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Judge Sandra Ikuta wrote in the majority opinion that the Supreme Court approved similar regulations in 1991 with Rust v. Sullivan and that the Protect Life Rule is “less restrictive in at least one important respect.” In the majority opinion, she stated “a counselor providing nondirective pregnancy counseling ‘may discuss abortion’ so long as ‘the counselor neither refers for, nor encourages, abortion,’” wrote Ikuta.
Planned Parenthood has called upon Congress to reverse the Protect Life Rule, which it calls a "gag rule."
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