Chris Van Hollen

Rikelman Nomination

Vote to confirm Julie Rikelman, a nominee with a positive record on reproductive freedom, to the U.S. Court of Appeals for the First Circuit. A vote for reproductive freedom was in favor of confirmation.

Abudu Nomination

Vote to confirm Nancy Abudu, a nominee with a positive record on reproductive freedom, to the U.S. Court of Appeals for the Eleventh Circuit.

Garcia Nomination

Vote to confirm Bradley Garcia, a nominee with a positive record on reproductive freedom, to the U.S. Court of Appeals for the District of Columbia Circuit.

Rescind VA Abortion Rule: Motion to End Debate

A resolution to express congressional disapproval of the interim final rule relating to abortion care, S.J.Res.10. Motion to proceed to consideration of the resolution. This measure would reverse the Biden administration’s rule that allows access to abortion care through the Department of Veterans Affairs (VA) in certain cases and allows VA to provide comprehensive information on pregnancy options. A vote for reproductive freedom was against the motion to proceed.

Equality Under the Constitution: Motion to End Debate

A resolution to eliminate the deadline for ratification of the Equal Rights Amendment (ERA) to the U.S Constitution, S.J.Res.4. Motion to invoke cloture (end debate) on the motion to proceed to S.J.Res.4. Three fifths of the Senate (60 votes) is required to invoke cloture on legislation.

Pregnant Workers Fairness Act

Consolidated Appropriations Act of 2023, H.R.2617. Cassidy (R-LA) amendment to include the Pregnant Workers Fairness Act in the FY’23 omnibus. A bill to eliminate pregnancy discrimination and promote health and economic security by requiring employers to provide reasonable accommodations to working people for limitations arising out of pregnancy, childbirth, and related medical conditions.

Refusal to Comply for State Employers: Pregnant Workers Fairness Act

Consolidated Appropriations Act of 2023, H.R.2617. Braun (R-OK) second-degree amendment to Cassidy (R-LA) amendment to add an exemption that would allow state employers to deny reasonable accommodations to pregnant working people employed by the state.

Refusal to Comply for Religious Employers: Pregnant Workers Fairness Act

Consolidated Appropriations Act of 2023, H.R.2617. Lankford (R-OK) second-degree amendment to Cassidy (R-LA) amendment to add an exemption that would allow religious employers to deny reasonable accomomodations to pregnant working people.

Attack on Trans Pregnant People

Inflation Reduction Act of 2022, H.R.5376. Motion to commit the FY’22 budget reconciliation legislation. Motion to commit the FY’22 budget reconciliation legislation with instructions to add language that would exclude trans pregnant people from maternal and infant-related federal programs.

Women’s Health Protection Act: Motion to End Debate S.4132

Women’s Health Protection Act, S.4132. Motion to invoke cloture (end debate) on the motion to proceed to the Women’s Health Protection Act, a bill to protect the federal right to abortion and block the barrage of state bans and restrictions on abortion intended to impede or outright deny access. Three-fifths of the Senate (60 votes) is required to invoke cloture on legislation.

Reinstate Title X Restrictions

A resolution to express congressional disapproval of the final rule relating to compliance with Title X requirements, S.J.Res.41. Motion to proceed to consideration of the resolution. This measure reverses the Biden administration rule, which overturned the Trump administration’s domestic gag rule—an anti-choice policy undermining access to birth control and preventive care that forced comprehensive reproductive health care providers out of the Title X program.

Jackson Nomination: Confirmation

Vote to confirm Ketanji Brown Jackson, a nominee with a positive record on reproductive freedom, to the post of associate justice of the Supreme Court.

Jackson Nomination: Motion to End Debate

Motion to invoke cloture (end debate) on the nomination of Ketanji Brown Jackson, a nominee with a positive record on reproductive freedom, to the post of associate justice of the Supreme Court. A simple majority is required to invoke cloture on nominations.

Women’s Health Protection Act: Motion to End Debate H.R.3755

Women’s Health Protection Act, H.R.3755. Motion to invoke cloture (end debate) on the motion to proceed to the Women’s Health Protection Act, a bill to protect the federal right to abortion and block the barrage of state bans and restrictions on abortion intended to impede or outright deny access. Three-fifths of the Senate (60 votes) is required to invoke cloture on legislation. A vote for reproductive freedom was for cloture.

