Hannah Haskins, Wake Forest University School of Law JD ’26Refusing Complicity:
A persistent pounding at her office door wakes Marta Delgado from a dead sleep. She jerks upright, peeling a loose paper from the side of her face. She tries to smooth the sleep lines from her cheek, but her supervisor’s raised eyebrow when she opens the door speaks for itself.
“New cases just came in for you.” Her supervisor pushes a stack of files into her hands and turns to leave, not one for excessive chatter.
“Wait! I’m already working almost eighty hours a week1—”
“And?”
“—and I don’t get paid overtime.2 I can’t take another case right now.”
“No problem. I’ll tell the grieving families downstairs that you’re too busy napping to do your job.”
Marta sighs. She had gotten called back to the hospital at four that morning, and now the sun had long since set. With no other choice, Marta returns to her office and shuts the door firmly behind her.
She flicks open the first file and with each turn of a page, fragments of a life begin to take shape. Sarah Miller, thirty-five years old, history of health complications, left in a persistent vegetative state after a sudden stroke. Currently twenty-eight weeks pregnant.
Marta stops reading and flips until she finds the page she needs. Sarah’s advance directive is detailed, with clear instructions rejecting life-sustaining treatments. Marta pushes her glasses up the bridge of her nose and exhales slowly, resigned to an unpleasant conversation with the Miller family.
Something catches her eye. In neat handwriting, Sarah Miller has outlined her wishes for this exact scenario.
In the event that I become incapacitated while pregnant, please disregard the above instructions if there is a chance the baby could reach viability and be born without significant complications. In that case, I want life-sustaining treatments only until the baby is safely delivered.
It’s not like the great state of Illinois gave you much of a choice, Marta thinks bitterly.3 She finishes reading Sarah’s file and mentally prepares herself to meet the family.
Half an hour and a cup of coffee later, Marta has made her way to the ICU. She hears the muffled sobs before she sees any of the family members. She takes a deep breath before rapping gently on the door.
“Come in,” a quavering voice calls out. A young woman sits in a narrow folding chair beside the bed, clasping Sarah’s hand.
“Are you Jane Miller?” Marta asks.
The woman nods without looking away from her wife.
“I’m Marta,” she says gently, taking the empty seat next to the woman. “I’m a social worker here at the hospital. My job is to make sure Sarah, and her family, get all the care they need.” Marta doesn’t try to shake Jane’s hand or otherwise intrude on her grief.
After a few moments of silence, Jane says, “Her parents just went home to get some sleep.”
“When’s the last time you slept?” Marta asks.
Jane snorts mirthlessly, “About thirty minutes ago.”
“When’s the last time you slept in a bed? Or ate something?”
“I’m not leaving her here alone.” Jane sets her jaw and looks at Marta for the first time since she entered the room.
“You won’t be leaving her alone,” Marta replies quietly. “I’ll sit with Sarah while you shower and get something to eat. I can tell you’re going to fight me on sleep, but that’s okay, we can start small.”
Jane exhales shakily, “You really won’t leave her?”
“Barring a medical emergency, I will not leave her side.” Marta promises.
When Jane returns from the hospital cafeteria, Marta is still perched next to Sarah, making notes in an open file on her lap.
“Better?”
“Marginally,” Jane sits and gets straight to business. “So, what are you doing here?”
“Well, whenever you’re ready, there are a few details about Sarah’s advance directive that we should go over.”
Jane nods as if to say, go on.
“Did she ever discuss her advance directive with you?”
“I was there when she filled it out. We made sure we had all that kind of stuff done before we had kids.”
“That was smart—a lot of people don’t consider what they want at the end,”4 Marta says. “So, Sarah specified that she wanted life-sustaining treatments only if she became incapacitated while pregnant. Because she’s about twenty-eight weeks along, hospital policy is to continue life-support until at least thirty-two weeks unless there are signs of fetal distress.”
“What if that happens before thirty-two weeks?” Jane asks.
“Most likely, the doctors will try to deliver early. I know that Sarah’s advance directive requests life-support only if the baby can be delivered without significant complications, but in Illinois—”
Jane lets out a sharp exhale. “We knew when we filled it out that Illinois generally invalidates pregnant patients’ advance directives, but we weren’t sure about the viability part. I guess we just wanted to be prepared for everything. We tried for a baby for so long and with Sarah’s past health issues we just didn’t want to take any risks,” Jane swipes angrily at the tears that have reemerged. “I know what you’re thinking. Why didn’t I carry the baby, right? I tried so many times and it just never…I couldn’t…if my body just worked the way it’s supposed to then we wouldn’t even be here right now.”
