Legal protection of access to abortion
Governments sometimes take measures designed to afford legal protection of access to abortion. Such legislation often seeks to guard facilities which provide induced abortion against obstruction, vandalism, picketing, and other actions, or to protect patients and employees of such facilities from threats and harassment (see sidewalk interference). Another form such legislation sometimes takes is in the creation of a perimeter around a facility, known variously as a "buffer zone", "bubble zone", "safe access zone" or "access zone". This area is intended to limit how close to these facilities demonstration by those who oppose abortion  can approach. Protests and other displays are restricted to a certain distance from the building, which varies depending upon the law, or are prohibited altogether. Similar zones have also been created to protect the homes of abortion providers and clinic staff. Bubble zone laws are divided into "fixed" and "floating" categories. Fixed bubble zone laws apply to the static area around the facility itself, and floating laws to objects in transit, such as people or cars. Laws in Australia. Tasmania, Victoria, South Australia, Australian Capital Territory, New South Wales, Western Australia, the Northern Territory and Queensland are the states and  territories in Australia where buffer zones exist. The Australian Capital Territory has a buffer zone of only 50 m that has to be approved by the ACT health minister. Tasmania was the first state or territory to enforce buffer zones. In 2013, the Tasmanian Parliament passed the "Reproductive Health (Access to Terminations) Act" which enforces 'access zones' of a radius of 150 metres from premises at which abortions are provided. Behaviour prohibited within access zones includes: besetting, harassing, intimidating, interfering with, threatening, hindering, obstructing or impeding a person; protests in relation to terminations that are able to be seen or  heard by a person accessing a clinic; footpath interference; and intentionally recording a person accessing a clinic without their consent. The laws, in particular, the recent regulations passed by the NSW parliament in June 2018, were opposed by "sidewalk counsellors" who are "known to stand outside clinics with the intention of changing the minds of women entering the clinics". In November 2015, Victoria became the second state to pass legislation to limit protests outside abortion clinics and 150 metre buffer zones are now enforced. Prior to this, in 2005, the Australian Democrats proposed a law to create buffer zones around  clinics in Victoria. However, these attempts were unsuccessful as buffer zones were not included in Victoria's "Public Health and Wellbeing Act". On August 12, 2021, Western Australia became the final state or territory to legislate 'safe access zones' after passing the Public Health Amendment (Safe Access Zones) Bill (Assent date August 17, 2021). Laws in Canada. Several "buffer zone" laws have been enacted within Canada. At least three of the country's provinces and territories have passed laws intended to protect medical facilities that provide induced abortion: Access zone legislation has also been passed at the level of local  government in Canada: Laws in South Africa. The Choice on Termination of Pregnancy Act prohibits anyone from "preventing the lawful termination of a pregnancy" or "obstructing access to a facility for the termination of a pregnancy", imposing a penalty of up to ten years' imprisonment. Laws in the United States. At the federal level in the United States, the Freedom of Access to Clinic Entrances Act (FACE), makes it an offense to use intimidation or physical forcesuch as forming a blockadein order to prevent a person from entering a facility which provides reproductive healthcare or a place of worship. The  law also creates specific penalties for destroying, or causing damage to, either of these types of building. California, New York, and Washington have each established their own version of FACE. Other states have instituted several different kinds of measures designed to protect clinics, their employees, and patients: In the February 2003 case, "Scheidler v. National Organization for Women," the Supreme Court of the United States ruled that pro-life activists could not be prosecuted under the Racketeer Influenced and Corrupt Organizations Act (RICO), a law drafted to counter organized crime, or the Hobbs Act, a law intended to address economic  damages caused by extortion. The Court reaffirmed this holding on February 28, 2006 in a unanimous decision, although only eight Justices participated in the ruling, because Samuel Alito had not yet been confirmed. Section::::"Buffer zone" laws. In the United States, three states have passed "buffer zone" legislation, which can create either a "fixed" area around a medical facility or a "floating" area around patients and staff: Several local governments in the United States have, at some time, also passed similar municipal ordinances: Debate. Supporters of such laws claim that these zones are necessary to ensure that women have access to  abortion. They argue that a buffer zone helps to prevent blockading of a clinic's entrance, to protect the safety of patients and staff, and to ensure that clients do not feel intimidated, distressed, or harassed by the presence of pro-life activists. Some traditional free speech advocates such as the British Columbia Civil Liberties Association have cautiously sided in favour of narrowly defined "bubble zones" around abortion clinics on the basis that patients have a medical right to privacy when receiving confidential legal medical procedures that is compromised if protesters identify patients for the purpose of publicly shaming or  intimidating them. The American Civil Liberties Union helped enact the Freedom of Access to Clinic Entrances Act in 1994, which guarantees pedestrian access to clinics, but does not restrict related speech activity. In "Schenck v. Pro-Choice Network of Western New York", the ACLU filed briefs defending the constitutionality of a court order that prohibited defendants from protesting within 15 feet of clinic driveways and entrances in western New York. The Supreme Court upheld the ACLU's position. Some pro-choice activists have also argued that anyone convicted of anti-abortion violence should be permanently banned from protesting outside abortion  clinics. Professor Jacob M. Appel of New York University has argued that "much as we do not permit convicted pedophiles to teach kindergarten or convicted hijackers to board airplanes, common sense dictates that individuals who have been imprisoned for plotting violence against abortion clinics should never again be permitted anywhere near such facilities.". Those who oppose the creation of such legislation contend that "bubble zones", by limiting the ability to protest peacefully, represent an infringement upon their rights to freedom of expression and freedom of assembly.