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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
LUBBOCK DIVISION
____________________________________________
PLANNED PARENTHOOD OF GREATER TEXAS
SURGICAL HEALTH SERVICES, on behalf of
itself, its staff, physicians and patients; and G. SEALY
MASSINGILL, M.D., on behalf of himself and his
patients,
Plaintiffs,
v.
CITY OF LUBBOCK, TEXAS,
Defendant.
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Case No. 5:21-cv-114
COMPLAINT
Plaintiffs Planned Parenthood of Greater Texas Surgical Health Services (“PPGTSHS”)
and Dr. G. Sealy Massingill, by and through their attorneys, hereby allege the following:
INTRODUCTION
1. The Constitution of the United States guarantees the right to have an abortion.
But as of June 1, 2021, the City of Lubbock will prohibit and prevent the exercise of that right
through the passage of its Ordinance Outlawing Abortion Within the City of Lubbock, Declaring
Lubbock a Sanctuary City for the Unborn, Making Various Provisions and Findings, Providing
for Severability, Repealing Conflicting Ordinances, and Establishing an Effective Date
(“Ordinance,” attached as Ex.). Plaintiffs bring this action to enjoin the City from maintaining in
force, enforcing, or giving legal effect to the Ordinance and to declare the Ordinance invalid
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under the Due Process Clause of the Fourteenth Amendment to the U.S. Constitution and Texas
law.
2. The Ordinance bans abortions in the City of Lubbock. It imposes substantial
liability on anyone who procures, performs, aids, or abets an abortion in Lubbock, be it a doctor,
nurse, relative, friend, or stranger. It invites any Texas citizen to obtain an injunction against
anyone who plans to procure, perform, aid, or abet an abortion. It permits these lawsuits at any
time, and bars providers from citing the patient’s consent as a defense.
3. The Ordinance will prevent Plaintiffs from providing abortions in Lubbock and
will seriously impede access to abortion. Consequently, the Ordinance plainly violates the
constitutional right to abortion.
4. The Ordinance also violates Texas law. As a municipality, the City of Lubbock
has no power to create civil liability between private parties. Moreover, the Ordinance is
preempted because the Texas Penal Code already covers the same conduct, and because the
Ordinance’s imposition of criminal and civil liability is inconsistent with the Texas Penal Code
and the Texas wrongful death statute.
5. Plaintiffs bring this lawsuit to safeguard their patients’ constitutional right to
abortion, to prevent the harm that the Ordinance will cause their patients’ health and well-being,
and to preserve their own ability to fulfill their mission to provide comprehensive reproductive
health care.
JURISDICTION AND VENUE
6. Plaintiffs assert their federal constitutional claim under 42 U.S.C. § 1983. The
Court has subject matter jurisdiction over that claim under 28 U.S.C. § 1331 and § 1343(a)(3)
and (a)(4).
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7. The Court has supplemental jurisdiction over Plaintiffs’ state-law claims under 28
U.S.C. § 1367(a).
8. Plaintiffs’ request for declaratory and injunctive relief is authorized by 28 U.S.C.
§ 2201 and § 2202, Federal Rules of Civil Procedure 57 and 65, Texas Civil Practice &
Remedies Code § 37.003 & .004(a) and § 65.011, and the Court’s general legal and equitable
powers.
9. Plaintiffs’ request for attorney’s fees and costs is authorized by 42 U.S.C.
§ 1988(b), Federal Rule of Civil Procedure 54(d), and Texas Civil Practice & Remedies Code
§ 37.009.
10. Venue is proper under 28 U.S.C. § 1391(b) because the City of Lubbock is in this
district and because a substantial part of the events or omissions giving rise to the claims
occurred in this district.
PARTIES
11. Plaintiff PPGTSHS is a non-profit corporation organized under the laws of the
State of Texas and a subsidiary of Planned Parenthood of Greater Texas (“PPGT”). PPGT,
through its predecessor organizations and through another subsidiary, has provided a broad range
of high-quality reproductive health care to patients in Texas since 1935. PPGT and its
subsidiaries provide medical services at a health center in Lubbock, Texas, which PPGT opened
in October 2020, including birth control, annual gynecological examinations, cervical pap
smears, diagnosis and treatment of vaginal infections, testing and treatment for certain sexually
transmitted infections, HIV testing, and pregnancy testing. In April 2021, PPGTSHS began
providing abortions at the Lubbock health center. PPGTSHS and its medical staff are threatened
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with civil liability if they perform, aid, or abet abortions at the Lubbock health center.
