal is pending after final judgment has been granted by a lower court. The DOJ and the FTC have investigated patent holders in the United States for seeking preliminary injunctions against accused infringers of standard-essential patents , or patents that

1200-594: Is an equitable remedy, that is, a remedy that originated in the English courts of equity . Like other equitable remedies, it has traditionally been given when a wrong cannot be effectively remedied by an award of money damages. (The doctrine that reflects this is the requirement that an injunction can be given only when there is "no adequate remedy at law.") Injunctions are intended to make whole again someone whose rights have been violated. Nevertheless, when deciding whether to grant an injunction, courts also take into account

1260-409: Is called a "mandatory injunction." An injunction that prohibits conduct is called a "prohibitory injunction." Many injunctions are both—that is, they have both mandatory and prohibitory components, because they require some conduct and forbid other conduct. When an injunction is given, it can be enforced with equitable enforcement mechanisms such as contempt. It can also be modified or dissolved (upon

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1320-406: Is funded by donation only and is a registered charity. NAF launched a Canadian Public Policy and Outreach Program on May 16, 2006, with the support of Senator Lucie Pépin , Federal MP and former Minister of State for Health Carolyn Bennett , and NDP Status of Women Critic Irene Mathyssen . The program offers Canadian women abortion referrals, options counseling and post-abortion counseling through

1380-602: Is in the Merle Hoffman Papers Collection, 1994 to 2001, at Duke University. In 2011, Hoffman endowed a director's position for sustained leadership of the Duke University Sallie Bingham Center for Women's History and Culture. In 2005, Hoffman adopted a three-year-old girl from Siberia whom she named Sasha. Hoffman is Jewish. Preliminary injunction An injunction is an equitable remedy in

1440-470: Is likely to succeed on the merits, that he is likely to suffer severe harm in the absence of preliminary relief, and that an injunction is in the public interest. In Turkish law, interim injunction is an extraordinary remedy that is never awarded as of right. In each case, courts balance the competing claims of injury and consider the likely hardship on the defendant. Injunctions have been especially important at two moments in American history. First, in

1500-406: Is usually to preserve the status quo until the court is able to decide the case. A special kind of injunction that may be issued before trial is called a "temporary restraining order" or TRO. A TRO may be issued without notice to the other party or a hearing. A TRO will be given only for a short period of time before a court can schedule a hearing at which the restrained person may appear and contest

1560-615: The American Journal of Obstetrics and Gynecology and the Journal of the American Medical Women's Association . Hoffman also published two studies with Adelphi University in the 80s that documented how poverty leads many women to choose abortions and showed that nearly half the women seeking abortion at CHOICES would pursue one illegally if Roe v. Wade were repealed. The study, "Abortionomics: When Choice

1620-761: The Amsterdam News in response to the Central Park jogger rape case . Hoffman's memoir, Intimate Wars: The Life and Times of the Woman Who Brought Abortion from the Back Alley to the Boardroom , was published in 2012 by Feminist Press . Publishers Weekly opined that "she eloquently chronicles more than three decades of struggles to keep abortion legal. Readers will learn much about her drive to recast 'reproductive freedom as

1680-657: The U.S. Supreme Court ruled in Webster that states could limit abortion access, Hoffman and the New York Pro-Choice Coalition held a press conference to rate the candidates on this question. In 1989 Hoffman also publicly challenged New York City's Cardinal John O'Connor 's support of Operation Rescue, which she deemed "violent to women" by organizing the first pro-choice civil disobedience action outside St. Patrick's Cathedral in New York City. Several hundred participated, and nine pro-choice protestors were arrested. In January 2022 she helped to found Rise Up 4 Abortion Rights ,

1740-486: The Issues became an online magazine, extending its reach even further. For both print and online editions, Hoffman wrote editorials on subjects ranging from her visit to San Francisco General Hospital's AIDS Unit in 1985 to a visit to a Rape Crisis Center in South Africa, and what is feels like to be an abortion provider in a time of attacks on clinics and murders of doctors. In 1990, she published an editorial in