“I wasn’t thinking that at all,” Marta states truthfully. “There is nothing wrong with you. This isn’t your fault.”
Jane shakes her head, on the verge of hyperventilating. She can’t speak.
“I need you to take a few deep breaths with me,” Marta says gently. “Is it okay if I touch your hand?”
Jane nods, sobs still lodged in her throat.
Marta takes Jane’s hand. “Okay, inhale as deep as you can.”
Jane takes a shallow inhale and her breathing stutters.
“That’s okay, try again,” Marta waits for Jane to take a bigger breath. “Okay, now exhale slow as you can and squeeze my hand.”
They sit like that for several minutes before Jane’s breathing returns to normal. Marta stays with her a while longer before finally convincing Jane to get some sleep. A nurse comes in to set up a small cot and Marta leaves with a promise that she’ll return in a few hours.
Back in the sanctity of her office, Marta tries to distance herself from the emotional weight of the scene downstairs before opening another file. Marta flips to the first page of Emily Hayes’ file. This can’t be happening. Emily Hayes, twenty-six years old, no history of health complications, declared brain dead after an accident. Currently sixteen weeks pregnant.
“Please, please, please.” Marta mutters to herself, frantically searching for an advance directive. She finds the page and nearly throws the file across the room.
I want this advance directive to apply to all medical situations, including pregnancy. I do not want to be kept artificially alive even if I am pregnant.
In her twenty years as a social worker, Marta has dealt with a few cases like Emily’s, and they always leave deep scars. Telling a family that their loved one will never wake up always takes its toll. But delivering a bill for unwanted long-term care in the hopes that an embryo will reach viability adds insult to injury. Having two of these cases reach her desk on the same day is almost more than Marta can stomach. At least Sarah opted for life-sustaining treatments in the event of pregnancy, even if the state never really gave her a choice.
Marta looks out the window into the inky night sky. The moon had risen high over the trees while she was with Jane and Sarah. Maybe Emily’s family will be asleep so I can put this off until tomorrow. Marta downs another cup of coffee and takes the long walk to the ICU like she’s being led to the gallows.
Marta senses her own impending doom within seconds of meeting Emily’s mother. There are no tears in Deborah Hayes’ eyes. Instead, barely contained rage flickers in their depths. Marta makes a snap judgment to cut straight to the point, but she’s interrupted before she gets there.
“Hello, I’m Marta, the social worker assigned to—”
“We don’t need a social worker,” Deborah snaps. “We just need someone to tell us what happens next. Why hasn’t Emily been taken off the ventilator?”
“I’m just here to make sure everyone’s needs are being met, and all the little procedural steps are being taken care of.” Marta says, and the tension in the room snaps taut.
“What needs? My daughter is dead,” Deborah’s voice is raw, but she still doesn’t cry. “Let’s just get this over with.”
Marta understands implicitly that Deborah’s callous demeanor is simply covering for the fact that this woman is on the brink of utter collapse. She just can’t let herself fall apart in front of a bunch of strangers. “Emily’s advance directive lists you as her agent, did you ever discuss Emily’s wishes for end-of-life care?”
“Obviously,” Deborah bites out, volume rising. “I’m standing here telling you to turn off the ventilator, aren’t I? Why isn’t anyone doing anything!”
“Well, Emily is pregnant—”
“What does it matter? It’s not like the baby can be delivered, Emily is only four months pregnant.”
Marta braces herself internally for what comes next. “Under Illinois law, pregnancy…changes things in terms of advance directives.”
Face growing redder by the second, Deborah snarls, “What the HELL does that mean?”
“It means that if the doctors determine that the pregnancy can continue with support, the directive becomes temporarily invalid.” Marta says, gently.
Deborah stares at her without blinking. Then, she explodes, voice echoing sharply off the linoleum. “No. No! Absolutely not. I will not have my daughter’s body used as an incubator!”
Marta starts to speak, to explain that it isn’t optional, but Deborah’s shouts drown her out.
“She WROTE IT DOWN! SHE WROTE DOWN WHAT SHE WANTED! You don’t get to decide that it doesn’t count!”