Hyde and Weldon Expansion

FY’22 Senate Budget Resolution, S.Con.Res.14. Lankford (R-OK) amendment to provide non-binding budget reconciliation instructions expanding Abortion coverage bans (Hyde Amendment) and denials of healthcare (Weldon Amendment).

20-Week Abortion Ban

FY’22 Senate Budget Resolution, S.Con.Res.14. Kennedy (R-LA) amendment to provide non-binding budget reconciliation instructions banning abortion after 20 weeks nationwide.

Abortion Ban Based on the Reason for Seeking Care

FY’22 Senate Budget Resolution, S.Con.Res.14. Inhofe (R-OK) amendment to provide non-binding budget reconciliation instructions banning federal funding for abortion based on the reason a person is seeking care.

Lin Confirmation

Vote to confirm Tana Lin, a nominee with a positive record on reproductive freedom, to the U.S. District Court for the Western District of Washington.

Robinson Confirmation

Vote to confirm Beth Robinson, a nominee with a positive record on reproductive freedom, to the U.S. Court of Appeals for the Second Circuit.

Ohta Confirmation

Vote to confirm Jinsook Ohta, a nominee with a positive record on reproductive freedom, to the U.S. District Court for the Southern District of California.

Jackson Confirmation

Vote to confirm Ketanji Brown Jackson, a nominee with a positive record on reproductive freedom, to the U.S. Court of Appeals for the District of Columbia Circuit. A vote for reproductive freedom was in favor of confirmation.

Biomedical Research Restriction

Endless Frontier Act, S.1260. Lee (R-UT) amendment to impose restrictions on biomedical research using embryonic and fetal tissue. Three-fifths of the Senate (60 votes) is required to approve the amendment.

Beckering Confirmation

Vote to confirm Jane Beckering, a nominee with a positive record on reproductive freedom, to the U.S. District Court for the Western District of Michigan.

Clarke Confirmation

Vote to confirm Kristen Clarke, a nominee with a positive record on reproductive freedom, to the post of assistant attorney general for civil rights at the U.S. Department of Justice.

Becerra Confirmation

Vote to confirm Xavier Becerra, a nominee with a positive record on reproductive freedom, to the post of secretary of Health and Human Services.

Hyde Expansion

American Rescue Plan Act of 2021. Motion to waive certain Senate rules that would advance the Lankford (R-OK) amendment to expand abortion coverage bans (Hyde Amendment).

Three-fifths of the Senate (60 votes) is required to advance an amendment using this procedural maneuver.

Denials of Care

FY’21 Senate Budget Resolution, S.Con.Res.5. Lee (R-UT) amendment to provide non-binding budget reconciliation instructions denying access to social services, healthcare, and employment under the guise of religious freedom.

Political Interference in Family Decisions

Motion to waive certain Senate rules that would advance the Sasse (R-NE) amendment to provide non-binding budget reconciliation instructions to interfere with the medical practice of abortion care under the threat of severe penalties. Three-fifths of the Senate (60 votes) is required to advance an amendment using this procedural maneuver.

Crouse Confirmation

Vote to confirm anti-choice nominee Toby Crouse to the U.S. District Court for the District of Kansas.

Barrett Nomination: Confirmation

Vote to confirm anti-choice nominee Amy Coney Barrett to the post of associate justice of the Supreme Court.

Barrett Nomination: Motion to End Debate

Motion to invoke cloture (end debate) on the nomination of anti-choice nominee Amy Coney Barrett to the post of associate justice of the Supreme Court. A simple majority is required to invoke cloture on nominations.

McGlynn Confirmation

Vote to confirm anti-choice nominee Stephen P. McGlynn to the U.S. District Court for the Southern District of Illinois.

Dugan Confirmation

Vote to confirm anti-choice nominee David W. Dugan to the U.S. District Court for the Southern District of Illinois.

Wilson Confirmation

Vote to confirm anti-choice nominee Cory T. Wilson to the U.S. Court of Appeals for the Fifth Circuit.

Walker Confirmation

Vote to confirm anti-choice nominee Justin Reed Walker to the U.S. Court of Appeals for the District of Columbia.

