For many, whether the right is the physician’s or the woman’s is of no practical consequence. The campaign for legal abortion has always been pre- mised on the still largely unquestioned assumption that only legal abortions are safe abortions because they are performed by physicians, who are licensed (and therefore presumably skilled), rather than by the notorious “back-alley abortionists” (who are presumably untrained and unskilled). For many people, to imagine abortions performed by nonphysicians is to conjure nightmares of bloody coat hangers, turpentine or lye ingestion, and other “home remedies” leading to injury and even death.’ Thus, while pro-choice advocates have repeatedly challenged almost every other restriction that state and federal governments have attempted to place on the performance of abortions, physician requirements have never provoked the same aggressive litigation and advocacy. In fact, in cases like Menillo, where a state prosecuted a non- physician for performing an unauthorized abortion, pro-choice legal organizations have shown an uncharacteristic silence on the issue.”