Everyone at the nurses’ station pretends otherwise, but they are all listening intently. “I don’t get to make medical decisions,” Marta keeps her voice calm and placating. “If I did, your daughter’s final wishes would be honored. I’m just here to help you navigate this process.”
For a moment, Marta thinks Deborah might take a swing at her. Instead, Deborah’s voice lowers and fills with venom, “The only help I want from you is in turning those damn machines OFF. You think that just because you’re following a law that what you’re doing is right?” She looks at Marta with unadulterated contempt. Then, she turns on her heel and storms off towards the elevators.
Marta releases a breath she didn’t realize she was holding.
The door to Emily’s room creaks open and a young man, maybe nineteen or twenty, steps out. He looks distraught and sheepish all at once. “Sorry, I probably should’ve stepped in before she really got going.”
Marta resists the urge to snort. “That’s alright, emotions are running high. You mind if I come in for a minute?” She gestures past him to the chairs by the bed.
He steps out of the way and takes the seat closest to Emily. “I’m Ethan, Emily’s brother. I know my mom wasn’t very…receptive, but we could really use your help.”
“Of course, that’s what I’m here for. Is there anything I can do for you or your mom right now?”
Ethan hesitates. “My mom made both of us fill out those form things last year. Her friend’s daughter said something about including whether the directive applies during pregnancy.”
“Do you know where the friend lives?” Marta prods, gently.
“Somewhere in Florida. Tampa, maybe?”
Everything clicks into place in Marta’s head. “Florida and Illinois have different laws. In Florida, the directive is honored if the patient specifies that it applies during pregnancy.”5
Ethan shakes his head, looking confused. “Why does it matter? Like why fill out the form at all if the government can just decide it doesn’t count?”
“I’m no lawyer, but I think the official explanation is that the government has an interest in potential life.”6
“Potential life?” Ethan’s brows furrow. “What about my sister’s life? Why isn’t she more important?” His voice breaks and he looks away, furtively brushing at his eyes with the sleeve of his sweatshirt.
Marta pretends to study the room while Ethan gathers himself. “I don’t know,” She answers honestly. “Between you and me, sometimes I think it has more to do with control than valuing life.”
“That doesn’t seem right. Why doesn’t anyone do something to change it?”
“A lot of people are working to change things. Washington actually just removed the pregnancy exclusion from its advance directive law.7 It just takes time and dedication.”
When Ethan speaks next, his voice is small, almost childlike in its innocence. “It’s not fair.”
“No, it isn’t. You and your mom have every right to be angry and upset.”
Ethan nods, jaw tight. For a moment, they sit in silence, the unwanted machines whirring with artificial life in the background.
Marta stands, knees popping as she straightens. “You don’t have to do any of this alone. I hope your mom understands that. I’m here to advocate for Emily and your family however I can. There’s just nothing I can do about the law right now.”
Ethan exhales slowly—not quite in relief, more like he’s no longer carrying the weight of everything by himself.
Marta’s hands are shaking by the time she reaches her car. She can’t quite get her key in the ignition. After a few tries, her forehead hits the steering wheel, and she releases a shuddering breath. She breathes slowly until the burning in her chest eases a little. Finally, she’s able to start the car. The clock on the dash reads four in the morning. She hasn’t breathed air outside the hospital for twenty-four hours. She makes eye contact with herself in the mirror and finally admits something to herself. I can’t keep doing this.
Later that morning, Marta walks back into the ICU to an unexpected scene. Jane Miller and two people who must be Sarah’s parents are sitting in the small waiting area with Deborah Hayes.
“…and she was stubborn. God, she was stubborn,” Deborah lets out a watery chuckle. “That’s what really kills me—how much she would’ve hated all this. She was so excited to be a mom, but she would’ve hated that it happened this way.” Deborah stops talking when she sees Marta.
Marta introduces herself to Sarah’s parents, offering comfort and a steady presence. They seem dazed, like they aren’t sure if they’re looking at a mirage. She sits next to Jane and listens to the parents tell stories about Sarah and Emily—their funny, kind, smart daughters. Underneath it all, she feels the gravity of their losses.
Sometime later, after the Millers have wandered back to Sarah’s bedside, Deborah finally looks at Marta.
“I’m sorry I raised my voice at you last night; I know that none of this is your fault.”
“Thank you, that’s kind of you to say. I know it was a terrible shock. Is there anything I can do for you right now?”