1800-718: The NAF toll-free helpline, and French language website support. NAF has taken issue with the Canadian Medical Association 's (CMA) abortion referral policy which allows physicians to refuse to refer women to abortion providers in accordance with their conscience and CMA Policy - Induced Abortion. If pressed, a physician must indicate alternative sources where a woman might obtain a referral. NAF has lobbied to require Canadian physicians to opt out of provincial healthcare plans entirely if they do not refer for abortion. The National Abortion Federation of Canada provides

1860-785: The National Abortion Council (NAC). One of its founders was Frances Kissling , later president of Catholics for a Free Choice . NAF's headquarters in Washington, D.C. , were bombed in 1984. An explosive device attached to a propane tank outside of the building failed to explode, but detonated the propane tank, severely damaging the building. NAF filed a lawsuit against the Metropolitan Atlanta Rapid Transit Authority (MARTA) in 1999 for refusing to place NAF advertisements in MARTA buses. The public transit system had previously allowed advertisements from

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1920-645: The Summer 2009 edition. Hoffman's essay did "a brilliant job with a controversial subject," said syndicated columnist Lenore Skenazy , who presented the Opinion Writing Award to her at a dinner and ceremony in New York on Nov. 4, 2010. The 1995 Media Award from Community Action NW was given to On the Issues for "Exceptional Merit" for the article, "Let's Get Tough on Rape," A Discussion with Prosecutors Liz Holtzman and Alice Vachss by Hoffman. Hoffman

1980-533: The Supreme Court stated that the scope of federal injunctive relief is constrained by the limits on equitable remedies that existed in the English Court of Chancery around 1789. Injunctions in the United States tend to come in three main forms: temporary restraining orders, preliminary injunctions and permanent injunctions. For both temporary restraining orders and preliminary injunctions, the goal

2040-632: The U.S., and was its first president. She also founded the New York Pro-Choice Coalition in 1985. Hoffman is the publisher of On the Issues magazine , which began as a print publication in 1983 and then became an online publication in 2008. She was awarded the Front Page Award for Political Commentary in 2010 from the Newswoman's Club of New York . Hoffman was born in Philadelphia and raised in New York City . Initially intent on becoming

2100-403: The Woman Who Brought Abortion from the Back Alley to the Boardroom , Hoffman recounts how she was exposed to feminist activism at Queens College in the late '60s and early '70s. She attended a reading by the writer Anaïs Nin and later a lecture by Florynce Kennedy , "who spoke about lesbianism and abortion, giving the class one of her famous lines: 'If men could get pregnant, abortion would be

2160-552: The borough of Queens in NYC in the spring of 1971, two years before Roe v. Wade legalized abortion nationwide. Hoffman considered many standard medical practices of the day sexist, invasive, and paternalistic. In response, she developed many of the patient-centered tenets and practices that have since become standards of female and feminist healthcare and implemented them at Flushing Women's. Hoffman's theory of "Patient Power" led to such now-standard practices as having another staff member in

2220-540: The documentary film Abortion: A Different Light , and in 1986 she produced and hosted the first feminist TV show, MH: On the Issues , a syndicated 30-minute cable TV show. Her first guest was then-Congresswoman Bella Abzug. Others included Betty Friedan and Phyllis Chesler . A documentary film, 25 Years of Choices: Feminism from the Ground Up (1986), was produced to honor her and her work. Hoffman's writing has appeared in numerous publications and journals including

2280-488: The federal courts' power to issue injunctions that it effectively prohibited federal court from issuing injunctions in cases arising out of labor disputes. A number of states followed suit and enacted "Little Norris-LaGuardia Acts" that imposed similar limitations on state courts' powers. The courts have since recognized a limited exception to the Norris-LaGuardia Act's strict limitations in those cases in which

2340-475: The form of a special court order that compels a party to do or refrain from specific acts. "When a court employs the extraordinary remedy of injunction, it directs the conduct of a party, and does so with the backing of its full coercive powers ." A party that fails to comply with an injunction faces criminal or civil penalties , including possible monetary sanctions and even imprisonment . They can also be charged with contempt of court . The injunction

