There had always been a little wiggle room in state abortion laws, because doctors were still permitted to perform them for “therapeutic” reasons—to save a woman’s life, for example.7 But what did that mean, exactly? An amicus curiae brief in Roe from the American College of Obstetricians and Gynecologists and several other medical groups observed that “a woman suffering from heart disease, diabetes or cancer whose pregnancy worsens the underlying pathology may be denied a medically indicated therapeutic abortion under the statute because death is not certain.