PPGTSHS brings this lawsuit on behalf of itself, its physicians, its staff, and its patients.
12. Plaintiff G. Sealy Massingill, M.D., is PPGT’s Chief Medical Officer and one of
the physicians serving patients at the Lubbock health center. In that capacity, he provides
patients with abortions and related health care. Consequently, Dr. Massingill, along with all
other physicians and medical staff who participate in the provision of abortions at the Lubbock
health center, are threatened with liability under the Ordinance. Dr. Massingill brings this
lawsuit on behalf of himself and his patients.
13. Defendant, the City of Lubbock, is a city located in Lubbock County, Texas.
ALLEGATIONS
A. Abortion in Lubbock
14. Lubbock is a medically underserved area with high rates of low-income and
uninsured residents. Access to comprehensive reproductive health care, including abortion, has
been especially difficult in Lubbock since 2013, when a health center operated in Lubbock by a
separate Planned Parenthood entity was forced to close following the State’s imposition of a
series of state funding cuts and abortion restrictions, which were later held unconstitutional. The
closure left people in the Lubbock area more than 300 miles from the nearest abortion provider.
Some to the north or west of Lubbock were even more isolated from abortion providers in Texas.
15. To fill this gap, PPGT decided to open a health center in Lubbock to provide
needed health care services. The Lubbock health center’s mission is to provide affordable and
accessible comprehensive reproductive, family-planning, and other health care services,
especially to patients from underserved communities. This includes screening for breast and
cervical cancer, testing and treatment for various infections, access to contraception and
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vaccines, and annual wellness checks. Comprehensive reproductive health care also includes
access to abortion, and so the health center was constructed to provide abortions.
16. The Lubbock health center is the only licensed abortion provider within 300 miles
of the City of Lubbock.
17. Legal abortion is one of the safest medical procedures in the United States. To
date, the Lubbock center has offered only medication abortion, but it is equipped to offer
procedural abortion and intends to begin performing such services soon. The Lubbock health
center’s staff for serving abortion patients includes not only doctors, but also nurses and medical
assistants.
B. The Ordinance
18. In September 2020, in response to PPGT’s announcement that it would open a
health center in Lubbock, an “initiating committee” of Lubbock residents, led by Charles Perry, a
state legislator, initiated a petition for the City to either adopt a proposed “sanctuary city”
ordinance or hold a referendum on the proposed ordinance.
19. The City solicited a legal opinion from an outside law firm, Olson & Olson LLC,
on the legality of the proposed ordinance. Olson & Olson advised the City: “The Proposed
Ordinance is inconsistent with the United States and Texas Constitutions” and “with the present
law of the State of Texas.” In particular, Olson & Olson concluded that the proposed ordinance
would violate the constitutional right to abortion under Roe v. Wade, 410 U.S. 113 (1973), and
other binding Supreme Court decisions. And Olson & Olson concluded that the proposed
ordinance was inconsistent with and therefore preempted by the Texas Penal Code and the Texas
wrongful death statute.
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20. At a meeting in November 2020, the City Council unanimously rejected the
proposed Ordinance. At that meeting, the mayor and all other city councilmembers explained
that the proposed Ordinance was constitutionally invalid under Roe and that it was inconsistent
with, and therefore void under, state law.
21. Pursuant to the City’s charter, upon the initiating committee’s request, the
proposed ordinance was referred to the City’s voters. The initiative passed on May 1, 2021. The
Ordinance will become effective on June 1, 2021.
22. The Ordinance states that that its aim is “to outlaw abortion under city law and to
establish penalties and remedies” in order “[t]o protect the health and welfare of all residents
within the City.” Ordinance § A(9). Accordingly, the Ordinance provides: “Abortion at all
times and at all stages of pregnancy is declared to be an act of murder.” Ordinance § C(2).
Further, the Ordinance declares it “unlawful for any person” to “procure or perform an abortion
of any type and at any stage of pregnancy in the City,” Ordinance § D(1), or to “knowingly aid
or abet an abortion that occurs in the City,” Ordinance § D(2). The Ordinance specifies that
aiding and abetting include “[k]nowingly providing transportation to or from an abortion
provider,” “[g]iving instructions over the telephone, the internet, or any other medium of
communication regarding self-administered abortion,” and “[p]roviding money with the
knowledge that it will be used to pay for an abortion or the costs associated with procuring an
abortion.” Id. The Ordinance provides for public enforcement and two mechanisms for private
enforcement.