Deborah clears her throat, like she wasn’t expecting compassion. “Sarah’s dad, Joe I think he said, gave me a phone number for a lawyer.”
Marta nods slowly, careful not to get the other woman’s hopes up with her response. “That’s good, it can never hurt to talk to someone who understands the legal side of things.”
Deborah swallows hard, eyes flicking away to some point in the distance. “Do you think…Will it change anything?”
Marta hesitates. “I think it can give you some clarity if nothing else. But I don’t want to promise that this will fix a broken system.”
Deborah’s face falls in disappointment, but not surprise. “Figured that might be the case.”
“You’re fighting as hard as you can for what Emily wanted,” Marta says quietly. “That’s not nothing.”
In the weeks that follow, Marta juggles old and new cases, going through the administrative motions that keep the hospital functioning. She visits them every day, the patients and their families. Sometimes for just a few moments, sometimes longer. She’s pleasantly surprised to see the two families huddled together most days. Grief settles unwillingly into routine.
Almost four weeks after her supervisor handed her those files, Deborah Hayes hands her another stack of papers. She takes a seat in the small waiting room and begins to read.
PLAINTIFF’S PETITION FOR DECLARATORY JUDGMENT AND APPLICATION FOR EXPEDITED RELIEF8
FACTS
- On March 2, 2024, Emily Hayes completed an advance directive which clearly states that in the event of brain death, she does not wish to receive life-sustaining treatments under any circumstances. Emily specified that these instructions applied even during pregnancy.
- On October 28, 2025, around 8:00 P.M., Emily Hayes’s car was struck by another vehicle at the intersection of Elm Street and Cherry Road. She was sixteen weeks pregnant at the time. A bystander called 911 and attempted cardiopulmonary resuscitation.
- Emily was transported to Lakeshore Medical Center. At 3:00 A.M. on October 29, 2025, doctors declared Emily Hayes brain-dead.
- Despite her wishes, doctors placed Emily on a ventilator and have been administering life-sustaining treatments ever since. Deborah Hayes, Emily’s healthcare surrogate, communicated Emily’s wishes to Lakeshore Medical Center and requested that she be taken off life support. Lakeshore staff refused, citing 755 ILCS 35/3(c)9 as the basis for their decision.
- 755 ILCS 35/3(c) states that “The declaration of a qualified patient diagnosed as pregnant by the attending physician shall be given no force and effect as long as in the opinion of the attending physician it is possible that the fetus could develop to the point of live birth with the continued application of death delaying procedures.”10
- The fetus suffered a prolonged period of hypoxia before Emily was resuscitated, rendering long-term survival unlikely. Combined, the early stage of fetal development and the nature of the injuries ensure that the fetus will suffer severe complications in the unlikely event that a live birth becomes possible. Forcing continued somatic care is no longer rationally related to fetal welfare in this case.
- In this case, 755 ILCS 35/3(c) unnecessarily prolongs the suffering of a family already grieving their deceased loved one. Lakeshore Medical Center’s compliance with this statute subverts the legislative intent in preserving potential life.
- Alternatively, 755 ILCS 35/3(c) is unconstitutional as applied to Emily pursuant to the Fourteenth Amendment to the U.S. Constitution.11
- Deborah Hayes requests that this Court order Lakeshore Medical Center to discontinue life-sustaining treatments and allow the family to lay Emily Hayes to rest.
Marta flips to the next document and her disappointment sinks like a stone in her chest.
ORDER DENYING PLAINTIFF’S PETITION FOR DECLARATORY JUDGMENT AND APPLICATION FOR EXPEDITED RELIEF12
This matter coming on to be heard and being heard before the undersigned Judge Presiding, the Court, having reviewed the court file and heard arguments of counsel, finds as follows:
- Plaintiff seeks enforcement of Emily Hayes’s advance directive via withdrawal of life-sustaining treatments.
- The record reflects that fetal cardiac activity remains detectable and that the attending physicians cannot presently make a determination of non-viability.
- Pursuant to 755 ILCS 35/3(c), an advance directive “shall be given no force and effect as long as in the opinion of the attending physician it is possible that the fetus could develop to the point of live birth with the continued application of death delaying procedures.”13
- While this mandate places a heavy burden on the family, the statutory language is clear and unambiguous.
- Accordingly, Plaintiff’s request for declaratory and expedited relief is DENIED.14
When she finishes reading, Marta says nothing. She has no words for this situation. She shakes her head and mourns with Deborah.