2400-413: The injunction was varied to permit reporting of the question. By long legal tradition, parliamentary proceedings may be reported without restriction. Parliamentary proceedings are covered by absolute privilege , but the reporting of those proceedings in newspapers is only covered by qualified privilege. Another example of the use of a super-injunction was in a libel case in which a plaintiff who claimed he

2460-432: The interests of non-parties (that is, the public interest). When deciding whether to give an injunction, and deciding what its scope should be, courts give special attention to questions of fairness and good faith. One manifestation of this is that injunctions are subject to equitable defenses, such as laches and unclean hands . Injunctions are given in many different kinds of cases. They can prohibit future violations of

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2520-616: The late nineteenth and early twentieth century, federal courts used injunctions to break strikes by unions. For example, after the United States government successfully used an injunction to outlaw the Pullman boycott in 1894 in In re Debs , employers found that they could obtain federal court injunctions to ban strikes and organizing activities of all kinds by unions . These injunctions were often extremely broad; one injunction issued by

2580-462: The law, such as trespass to real property, infringement of a patent, or the violation of a constitutional right (e.g., the free exercise of religion). Or they can require the defendant to repair past violations of the law. An injunction can require someone to do something, like clean up an oil spill or remove a spite fence . Or it can prohibit someone from doing something, like using an illegally obtained trade secret. An injunction that requires conduct

2640-473: The law." In 2016, Orrick issued a preliminary injunction against CMP blocking the release of their videos; after Daleiden violated the injunction, Orrick found Daleiden and his two attorneys in civil contempt and fined them $ 195,000. The contempt finding was upheld on appeal. Orrick awarded NAF $ 6.3 million in legal fees in 2021 after he refused to dismiss the lawsuit; he awarded NAF an additional $ 700,000 in legal fees in 2024. Physician Phillip G. Stubblefield

2700-770: The management of public schools in order to ensure compliance. (An injunction that puts a court in the position of taking over and administering an institution—such as a school, a prison, or a hospital—is often called a " structural injunction ".) Injunctions remain widely used to require government officials to comply with the Constitution, and they are also frequently used in private law disputes about intellectual property, real property, and contracts. Many state and federal statutes, including environmental statutes , civil rights statutes and employment-discrimination statutes , are enforced with injunctions. In Grupo Mexicano de Desarrollo, S.A. v. Alliance Bond Fund, Inc. (1999),

2760-502: The order. If the TRO is contested, the court must decide whether to issue a preliminary injunction. Temporary restraining orders are often, but not exclusively, given to prevent domestic violence, stalking, sexual assault, or harassment. Preliminary injunctions are given before trial. Because they are issued at an early stage, before the court has heard the evidence and made a decision in the case, they are more rarely given. The requirements for

2820-430: The patent holder must license on reasonable and non-discriminatory terms . There is an ongoing debate among legal and economic scholars with major implications for antitrust policy in the United States as well as in other countries over the statutory limits to the patent holder's right to seek and obtain injunctive relief against infringers of standard-essential patents. Citing concerns of the absence of competition facing

2880-511: The patent holder once its technology is locked-in to the standard , some scholars argue that the holder of a standard-essential patent should face antitrust liability when seeking an injunction against an implementer of a standard. Other scholars assert that patent holders are not contractually restrained from pursuing injunctions for standard-essential patent claims and that patent law is already capable of determining whether an injunction against an infringer of standard-essential patents will impose

2940-512: The person online. A court may issue the order if it believes a person has reasonable grounds for their fears or has no reasonable grounds for their fears. Non-compliance may result in the imposition of a fine, imprisonment, or both, and deportation. Interim injunctions are a provisional form of injunctive relief, which can compel a party to do something (mandatory injunction) or stop it from doing something (prohibitory injunction). A plaintiff seeking an interim injunction must establish that he

3000-581: The reason for prescribing certain medications. Her work was noted by Francis X. Clines in The New York Times as "making women feel powerful." In November, 1974, Hoffman was the initiator and moderator for New York City's first Women's Health Forum, with speakers including Barbara Ehrenreich and Congresswoman Bella Abzug . In 1975, Hoffman helped develop and introduce a program to diagnosis women with breast cancer in an outpatient center. The program, known as STOP (Second Treatment Option Program),