23. As to public enforcement, the Ordinance subjects “any person, corporation, or
entity who commits an unlawful act” under the Ordinance—procuring, providing, aiding or
abetting an abortion—“to the maximum penalty permitted under Texas law for the violation of a
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municipal ordinance governing public health.” Ordinance § E(1). However, the Ordinance
states that no such penalty may be “impose[d] or threaten[ed] … unless and until” one of three
events occurs: (a) the Supreme Court “overrules Roe v. Wade, 410 U.S. 113 (1973), and Planned
Parenthood v. Casey, 505 U.S. 833 (1992)”; (b) a “state or federal court … rules that the
imposition or threatened imposition” of such penalty “will not impose an ‘undue burden’ on
women seeking abortions”; or (c) “state or federal court … rules that the person, corporation, or
entity that committed the unlawful act … lacks third-party standing to assert the rights of women
seeking abortions in court.” Ordinance § E(2).
24. As to private enforcement, first, the Ordinance provides that “[a]ny person,
corporation, or entity that commits an unlawful act” under the Ordinance “shall be liable in tort
to the unborn child’s mother, father, grandparents, siblings and half-siblings.” Ordinance § F(1).
“[E]ach” such “relative” is entitled to recover “[c]ompensatory damages, including damages for
emotional distress,” “[p]unitive damages,” and “[c]osts and attorneys’ fees.” Id. “There is no
statute of limitations for this private right of action,” and “[t]he consent of the unborn child’s
mother to the abortion shall not be a defense to liability, even if the unborn child’s mother sues
under this provision.” Id.
25. Second, the Ordinance provides that “[a]ny private citizen of Texas … may bring
an action to enforce this ordinance against a person or entity that has committed an unlawful act”
under the Ordinance “or that commits or plans to commit [such] an unlawful act.” Ordinance
§ F(2). The Ordinance directs that such a private plaintiff “be awarded … [i]njunctive relief” if
the “unlawful act” has not already been committed, “[s]tatutory damages of not less than”
$2,000, and “[c]osts and attorneys’ fees” if either injunctive relief or statutory damages are
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awarded. Ordinance § F(2). Again, there is no statute of limitations and the patient’s consent to
the abortion is not a defense. Id.
26. The Ordinance declares that “[t]he non-imposition of the penalties” through
public enforcement “does not in any way limit or [a]ffect the availability of the private-
enforcement remedies.” Ordinance § E(4). And the Ordinance provides an “affirmative
defense” to both public and private enforcement actions “if the abortion was in response to a life-
threatening physical condition aggravated by, caused by, or arising from a pregnancy that, as
certified by a physician, places the woman in danger of death or a serious risk of substantial
impairment of a major bodily function unless an abortion is performed.” Ordinance § D(3).
C. The Ordinance’s Effects
27. The Ordinance’s obvious purpose is to prevent Plaintiffs from providing abortions
in Lubbock, depriving anyone in the Lubbock area who wants an abortion of access to a safe and
legal abortion. And that will be its effect.
28. Because the Ordinance declares procuring, performing, aiding, or abetting
abortion “unlawful” and “murder,” imposes substantial liability on anyone who procures,
performs, aids, or abets an abortion in Lubbock, and allows injunctions against anyone planning
to so act, no doctor, nurse, or other staff at the Lubbock center will participate in the center’s
abortion services. The legal and financial risk to the health center and to its personnel personally
is too great. Even if they were to successfully defend against a civil suit, the litigation costs from
the barrage of civil lawsuits encouraged by the Ordinance would be crushing. Indeed, the
Ordinance has already forced Plaintiffs to cancel abortion-related appointments to avoid
potential liability.
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29. Therefore, the Ordinance leaves Plaintiffs no choice but to cease all abortion
services in Lubbock. That will undermine Plaintiffs’ mission of providing affordable,
comprehensive reproductive health care (especially to patients from underserved communities).
30. More fundamentally and more troubling, Plaintiffs’ inability to perform abortions
in Lubbock will prevent and unduly burden their patients’ exercise of the constitutional right to
abortion. Without access to abortion at the Lubbock center, anyone in the Lubbock area who
wants an abortion will be able to obtain one only by traveling extraordinary distances—a
daunting and, for many, prohibitive obstacle, especially for people with lower incomes.
31. People who want an abortion generally seek one as soon as possible, but many
face logistical challenges that can delay access to care. For example, a pregnant person needs to
deliberate and decide whether to seek an abortion, schedule appointments, gather the financial
resources to pay for the abortion and related costs, arrange transportation to and from a health
center, take time off work (often unpaid), and possibly obtain substitute care for a child or other
family member during the abortion and recovery. There is a narrow window of time to
accomplish these tasks; people usually do not learn they are pregnant until at least four weeks
after their last menstrual period, and often much later, and Texas law prohibits nearly all
abortions beginning at twenty-two weeks of gestation.
