A few years before Roe v. Wade (1973) 410 U.S. 113, California’s Supreme Court reversed the criminal conviction of a physician for abortion and conspiracy to commit an abortion. The court’s 4-3 decision in People v. Belous (1969) 71 Cal.2d 954, cited in Roe, said, “The fundamental right of the woman to choose whether to bear children follows from the [U.S.] Supreme Court’s and this court’s repeated acknowledgment of a ‘right of privacy’ or ‘liberty’ in matters related to marriage, family, and sex.” (Id. at p. 963.)
The backstory of the Belous case is recounted by Brittny Mejia in the Los Angeles Times: “How a California’s illegal abortion paved way for Roe.” The article is about Cheryl and Cliff Palmer, Cheryl’s abortion before they were married, and Dr. Leon Belous, a Los Angeles physician and advocate for changing abortion laws who referred them to a Chula Vista physician — licensed in Mexico but not California — to perform the abortion.