The delivery takes place just before dawn a few weeks later. The entire floor feels like it’s holding its breath, hushed and reverent. The obstetrics team moves fast after the latest infection wreaks havoc on the patient’s body. Marta watches from the corridor as the NICU staff place the tiny infant—Sarah and Jane’s daughter—in an isolette and carefully maneuver toward the elevator.
When the sun has risen high over the hospital, Sarah is extubated and the machines, which have been whirring relentlessly for weeks, fall silent. Marta looks away as the family collapses in on itself. Her eyes flick over to where Ethan and Deborah sit in the waiting room, feeling the confusing mix of joy and grief just as acutely. Parallel losses that leave them all hollow.
When it’s over, Marta shuts herself in her office and sags under the impossible weight of it all. She decides that Emily Hayes will be her last case.
OBITUARY
Emily Catherine Hayes, 26, passed away on December 15 at Lakeshore Medical Center, together with her unborn daughter, following complications from an accident. Born and raised in Chicago, Emily will be remembered for her kindness, her quick wit, and her steadfast devotion to her loved ones. Emily is survived by her mother Deborah and her brother Ethan. A private memorial will be held on a later date.
Marta hands in her ID badge a week later. Her resignation letter is brief, but poignant. She simply explains that she cannot continue to square her ethical beliefs with a system that denies patients’ autonomy. Really, her decision was a foregone conclusion. After twenty years, the exhaustion has caught up with her. She walks out with a strange feeling of lightness and doesn’t look back.
Refusing Complicity: A Social Worker’s Account of Pregnancy Exclusions in Practice
by Marta Delgado
Something we never seem to acknowledge in healthcare spheres is the understated violence of pregnancy-exclusion statutes. We must grapple with the fact that these laws erase the autonomy of pregnant persons under a paternalistic guise. Legislators reduce these patients, already so vulnerable, to mere vessels for the state’s purported interests.
Over the past few months, I have watched two families navigate this tragic system in different ways. One lost a daughter whose advance directive was honored only because her wishes happened to align with the state’s. The other was kept in limbo while doctors argued over viability. Both families were forced to confront the fact that the law treated the people they loved as afterthoughts to “potential life.”
We must work to repeal these pregnancy exclusions. We know it can be done, just look at Washington and Colorado.15 Scholars like Joan Krause even propose a Pregnancy Advance Directive, a “targeted medical form addressing a patient’s wishes in the case of decisional incapacity during pregnancy, which could be completed only after the patient has become pregnant.”16 Healthcare providers shouldn’t be forced to choose between breaking the law or upholding the dignity and autonomy of their patients.
These patients deserved more than what the law can currently provide. They were more than incubators or organic life-support systems. We can’t change the fact that one family’s grief was unnecessarily extended by the state’s desire for control. But we can prevent more pregnant patients, more families from suffering the devastating denial of autonomy and basic human dignity.
One Year Later
Dear Marta,
I’ve wanted to write to you for months, but I couldn’t seem to find the right words. I always thought of grief as something sharp and swift. It turns out, it’s more like creeping ivy. Some days it’s a choking, all-consuming force. And other times it gets all tangled up with the happy memories. I go back and forth on which I’d rather face.
I guess I just wanted you to know that we’re still here, still fighting. Ethan and I started an advocacy group for families like ours. It’s all online, so Ethan and Jane handle most of the logistics. We meet twice a month and organize things like letter-writing campaigns and protests. There’s only about fifteen of us so far, but it feels like a start.
We still see Sarah’s family every few weeks, and they’ve been helping with the meetings. The baby is already walking! Poor Jane has been a nervous wreck chasing that girl around the house. I can’t fault her though; I did the same with Emily.
I finally read your op-ed in the Lakeshore Chronicle. I know we discussed all the details beforehand, but it still knocked the wind out of me to see Emily’s story out in the world. I hope it can help change things, or at least make other families feel less alone. Really, I just wanted you to know that your presence in our lives made a difference. Even though you couldn’t change the outcome, you stood by us. That mattered more than you know.
–Deborah
P.S. Jane asked me to pass along the photo.
Marta opens the envelope and fishes out a photo of both families. It’s slightly blurry and someone’s thumb is clearly visible in the bottom corner, but Marta smiles all the same. She sets the photo down on her new desk and starts the next chapter.