32. Having to travel hundreds of miles to an abortion provider and hundreds of miles
back, likely with an overnight stay, exacerbates these challenges. Anyone seeking an abortion
will likely need to gather more money to cover higher travel costs (not just for gas but potentially
also for overnight lodging and more meals), might lose more income from taking more time off
work, and will have a harder time obtaining substitute family care. For some, these heightened
challenges will be impossible to overcome; for others, they will appreciably delay their access to
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an abortion. These challenges are especially serious for people with lower incomes, who are
already medically underserved and constitute a substantial portion of Plaintiffs’ patients.
33. Delay in accessing abortion poses significant health risks because, although
abortion is very safe, the health risk associated with an abortion increases with gestational age.
Delay also increases medical costs because the cost of an abortion procedure increases as
gestational age increases. Someone seeking an abortion can fall into a vicious cycle of delaying
while gathering funds only to find that procedures later in pregnancy are more expensive than
anticipated, requiring further delay. In the worst-case scenario, the person may be so delayed by
the challenges of having to travel hundreds of miles that the time to have an abortion expires.
34. Studies have confirmed that “greater distances to abortion facilities are associated
with increased burden [on the person seeking an abortion], including higher associated out-of-
pocket costs, greater difficulty getting to the clinic, negative mental health outcomes, higher
likelihood of emergency room-based follow-up care, delayed care, and decreased use of abortion
services.” Indeed, after the State of Texas adopted a set of draconian abortion restrictions in
2013 that—before they were struck down by the Supreme Court—forced many abortion
providers to close (including the one in Lubbock), the number of abortions performed in Texas
abruptly fell substantially, and the more those closures increased the distance to the nearest
abortion provider, the greater was the decline. For example, where those closures increased the
distance to the nearest abortion facility by 100 miles or more—as they did for Lubbock—the
number of abortions declined by 50.3%.
35. Consequently, the Ordinance will put many pregnant people in the Lubbock area
to a difficult choice: carry the pregnancy to term (which may be harmful emotionally and poses
significant medical risks) or pursue illegal or potentially unsafe abortion methods. That is not
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the choice protected by the U.S. Constitution. See, e.g., Roe, 410 U.S. at 153 (describing
“[s]pecific and direct harm” to women from forced childbirth).
CLAIMS
COUNT ONE
Due Process Clause
36. The Due Process Clause of the Fourteenth Amendment to the U.S. Constitution
guarantees the right to abortion before viability. Binding precedent of the Supreme Court and
the Fifth Circuit establishes that laws banning pre-viability abortion are categorically
unconstitutional. See, e.g., Planned Parenthood v. Casey, 505 U.S. 833, 846 (1992) (maj. op.);
Jackson Women’s Health Org. v. Dobbs, 951 F.3d 246, 248 (5th Cir. 2020) (per curiam).
37. Because the Ordinance bans pre-viability abortions, it is a per se violation of
Plaintiffs’ patients’ constitutional right to choose abortion.
38. Additionally, binding Supreme Court and Fifth Circuit precedent establishes that
an abortion regulation imposes a constitutionally impermissible “undue burden” if its purpose or
effect is to place a substantial obstacle in the path of obtaining an abortion. See, e.g., Whole
Woman’s Health v. Hellerstedt, 136 S. Ct. 2292, 2300 (2016); Jackson Women’s Health, 945
F.3d at 275-276.
39. The Ordinance imposes a constitutionally impermissible undue burden because its
purpose and effect are to place a substantial obstacle in the path of obtaining abortions:
preventing abortion providers from providing abortions in Lubbock, leaving pregnant people in
the Lubbock area hundreds of miles from the nearest abortion provider.
40. Plaintiffs and their staff face serious legal liability under the Ordinance should
they participate in the provision of an abortion—or even plan to. The constant threat of such
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liability will impair Plaintiffs’ and their staff’s ability to provide abortions in Lubbock. Plaintiffs
will have no choice but to cease providing abortions in Lubbock.
41. The elimination of abortion providers in Lubbock is an extreme obstacle to
abortion. Providers in other locations are not an adequate substitute. The nearest abortion
provider to Lubbock is more than 300 miles away. As explained above, the logistical and
financial challenges of traveling such a great distance for an abortion are significant. For some,
these obstacles will delay access to an abortion, potentially forcing them to obtain a later
abortion, which carries greater health risks, without adequate justification. For others, these
obstacles will entirely foreclose access, forcing them to carry an unwanted pregnancy to term.
