"What then, would happen if Roe were overturned? Contrary to assertions that bans on abortion--including first trimester abortions--would occur in only a few states and take considerable time to enact, it is probable that many states would revive and enact immediate abortion bans. Moreover, in the absence of Roe, states would be given free reign to erode Roe; one only need look at the number of state restrictions placed on abortion provision in 2004, discussed supra, to know this is an all too real possibility. The move toward criminalizing abortion could be immediate: four states (Alabama, Delaware, Massachusetts, and Wisconsin) have abortion bans in place that have never been declared unconstitutional or blocked by courts. Roe’s reversal could “trigger” these laws; that is, state officials could immediately begin enforcing these bans the day Roe is overruled. Another 13 states have abortion bans on the books that have been blocked by courts as unconstitutional. . If Roe was overturned, officials in such states could immediately file suits asking courts to set aside the orders that prevented enforcement of the laws. And, in the remaining states, legislators would be free to introduce and enact new severe restrictions or bans on abortion. Ultimately, abortion would likely remain legal in small number of states, but even in such states women’s access would likely be severely restricted. This would create a daunting, patchwork system of abortion statutes: a woman’s right to obtain an abortion would be entirely dependent on the state in which she lived or her ability to travel to another state--assuming the states that keep abortion legal would permit non-residents to obtain abortions in that state. For those women who are able to navigate this patchwork system, the need to travel and the increased demand for a dwindling number of abortion providers could lead to dangerous delays in the provision of abortion care. Even more frightening, however, is the plight that women who do not live in provider states, and are unable to travel to those states, would face. In essence, overruling Roe would force a return to the two-tier system of abortion access that was in place before 1973: women with the financial ability to travel to other states may still be able to exercise their rights, whereas low-income women (disproportionately women of color and young women) would not. We would see a return to the days of back-alley and self-induced abortions; a return to the day where women -- our daughters, our sisters, our mothers, and our wives -- sacrificed their health and lives because they felt they were left with no other option. Re-criminalizing abortion, or so severely restricting it so as to make it practically unavailable, will not end the practice of abortion; it will end the practice of safe abortion."