THE SEASON OF ABORTION LITIGATION is in full bloom. South Dakota’s passage of a bill banning all abortions has captured most of the headlines, and Mississippi is considering similar legislation. Meanwhile, the Supreme Court has quietly decided two abortion cases this term–the first dealing with the process of invalidating abortion statutes that are unconstitutional in the case of medical emergencies; the second involving whether abortion protesters have violated the RICO Act. More significant, the Court granted certiorari last month in what may be the most momentous abortion case in more than a decade: Gonzales v. Carhart. Gonzales involves a constitutional challenge to the Partial-Birth Abortion Ban Act of 2003, which outlaws partial-birth abortions throughout the country. While Roe v. Wade will survive Gonzales, the issues involved are significant, such that this case may be a harbinger of things to come in the battle over abortion.