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saw the pharmacy rules again upheld
as constitutional and the U.S. Supreme
Court denied review. 27
Similarly, Charbonneau found herself
despairing after the U.S. Supreme Court’s
2014 decision in Burwell v. Hobby Lobby
Stores, which held that a for-profit corporation was a “person” entitled to Free Exercise rights violated by a contraceptives
mandate of the U.S. Department of Health
and Human Services. 28 PPGNHI and other Planned Parenthood affiliates prepared
for an onslaught of businesses opting out
of employer health insurance coverage for
contraceptives. But since Burwell, Charbonneau’s impression has been that the
marketplace is reluctant to broadly assert
corporate Free Exercise rights that could
negatively impact employee hiring and
retention, among other considerations.
By contrast, a Washington law supported by PPGNHI that requires the teaching
of “medically accurate” information in
sexuality education classes has stood the
test of time. Charbonneau credits this
legislative change with eliminating fear-based misinformation designed to scare
young people into certain choices.
In the recent past, Charbonneau has
found the U.S. Department of Justice
and courts generally to be staunch
defenders of pro-choice rights and
the safety of Planned Parenthood clinics. Buffer zones have been enforced
around clinics for the protection of
patients and staff. Threats and attacks
against clinics have been investigated
as serious criminal offenses, including
the FBI’s investigation of a 2015 arson
attack on a clinic in Pullman. 29
But what about the equally vocal
opposition to PPGNHI’s advocacy of
pro-choice rights? “I actually support
the right of people who don’t agree
with me to picket,” Charbonneau says.
“That part doesn’t bother me.” She is
quick to add, however, that circumstances matter. For example, she recalls a clinic on the second floor of a
building above a movie theater where
moviegoers, including young children,
were subjected to a picketer’s graphic