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Plaintiffs' Brief in Response to All Defendants Motions to Dismiss

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Plaintiffs' Brief in Response to All Defendants Motions to Dismiss Electronically Filed 2021-02-17 16:41:44 STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF WAKE CASE NO. 20 CVS 500147 PLANNED PARENTHOOD SOUTH ATLANTIC, on behalf of itself, its physicians and staff, and its patients; et al., Plaintiffs, PLAINTIFFS’ BRIEF IN OPPOSITION TO v. ALL DEFENDANTS’ TIMOTHY K. MOORE, as Speaker of the North MOTIONS TO DISMISS Carolina House of Representatives, in his official capacity; et al., Defendants. TABLE OF CONTENTS TABLE OF AUTHORITIES ......................................................................................................... iv INTRODUCTION .......................................................................................................................... 1 BACKGROUND ............................................................................................................................ 2 STANDARD OF REVIEW ............................................................................................................ 3 ARGUMENT .................................................................................................................................. 4 I. This Court Has Subject Matter Jurisdiction ........................................................................ 4 A. Plaintiffs Have Standing ......................................................................................... 4 1. Plaintiff Providers Have Standing in Their Own Right .............................. 5 a. Plaintiff Providers Have Suffered a Direct Injury Sufficient to Confer Individual Standing ............................................................. 6 b. Plaintiff Providers Intend to Engage in the Prohibited Course of Conduct but for the Abortion Restrictions ...................................... 7 c. Plaintiff Providers Credibly Fear Enforcement of the Abortion Restrictions ..................................................................................... 8 2. Plaintiff Providers Have Third-Party Standing on Behalf of Their Patients ................................................................................................................... 11 a. Plaintiff Providers Have Suffered an Injury ................................. 12 b. Plaintiff Providers Have a “Close Relationship” with Patients Seeking Abortion .......................................................................... 13 c. Patients Seeking Abortion Would Face a Hindrance to Asserting Their Own Rights .......................................................................... 14 3. SisterSong Has Associational Standing .................................................... 15 a. SisterSong Members Have Standing to Sue in Their Own Right . 16 b. There Is No Need for SisterSong’s Individual Members to Participate in the Lawsuit .............................................................. 17 B. Plaintiffs’ Claims Are Redressable by the Relief Sought ..................................... 18 C. Plaintiffs’ Claims Are Ripe for Review ................................................................ 20 ii D. Plaintiffs Raise Constitutional, Not Political, Questions ...................................... 21 II. Plaintiffs Adequately State Claims upon Which Relief Can Be Granted ......................... 23 A. Abortion Is a Fundamental Right Under the North Carolina Constitution ........... 24 B. Plaintiffs Adequately Pleaded Their Substantive Due Process Claims Under the North Carolina Constitution .................................................................................. 26 1. Plaintiffs Adequately Pleaded the Abortion Restrictions Fail Strict Scrutiny ..................................................................................................... 26 a. Plaintiffs Adequately Pleaded the APC Ban Is Not Narrowly Tailored to Further a Compelling State Interest ........................... 27 b. Plaintiffs Adequately Pleaded the Telemedicine Ban Is Not Narrowly Tailored to Further a Compelling State Interest ........... 28 c. Plaintiffs Adequately Pleaded the TRAP Scheme Is Not Narrowly Tailored to Further a Compelling State Interest ........................... 29 d. Plaintiffs Adequately Pleaded the 72-Hour Mandatory Delay and Biased Counseling Requirement Are Not Narrowly Tailored to Further a Compelling State Interest .............................................. 30 2. Plaintiffs Adequately Pleaded the Abortion Restrictions Fail the Undue Burden Test ............................................................................................... 32 C. Plaintiffs Adequately Pleaded Their Equal Protection Claims Under the North Carolina Constitution ............................................................................................ 