20-Week Abortion Ban: Motion to End Debate

Pain-Capable Unborn Child Protection Act, S.3275. Motion to invoke cloture (end debate) on the motion to proceed to the Graham (R-SC) bill to ban abortion after 20 weeks nationwide. Three-fifths of the Senate (60 votes) is required to invoke cloture on legislation. February 25, 2020.

Interference in Abortion Practice: Motion to End Debate

Born-Alive Abortion Survivors Protection Act, S.311. Motion to invoke cloture (end debate) on the motion to proceed to the Sasse (R-NE) bill to interfere with the medical practice of abortion care under the threat of severe penalties. Three-fifths of the Senate (60 votes) is required to invoke cloture on legislation.

Brasher Confirmation

Vote to confirm anti-choice nominee Andrew Brasher to the U.S. Court of Appeals for the Eleventh Circuit. February 11, 2020.

VanDyke Confirmation

Vote to confirm anti-choice nominee Lawrence VanDyke to the U.S. Court of Appeals for the Ninth Circuit.

Pitlyk Confirmation

Vote to confirm anti-choice nominee Sarah Pitlyk to the U.S. District Court for the Eastern District of Missouri.

Menashi Confirmation

Vote to confirm anti-choice nominee Steven Menashi the U.S. Court of Appeals for the Second Circuit.

Rudofsky Confirmation

Vote to confirm anti-choice nominee Lee Rudofsky to the U.S. District Court for the Eastern District of Arkansas.

Paid Leave for Federal Employees in the Military

Schatz (D-HI) Motion to Instruct conferees to retain the House-passed Federal Employee Paid Leave Act in the final bill.

Stickman Confirmation

Vote to confirm anti-choice nominee William Shaw Stickman to the U.S. District Court for the Western District of Pennsylvania.

Brown Confirmation

Vote to confirm anti-choice nominee Jeffrey Vincent Brown to the U.S. District Court for the Southern District of Texas.

Jordan Confirmation

Vote to confirm anti-choice nominee Sean Jordan to the U.S. District Court for the Eastern District of Texas.

Starr Confirmation

Vote to confirm anti-choice nominee Brantley Starr to the U.S. District Court for the Northern District of Texas.

Liburdi Confirmation

Vote to confirm anti-choice nominee Michael Liburdi to the U.S. District Court for the District of Arizona.

Berger Confirmation

Vote to confirm anti-choice nominee Wendy Williams Berger to the U.S. District Court for the Middle District of Florida.

Buescher Confirmation

Vote to confirm anti-choice nominee Brian Buescher to the U.S. District Court for the District of Nebraska.

Phipps Confirmation

Vote to confirm anti-choice nominee Peter Phipps to the U.S. Court of Appeals for the Third Circuit.

Guidry Confirmation

Vote to confirm anti-choice nominee Greg Guidry to the U.S. District Court for the Eastern District of Louisiana.

Winsor Confirmation

Vote to confirm anti-choice nominee Allen Winsor to the U.S. District Court for the Northern District of Florida.

Miller Confirmation

Vote to confirm anti-choice nominee Eric Miller to the U.S. Court of Appeals for the Ninth Circuit.

Kacsmaryk Confirmation

Vote to confirm anti-choice nominee Matthew Kacsmaryk to the U.S. District Court for the Northern District of Texas.

Wyrick Confirmation

Vote to confirm anti-choice nominee Patrick Wyrick to the U.S. District Court for the Western District of Oklahoma.

Bell Confirmation

Vote to confirm anti-choice nominee Kenneth Bell to the U.S. District Court for the Western District of North Carolina.

Nichols Confirmation

Vote to confirm anti-choice nominee Carl Nichols to the U.S. District Court for the District of Columbia.

Clark Confirmation

Vote to confirm anti-choice nominee Stephen Clark to the U.S. District Court for the Eastern District of Missouri.

Nielson Confirmation

Vote to confirm anti-choice nominee Howard Nielson to the U.S. District Court for the District of Utah.

Collins Confirmation

Vote to confirm anti-choice nominee Daniel Collins to the U.S. Court of Appeals for the Ninth Circuit.

Vitter Confirmation

Vote to confirm anti-choice nominee Wendy Vitter to the U.S. District Court for the Eastern District of Louisiana.

Lee Confirmation

Vote to confirm anti-choice nominee Kenneth Lee to the U.S. Court of Appeals for the Ninth Circuit.

Truncale Confirmation

Vote to confirm anti-choice nominee Michael Truncale to the U.S. District Court for the Eastern District of Texas.