- Since COVID-19, healthcare social workers (HSW) have experienced not only increased workloads, but expansions in the scope of their practice. Among many other responsibilities, HSWs must provide psychosocial support for patients and their families, become experts in medical fields related to patient needs, and handle administrative duties such as discharge planning. With heavy caseloads and expanded duties, HSWs are at high risk of burnout and psychological distress. Oluwaseun A. Aladesuru et al., Healthcare Social Workers’ Scope of Practice during COVID-19, 12 Healthcare 174 (2024). ↩︎
- Many HSWs are required to have a Master of Social Work, which could exempt them from overtime pay. As a result, many salaried HSWs work far more than forty hours per week without fair compensation. U.S. Dep’t of Labor, Wage & Hour Div., Fact Sheet #17D: Exemption for Professional Employees Under the Fair Labor Standards Act (FLSA), https://www.dol.gov/agencies/whd/fact-sheets/17d-overtime-professional (last visited Nov. 28, 2025). ↩︎
- Nineteen states, including Illinois, invalidate a pregnant patient’s advance directive if there is a possibility of fetal survival with continued life-sustaining treatments. Ten states invalidate a pregnant patient’s advance directive without considering the likelihood of fetal survival. Pregnancy Exceptionalism: A Review of Restrictions on Advance Directives, https://www.pregnancyjusticeus.org/wp-content/uploads/2025/06/advanced-directives.pdf (last visited Nov. 28, 2025). ↩︎
- A study conducted in 2017 found that only one in three adults in the U.S. has any kind of advance directive for end-of-life care. I’ve included this because I think that pregnancy exclusions often get overlooked in academic scholarship in part because advance directives are not very widely used. Susan E. Nelson, What Doctors Wish Patients Knew About End-of-Life Care Planning, Am. Med. Ass’n (Nov. 25, 2025), https://www.ama-assn.org/public-health/population-health/what-doctors-wish-patients-knew-about-end-life-care-planning. ↩︎
- Three states (Florida, Oklahoma, and Minnesota) honor a pregnant patient’s advance directive as long as it clearly states that it applies during pregnancy. Pregnancy Exceptionalism: A Review of Restrictions on Advance Directives. ↩︎
- Dobbs v. Jackson Women’s Health Org., 597 U.S. 215 (2022) (recognizing state interest in potential life) ↩︎
- If/When/How: Lawyering for Reprod. Just., Pregnancy Exclusion Laws Deny Pregnant People End-of-Life Decision-Making, https://ifwhenhow.org/resources/pregnancy-exclusion-laws-deny-pregnant-people-end-of-life-decision-making/ (last visited Nov. 26, 2025). ↩︎
- In the interest of sticking to the word count, I’ve written a small excerpt of what a petition like this might look like. The change in font is intentional. This is loosely based on the Plaintiff’s petition in Munoz v. John Peter Smith Hosp., No. 096-270080-14, 2014 WL 285057 (Dist. Ct. Tex. Jan. 23, 2014). ↩︎
- 755 Ill. Comp. Stat. Ann. 35/3(c) (West 2007). ↩︎
- Id. ↩︎
- This is also loosely based on arguments made in the Plaintiff’s petition in Munoz and in Almerico v. Denney, 532 F. Supp. 3d 993 (D. Idaho 2021). I thought it would be interesting to include as a nod to the pre-Dobbs era and to foreshadow the court’s decision in this fictional case. ↩︎
- This is similarly intended to be an excerpt from a longer decision. This is loosely based on proposed court orders I’ve written for work. ↩︎
- 755 Ill. Comp. Stat. Ann. 35/3(c) (West 2007). ↩︎
- I chose to depart from the Muñoz and Almerico decisions to reflect the changes in law and policy post-Dobbs. ↩︎
- In Washington, HB 1215 was signed into law on April 16, 2025, effectively repealing the state’s statutory pregnancy exclusion clause. In 2021, Colorado passed SB 193, removing the pregnancy exclusion from its advance directive law. I included these because it’s important to acknowledge even the smallest of victories. Compassion & Choices, Pregnancy Exclusions, https://compassionandchoices.org/resource/pregnancy-exclusions/ (last visited Nov. 26, 2025). ↩︎
- Joan H. Krause, Pregnancy Advance Directives, UNC Sch. of L. Faculty Publications (2023). ↩︎
Awaken 