"[I]n 2004, Attorney General John Ashcroft revived the tactics that nearly fifty years ago had shocked physicians and much of the public and propelled abortion law reform forward. Ashcroft subpoenaed thousands of patient records from hospitals and Planned Parenthood clinics in New York, Philadelphia, Chicago, Michigan, Missouri, California, Nebraska, and elsewhere in search of evidence that physicians had performed “medically unnecessary” abortions in violation of the new “partial-birth” abortion ban passed by Congress the year before. Hospitals refused to provide the records, citing a violation of patient privacy and the privacy of medical records (privacy that President George W. Bush had declared a “fundamental right” and written into law only the year before as part of HIPAA, the Health Insurance Portability and Accountability Act). Individual physicians and reproductive rights organizations sued; Democrats in Congress protested Ashcroft’s actions. Courts gave conflicting opinions on the privacy of patients’ medical records, though eventually the federal government withdrew the demand for records."