Park Confirmation

Vote to confirm anti-choice nominee Neomi Rao to the U.S. Court of Appeals for the Second Circuit.

Brasher Confirmation

Vote to confirm anti-choice nominee Andrew Brasher to the U.S. District Court for the Middle District of Alabama.

Barker Confirmation

Vote to confirm anti-choice nominee J. Campbell Barker to the U.S. District Court for the Eastern District of Texas.

Rao Confirmation

Vote to confirm anti-choice nominee Neomi Rao to the U.S. Court of Appeals for the District of Columbia Circuit.

Murphy Confirmation

Vote to confirm anti-choice nominee Eric Murphy to the U.S. Court of Appeals for the Sixth Circuit.

Interference in Abortion Practice: Motion to End Debate

Motion to invoke cloture (end debate) on Sasse (R-NE) bill to to interfere with the medical practice of abortion care under the threat of severe penalties. Three-fifths of the Senate (60 votes) is required to invoke cloture on legislation.

Barr Confirmation

Vote to confirm anti-choice nominee William Barr to the post of Attorney General.

No Taxpayer Funding for Abortion Act: Motion to End Debate

Motion to invoke cloture (end debate) on Wicker (R-MS) bill to effectively ban abortion coverage in the state health insurance exchanges, penalize small businesses that purchase private health plans that include abortion coverage, mandate that health plans make biased, one-sided "disclosures" of abortion coverage, and reiterate and expand bans on public insurance coverage of abortion.

Three-fifths of the Senate (60 votes) is required to invoke cloture on legislation.

Readler Confirmation

Vote to confirm anti-choice nominee Chad Readler to the U.S. Court of Appeals for the Sixth Circuit.

Kobes Confirmation

Vote to confirm anti-choice nominee Jonathan Kobes to the U.S. Court of Appeals for the Eighth Circuit.

Vice President Mike Pence cast the tie-breaking vote to confirm Jonathan Kobes.

Norris Confirmation

Vote to confirm anti-choice nominee Mark Norris to the U.S. Court District Court for the Western District of Tennessee.

Porter Confirmation

Vote to confirm anti-choice nominee David Porter to the U.S. Court of Appeals for the Third Circuit.

Dreiband Confirmation

Vote to confirm anti-choice nominee Eric Dreiband to the post of assistant attorney general for civil rights.

Kavanaugh Nomination: Confirmation

Vote to confirm anti-choice nominee Brett Kavanaugh to the post of associate justice of the Supreme Court.

Kavanaugh Nomination: Motion to End Debate

Motion to invoke cloture (end debate) on the nomination of anti-choice nominee Brett Kavanaugh to the post of associate justice of the Supreme Court. A simple majority is required to invoke cloture on nominations.

Attack on Planned Parenthood

FY’19 Department of Defense and Labor, Health and Human Services, and Education Appropriations Act, and FY’19 Continuing Appropriations Act, H.R.6157. Paul (R-KY) amendment to disqualify Planned Parenthood from participating in federal health care programs.

Grant Confirmation

Vote to confirm anti-choice nominee Britt Grant to the U.S. Court of Appeals for the Eleventh Circuit.

Oldham Confirmation

Vote to confirm anti-choice nominee Andrew Oldham to the U.S. Court of Appeals for the Fifth Circuit.

Brennan Confirmation

Vote to confirm anti-choice nominee Michael Brennan to the U.S. Court of Appeals for the Seventh Circuit.

Pompeo Confirmation

Vote to confirm anti-choice nominee Mike Pompeo to the post of secretary of State.

Duncan Confirmation

Vote to confirm anti-choice nominee Stuart Kyle Duncan to the U.S. Court of Appeals for the Fifth Circuit.

20-Week Abortion Ban: Motion to End Debate

Pain-Capable Unborn Child Protection Act, S.2311. Motion to invoke cloture (end debate) on the motion to proceed to the Graham (R-SC) bill to ban abortion after 20 weeks nationwide. Three-fifths of the Senate (60 votes) is required to invoke cloture on legislation.

Brownback Confirmation

Vote to confirm anti-choice nominee Sam Brownback to the post of ambassador at large for international religious freedom. Confirmed 50-49.

Vice President Mike Pence cast the tie-breaking vote to confirm Sam Brownback.