COUNT TWO
State Law – Ultra Vires
42. Texas law grants municipalities the power to adopt ordinances and to enforce
their ordinances themselves, see Tex. Loc. Gov’t Code § 51.001, §§ 51.071-51.079, § 54.001,
but it does not grant municipalities the power to create civil liability between private parties.
Only State law, through the common law or a statute, may do that.
43. Insofar as the Ordinance permits a private person to sue for money damages or
injunctive relief, it is ultra vires.
COUNT THREE
State Law – Preemption
44. The Ordinance is expressly and impliedly preempted by the Texas Penal Code
and Texas’s wrongful death statute.
45. Under Texas law, “[n]o governmental subdivision or agency may enact or enforce
a law that makes any conduct covered by this code an offense subject to a criminal penalty.”
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Tex. Penal Code § 1.08. The Ordinance subjects those who participate in providing an abortion
to criminal penalties, but the Texas Penal Code already covers abortion. See Tex. Penal Code
§§ 1.07(a)(26), 19.02(b).
46. Additionally, under Texas law no ordinance may “contain any provision
inconsistent with … the general laws enacted by the Legislature of this State.” Tex. Const. art.
XI. The Ordinance is inconsistent with Texas’s homicide and wrongful death statutes: whereas
Texas has deliberately exempted from criminal and civil liability a death arising from a lawful
medical or health care procedure or the lawful dispensation or administration of a drug, see Tex.
Penal Code § 19.06; Tex. Civ. Prac. & Rem. Code §§ 71.002(a) & 71.003(c), the Ordinance
imposes criminal and civil liability on such abortions. The Ordinance is also inconsistent with
Texas’s health code, which permits abortion by licensed physicians, subject to extensive
requirements. See Tex. Health & Safety Code ch. 171.
47. The Ordinance is also inconsistent with the State’s wrongful death statute in that
the wrongful death statute defines a two-year limitations period and a narrow and exclusive class
of plaintiffs, see Tex. Civ. Prac. & Rem. Code § 16.003(b), § 71.004(a), whereas the Ordinance
eliminates the limitations period and greatly expand the class of plaintiffs.
RELIEF REQUESTED
Plaintiffs request that this Court:
a. Declare the Ordinance invalid under the Due Process Clause of the Fourteenth
Amendment to the U.S. Constitution;
b. Preliminarily and permanently enjoin the City and its officers, agents, servants,
employees, and attorneys, and any other persons who are in active concert or
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participation with them from maintaining in force, enforcing, or giving legal
effect to the Ordinance;
c. Declare the Ordinance invalid under Texas law;
d. Award to Plaintiffs their attorney’s fees and costs; and
e. Award such other and further relief as this Court shall deem just and reasonable.
Dated: May 17, 2021 Respectfully submitted,
/s/ Robin M. Green
ROBIN M. GREEN (Tx. Bar No. 08369000)
1001 Main Street
Suite 204
Lubbock, Texas, 79401
(806) 749-3030
(806) 451-3344 (fax)
PAUL R.Q. WOLFSON*
DAVID M. LEHN*
WILMER CUTLER PICKERING
HALE AND DORR LLP
1875 Pennsylvania Ave., NW
Washington, DC 20006
(202) 663-6000
(202) 663-6363 (fax)
LORI A. MARTIN*
ALAN E. SCHOENFELD*
CINDY Y. PAN*
WILMER CUTLER PICKERING
HALE AND DORR LLP
7 World Trade Center
New York, NY 10007
(212) 230-8800
(212) 230-8888 (fax)
VIKRAM P. IYER*
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WILMER CUTLER PICKERING
HALE AND DORR LLP
350 South Grand Ave.
Los Angeles, CA 90071
(213) 443-5300
(213) 443-5400 (fax)
MELISSA A. COHEN*
PLANNED PARENTHOOD FEDERATION OF AMERICA
123 William St.
New York, NY 10038
(212) 261-4649 (phone & fax)
RICHARD MUNIZ*
PLANNED PARENT FEDERATION OF AMERICA
1110 Vermont Ave., NW, Suite 300
Washington, DC 20005
(202) 973-4997 (phone & fax)
ANDRE SEGURA
ADRIANA PINON*
ACLU FOUNDATION OF TEXAS, INC.
5525 Katy Freeway, Suite 350
Houston, TX 77077
(713) 942-8146
(713) 942-8966 (fax)
Counsel for Plaintiffs
* Pro hac vice applications forthcoming
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