NARAL's Keenan had this to say: "Samuel Alito's writings reflect a visceral opposition to Roe v. Wade. It is clear that his legal philosophy calls for a calculated strategy to dismantle fundamental constitutional protections for women, including the health exception issue that the Supreme Court is considering right now." Keenan also states that, "Alito's memo is a litany of legal strategies designed to undermine women's reproductive health. He even confuses birth control with abortion and advocates additional restrictions on women's access to contraception."
Her contraception remarks are probably about the portion of the memo below.
"What, for example, is the objection to informing a woman that certain methods of birth control are "abortifacients," i.e., that they do not prevent fertilization but terminate the development of the fetus after conception? Why cannot the State of Illinois require that this information be provided to patients, in the doctor's own words, so that women for whom the difference is morally significant can make an informal choice? Would a court hesitate for a moment before upholding government's authority to require that patients be informed about the operation of any other drug or medical device?"
So Alito confuses abortion with contraception because he recognizes that some methods of birth control impede implantation instead of preventing conception? An additional restriction is telling women that their birth control method might prevent implantation?
The memo crushes a number of absurd pro-choice arguments against prolife legislation. Alito notes, "If abortion is a woman's choice, as the Court has held, then surely the choice should be informed."
"Furthermore, many physicians, including those operating high-volume abortion clinics, have a financial interest in encouraging women to have abortions. Must the state entrust to them the sole responsibility to provide a woman with the relevant information bearing on her choice?"