Soliciting to Submit to Operation, Etc., to Cause an

Abortion. Every person who solicits any woman to submit to any operation, or to the use of any means whatever, to cause an abortion as defined in § 31.20 of this Title is guilty of a misdemeanor. In Guam Society of Obstetricians & Gynecologists v. Ada, 962 F.2d 1366 (9th Cir 1992), cert. denied, 506 U.S. 1011 (1992), the Ninth Circuit Court invalidated these provisions, relying on Roe v. Wade, 410 U.S. 113 (1972), and also permanently enjoined enforcement of P.L. 20-134. Roe v. Wade was overturned by Dobbs v. Jackson Women’s Health Organization, 597 U.S. -- (2022), and in response to a request from members of the 36th Guam Legislature, the Attorney General of Guam issued Opinion COL7/19/2022 CH. 31 OFFENSES AGAINST THE FAMILY Memorandum LEG-22-0324, finding that the 20th Guam Legislature had exceeded its Organic Act authority in enacting P.L. 20-134, and that P.L. 20-134 was void ab initio. See Att’y. Gen. Op. Mem LEG-22-034 (July 6, 2022). Based on this guidance, the provisions of P.L. 20-134 will not be codified in the GCA.