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On January 17th 2014, Catherine Eagles, a federal judge for the Middle District of North Carolina, struck down as unconstitutional a portion of North Carolina’s 2011 Women’s Right to Know Act. The portion in question would have required abortion providers in the state to perform an ultrasound and display and describe the images presented to every woman seeking an abortion. Eagles concluded that this so-called “speech-and-display provision” was “performative rather than informative” and therefore served no medical purpose. She determined this in part because the original text of the law suggested that women might choose not to look at these ultrasound images: “Nothing in this section shall be construed to prevent a pregnant woman from averting her eyes from the ultrasound images required to be provided to and reviewed with her.” In a 42-page memorandum outlining her decision, Eagles wrote, “Requiring a physician or other health care provider to deliver the state’s content-based, non-medical message in his or her own voice as if the message was his or her own constitutes compelled ideological speech and warrants the highest degree of First Amendment protection.”