3060-499: The room with the doctor and patient at all times and developing the concept of informed consent; having other women counselors rather than doctors provide emotional support and answer patients' questions during abortions; and using patients' abortion-based clinic visits as an opportunity to provide sexual health education as well as counseling on birth control options. Hoffman was also among the first to urge women to question their doctor about everything from their training and background to

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3120-648: The standards for abortion procedures. First published in 1996 and revised annually, the CPGs distill a large body of medical knowledge into guidelines developed by consensus, based on rigorous review of relevant literature and known patient outcomes. NAF indicates that "In order to become a member, a clinic must complete a rigorous application process. Member clinics have agreed to comply with our standards for quality and care, updated annually in our Clinical Policy Guidelines. NAF periodically conducts site visits to confirm that our clinics are in compliance with our guidelines." NAF

3180-543: The use of super-injunctions revealed that only two super-injunctions had been granted since January 2010. Many media sources were wrongly describing all gagging orders as super-injunctions. The widespread media coverage of super-injunctions led to a drop in numbers after 2011; however four were granted in the first five months of 2015. Injunctions defined by the European Commission as injunctions which can be issued for instance in cases in which materially

3240-525: Was defamed by family members in a dispute over a multimillion-pound family trust obtained anonymity for himself and for his relatives. Roy Greenslade credits the former editor of The Guardian , Alan Rusbridger , with coining the word "super-injunction" in an article about the Trafigura affair in September 2009. The term "hyper-injunction" has also been used to describe an injunction similar to

3300-653: Was honored for her work by New York City Mayor Ed Koch and the Mayor's Volunteer Action Center in appreciation of "dedicated volunteer service" and the Department of Corrections of New York City (July 10, 1984); Friends of Animals/Eco-Visions Conference (1994). Hoffman's Archive Collection, which features the On the Issues back catalog, CHOICES documents, and thousands of pages on the Reproductive Rights movement

3360-487: Was named president and CEO in 2023. Merle Hoffman Merle Hoffman (born March 6, 1946) is an American journalist and activist. Shortly after New York State legalized abortion in 1970, three years before the Supreme Court's Roe v. Wade decision legalized abortion nationally, Hoffman helped establish one of the country's first ambulatory abortion centers, Flushing Women's Medical Center in 1971. It

3420-506: Was one of the NAF's early presidents. Abortion counselor Glenna Halvorson-Boyd served as NAF's president from 1984 to 1986. Former union leader Vicki Saporta served in the position from 1995 to 2019; she announced her retirement in 2018 after being accused of not taking action when an employee was guilty of sexual harassment. Katherine Hancock Ragsdale , an Episcopal priest, was interim president and CEO from September 2018 to October 2021. The position remained unfilled until Brittany Fonteno

3480-435: Was pathbreaking; prior to its inception women were not consulted as to their diagnosis or treatment options. Previously, doctors had simply removed the breast of any woman whose biopsy came back positive while she was still anesthetized and before she had the opportunity to learn about her options or make decisions. When Hoffman learned about the lack of birth control options available to women in Russia, she organized and led

3540-501: Was the forerunner of Choices Women's Medical Center which Hoffman founded and serves as president and CEO. Choices is a full-service healthcare provider, offering gynecological services, pre-natal care, family care, transgender health care, telemedicine , mental health and other services. Hoffman co-founded the National Abortion Federation in 1976, the first professional organization of abortion providers in

3600-606: Was the super-injunction raised in September 2009 by Carter-Ruck solicitors on behalf of oil trader Trafigura , prohibiting the reporting of an internal Trafigura report into the 2006 Ivory Coast toxic waste dump scandal. The existence of the super-injunction was revealed only when it was referred to in a parliamentary question that was subsequently circulated on the Internet ( parliamentary privilege protects statements by MPs in Parliament which would otherwise be held to be in contempt of court). Before it could be challenged in court,

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