34 1. North Carolina Courts Review Equal Protection Challenges Under Three Tiers of Scrutiny ....................................................................................... 34 2. Plaintiffs Adequately Pleaded Their Equal Protection Claims Under Any Standard of Review ................................................................................... 35 D. Plaintiff Providers Sufficiently Pleaded the APC Ban, Telemedicine Ban, and TRAP Scheme Violate Their Rights to the Fruits of their Labor and to Pursue Their Livelihoods .................................................................................................. 38 E. Plaintiffs Adequately Pleaded the Abortion Restrictions Are Facially Unconstitutional .................................................................................................... 40 CONCLUSION ............................................................................................................................. 43 iii TABLE OF AUTHORITIES Cases Page(s) 520 S. Mich. Ave. Assocs., Ltd. v. Devine, 433 F.3d 961 (7th Cir. 2006) ............................................................................................ 16 Adams & Boyle, P.C. v. Slatery, No. 3:15-cv-00705, 2020 WL 6063778 (M.D. Tenn. Oct. 14, 2020) ............................... 33 Affordable Care, Inc. v. N.C. State Bd. of Dental Exam’rs, 153 N.C. App. 527, 571 S.E.2d 52 (2002) ............................................................ 26, 38, 41 Armstrong v. State, 296 Mont. 361, 989 P.2d 364 (1999) ................................................................................ 31 Arnesen v. Rivers Edge Golf Club & Plantation, Inc., 368 N.C. 440, 781 S.E.2d 1 (2015) ................................................................................... 23 Babbitt v. United Farm Workers Nat’l Union, 442 U.S. 289 (1979) ........................................................................................................ 5, 9 Bacon v. Lee, 353 N.C. 696, 549 S.E.2d 840 (2001) ............................................................................... 34 Beaufort Cnty. Bd. of Educ. v. Beaufort Cnty. Bd. of Comm’rs, 363 N.C. 500, 681 S.E.2d 278 (2009) ............................................................................... 39 Blanchette v. Conn. Gen. Ins. Corps., 419 U.S. 102 (1974) ............................................................................................................ 8 Blankenship v. Bartlett, 363 N.C. 518, 681 S.E.2d 759 (2009) ............................................................................... 34 Bryant v. Woodall, 363 F. Supp. 3d 611 (M.D.N.C. 2019) ............................................................................... 8 Chavez v. Wadlington, 261 N.C. App. 541, 821 S.E.2d 289 (2018) ...................................................................... 13 Cherry Cmty. Org. v. City of Charlotte, 257 N.C. App. 579, 809 S.E.2d 397 (2018) ...................................................................... 12 Citizens United v. FEC, 558 U.S. 310 (2010) .......................................................................................................... 40 City of L.A. v. Patel, 576 U.S. 409 (2015) .......................................................................................................... 41 iv Comm. to Def. Reprod. Rts. v. Myers, 29 Cal. 3d 252, 625 P.2d 779 (1981) ................................................................................ 31 Comm. to Elect Dan Forest. v. Emps. Pol. Action Comm., No. 231A18, --- S.E.2d ---, 2021 WL 403933 (N.C. Feb. 5, 2021) ...................... 4, 6, 7, 11 Cooper v. Berger, 370 N.C. 392, 809 S.E.2d 98 (2018) ..................................................................... 21, 22, 23 Corum v. Univ. of N.C. ex rel. Bd. of Governors, 330 N.C. 761, 413 S.E.2d 276 (1992) ......................................................................... 22, 25 Craig v. Boren, 429 U.S. 190 (1976) ...................................................................................................... 6, 18 Creek Pointe Homeowner’s Ass’n, Inc. v. Happ, 146 N.C. App 159, 552 S.E.2d 220 (2001) ........................................................... 16, 17, 18 Davis v. New Zion Baptist Church, 258 N.C. App. 223, 811 S.E.2d 725 (2018) ........................................................................ 4 Democratic Party of Ga., Inc. v. Crittenden, 347 F. Supp. 3d 1324 (N.D. Ga. 2018) ............................................................................. 16 Dep’t of Transp. v. Rowe, 353 N.C. 671, 549 S.E.2d 203 (2001) ................................................................... 34, 35, 40 Doe v. Bolton, 410 U.S. 179 (1973) ...........................................................................................................
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