Azar Confirmation

Vote to confirm anti-choice nominee Alex Azar to the post of secretary of Health and Human Services.

Attack on the ACA – Senate Conference Report

Tax Cuts and Jobs Act, H.R.1. On agreeing to the conference report. Final passage. The conference report overhauls the tax system and eliminates the Affordable Care Act's requirement for individuals to purchase health insurance.

(Some anti-choice lawmakers cast what appear to be pro-choice votes; most observers recognize that those votes were cast for reasons unrelated to reproductive health.).

Willett Confirmation, Fifth Circuit Judge

Vote to confirm anti-choice nominee Don Willett to the U.S. Court of Appeals for the Fifth Circuit.

Grasz Confirmation, Eighth Circuit Judge

Vote to confirm anti-choice nominee Leonard Steven Grasz to the U.S. Court of Appeals for the Eighth Circuit.

Attack on the ACA – Senate Final Passage

Katsas Confirmation, D.C. Circuit Judge

Vote to confirm anti-choice nominee Greg Katsas to the U.S. Court of Appeals for the D.C. Circuit.

Barrett Confirmation, Seventh Circuit Judge

Vote to confirm anti-choice nominee Amy Coney Barrett to the U.S. Court of Appeals for the Seventh Circuit.

ACA Repeal: Paul Amendment

FY’18 budget resolution, H.Con.Res.71. Paul (R-KY) amendment to provide budget reconciliation instructions to repeal consumer protections, including protections for pre-existing conditions and required coverage of essential health benefits, provided by the Affordable Care Act.

(Some anti-abortion lawmakers cast what appear to be pro-reproductive freedom votes; most observers recognize that those votes were cast for reasons unrelated to reproductive health.)

ACA Repeal: Lee Amendment

FY’18 budget resolution, H.Con.Res.71. Lee (R-UT) amendment to provide budget reconciliation instructions to repeal the Affordable Care Act.

(Some anti-choice lawmakers cast what appear to be pro-choice votes; most observers recognize that those votes were cast for reasons unrelated to reproductive health.)

ACA Repeal and Attack on Planned Parenthood – McConnell Amendment

Health Care Freedom Act of 2017, H.R.1628. McConnell (R-KY) Amendment to FY’17 budget reconciliation legislation to defund Planned Parenthood and to eliminate the Affordable Care Act requirement to have health insurance.

(Some anti-choice lawmakers cast what appear to be pro-choice votes; most observers recognize that those votes were cast for reasons unrelated to reproductive health.)

Abortion-Coverage Ban

American Health Care Act of 2017, H.R.1628. Motion to waive the point of order that removes certain abortion-coverage restrictions in the budget reconciliation bill. This motion reinstates abortion restrictions on private insurance in the budget reconciliation bill.

ACA Repeal and Attack on Planned Parenthood – Obamacare Repeal Reconciliation Act of 2017

Obamacare Repeal Reconciliation Act of 2017, H.R.1628. Motion to waive certain Senate rules on the FY’17 budget reconciliation legislation. Waiving these rules would move forward a bill to dismantle the Affordable Care Act, restrict private insurance coverage of abortion care, and disqualify Planned Parenthood from participating in federal healthcare programs for one year.

(Some anti-choice lawmakers cast what appear to be pro-choice votes; most observers recognize that those votes were cast for reasons unrelated to reproductive health.)

ACA Repeal and Attack on Planned Parenthood – Better Care Reconciliation Act of 2017

Better Care Reconciliation Act of 2017, H.R.1628. Motion to waive certain Senate rules on the FY’17 budget reconciliation legislation. Waiving these rules would move forward a bill to dismantle the Affordable Care Act, including restrictions on private insurance coverage of abortion care, and disqualify Planned Parenthood from participating in federal healthcare programs for one year.

(Some anti-choice lawmakers cast what appear to be pro-choice votes; most observers recognize that those votes were cast for reasons unrelated to reproductive health.)

Bush Confirmation, Sixth Circuit Judge

Vote to confirm anti-choice nominee John Bush to the U.S. Court of Appeals for the Sixth Circuit.

Gottlieb Confirmation, FDA Commissioner

Vote to confirm anti-choice nominee Scott Gottlieb to the post of commissioner of the Food and Drug Administration.

Gorsuch Nomination, Supreme Court: Confirmation

Vote to confirm antichoice nominee Neil Gorsuch to the post of associate justice of the Supreme Court.

Gorsuch Nomination, Supreme Court: Rules Change

Vote to sustain the decision of the Chair that Supreme Court nominees must pass a 60-vote threshold. Vote failed. This rules change lowered the threshold to a simple majority.

Gorsuch Nomination, Supreme Court: Motion to End Debate

Motion to invoke cloture (end debate) on the nomination of anti-choice Neil Gorsuch to the post of associate justice of the Supreme Court. Three-fifths of the Senate (60 votes) is required to invoke cloture.

Rescind Title X Protections – Senate Final Passage

A resolution to express congressional disapproval of the final rule relating to compliance with Title X requirements, H.J.Res.43. Final passage. This measure reverses the Obama administration rule prohibiting discrimination against healthcare providers in the Title X program. VP Mike Pence cast a tie-breaking, anti-choice vote for the bill and it passed 51-50.

Rescind Title X Protections: Motion to End Debate

A resolution to express congressional disapproval of the final rule relating to compliance with Title X requirements, H.J.Res.43. Motion to proceed to consideration of the resolution. This measure reverses the Obama administration rule prohibiting discrimination against healthcare providers in the Title X program. VP Mike Pence cast a tie-breaking, anti-choice vote for the bill and it passed 51-50.

Price Confirmation, HHS Secretary

Vote to confirm anti-choice nominee Tom Price to the post of secretary of Health and Human Services.

Attack on Planned Parenthood: Special “Investigation” Committee Funding

H.Res.933. Final Passage. A resolution to allocate $800,000 in back-funding to the special committee investigating fetal-tissue donation and abortion practice.

Anti-Choice Refusal: Conscience Protection Act

S.304. Final passage. The bill would expand the Federal Refusal Clause by allowing individuals and healthcare companies to refuse to participate in, facilitate, or make arrangements for abortion services. It would also let individuals and organizations bring lawsuits for actual or threatened violations.

Anti-Choice Refusal: D.C. Reproductive-Health Non-Discrimination Law

Financial Services and General Government Appropriations Act, H.R.5485. Palmer (R-AL) amendment to block a D.C. law that prohibits employers from taking adverse action against employees based on their reproductive-health decisions.

Federal Employees’ Health Insurance

Financial Services and General Government Appropriations Act, H.R.5485. Grayson (D-FL) amendment to strike the current-law provision that prohibits federal employees and their dependents from choosing a health-insurance plan with abortion coverage through the Federal Employee Health Benefits (FEHB) program.

Restriction on Contraception: Zika Response

Zika Response and Preparedness Act, H.R.2577. On agreeing to the conference report to accompany H.R.2577. Final passage. The conference report restricts access to contraception by excluding family-planning providers from Zika response funds.

Anti-Choice Refusal: Taxpayer-Funded Discrimination

Energy and Water Development and Related Agencies Appropriations Act, H.R.5055. Byrne (R-AL) amendment to add a sweeping refusal provision that would allow employers to discriminate against women and LGBT workers.

Sessions Confirmation, Attorney General

Vote to confirm anti-choice nominee Jeff Sessions to the post of attorney general.

Attack on Planned Parenthood: Veto Override

To provide for reconciliation on the budget for fiscal year 2016, H.R.3762. Veto override. Vote to override President Obama’s January 8 veto of a bill that would disqualify Planned Parenthood from participating in federal health-care programs for one year.

(Some anti-choice lawmakers cast what appear to be pro-choice votes; most observers recognize that those votes were cast for reasons unrelated to reproductive health.) A two-thirds majority of those present and voting (285 votes needed to sustain the president’s veto in this case) of both houses is required to override a veto.

Support Women’s Access to No-Copay Contraception

FY’17 senate budget resolution, S.Con.Res.3. Gillibrand (D-NY) and Hirono (D-HI) amendment to ensure that women retain their guaranteed no-cost contraceptive coverage.

Attack on Planned Parenthood: One-Year Funding Ban

To provide for reconciliation on the budget for fiscal year 2016, H.R.3762. Final passage. The bill would disqualify Planned Parenthood from participating in federal healthcare programs for one year.

(Some anti-choice lawmakers cast what appear to be pro-choice votes; most observers recognize that those votes were cast for reasons unrelated to reproductive health.)