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A layered lake is a little like Earth’s early oceans − and lets researchers explore how oxygen built up in our atmosphere billions of years ago

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A layered lake is a little like Earth’s early oceans − and lets researchers explore how oxygen built up in our atmosphere billions of years ago

Researchers sample water from various layers to analyze back in the lab.
Elizabeth Swanner, CC BY-ND

Elizabeth Swanner, Iowa State University

Little Deming Lake doesn’t get much notice from visitors to Itasca State Park in Minnesota. There’s better boating on nearby Lake Itasca, the headwaters of the Mississippi River. My colleagues and I need to maneuver hundreds of pounds of equipment down a hidden path made narrow by late-summer poison ivy to launch our rowboats.

But modest Deming Lake offers more than meets the eye for me, a geochemist interested in how oxygen built up in the atmosphere 2.4 billion years ago. The absence of oxygen in the deep layers of Deming Lake is something this small body of water has in common with early Earth’s oceans.

On each of our several expeditions here each year, we row our boats out into the deepest part of the lake – over 60 feet (18 meters), despite the lake’s surface area being only 13 acres. We drop an anchor and connect our boats in a flotilla, readying ourselves for the work ahead.

Smooth lake with boats in the distance against woodsy shoreline
Researchers’ boats on Deming Lake.
Elizabeth Swanner, CC BY-ND

Deming Lake is meromictic, a term from Greek that means only partially mixing. In most lakes, at least once a year, the water at the top sinks while the water at the bottom rises because of wind and seasonal temperature changes that affect water’s density. But the deepest waters of Deming Lake never reach the surface. This prevents oxygen in its top layer of water from ever mixing into its deep layer.

Less than 1% of lakes are meromictic, and most that are have dense, salty bottom waters. Deming Lake’s deep waters are not very salty, but of the salts in its bottom waters, iron is one of the most abundant. This makes Deming Lake one of the rarest types of meromictic lakes.

man seated in small boat wearing gloves injecting water into a collection tube
Postdoc researcher Sajjad Akam collects a water sample for chemical analysis back in the lab.
Elizabeth Swanner, CC BY-ND

The lake surface is calm, and the still air is glorious on this cool, cloudless August morning. We lower a 2-foot-long water pump zip-tied to a cable attached to four sensors. The sensors measure the temperature, amount of oxygen, pH and amount of chlorophyll in the water at each layer we encounter. We pump water from the most intriguing layers up to the boat and fill a myriad of bottles and tubes, each destined for a different chemical or biological analysis.

My colleagues and I have homed in on Deming Lake to explore questions about how microbial life adapted to and changed the environmental conditions on early Earth. Our planet was inhabited only by microbes for most of its history. The atmosphere and the oceans’ depths didn’t have much oxygen, but they did have a lot of iron, just like Deming Lake does. By investigating what Deming Lake’s microbes are doing, we can better understand how billions of years ago they helped to transform the Earth’s atmosphere and oceans into what they’re like now.

Layer by layer, into the lake

Two and a half billion years ago, ocean waters had enough iron to form today’s globally distributed rusty iron deposits called banded iron formations that supply iron for the modern global steel industry. Nowadays, oceans have only trace amounts of iron but abundant oxygen. In most waters, iron and oxygen are antithetical. Rapid chemical and biological reactions between iron and oxygen mean you can’t have much of one while the other is present.

The rise of oxygen in the early atmosphere and ocean was due to cyanobacteria. These single-celled organisms emerged at least 2.5 billion years ago. But it took roughly 2 billion years for the oxygen they produce via photosynthesis to build up to levels that allowed for the first animals to appear on Earth.

water concentrated on a filter looks pale green
Chlorophyll colors water from the lake slightly green.
Elizabeth Swanner, CC BY-ND

At Deming Lake, my colleagues and I pay special attention to the water layer where the chlorophyll readings jump. Chlorophyll is the pigment that makes plants green. It harnesses sunlight energy to turn water and carbon dioxide into oxygen and sugars. Nearly 20 feet (6 meters) below Deming’s surface, the chlorophyll is in cyanobacteria and photosynthetic algae, not plants.

But the curious thing about this layer is that we don’t detect oxygen, despite the abundance of these oxygen-producing organisms. This is the depth where iron concentrations start to climb to the high levels present at the lake’s bottom.

This high-chlorophyll, high-iron and low-oxygen layer is of special interest to us because it might help us understand where cyanobacteria lived in the ancient ocean, how well they were growing and how much oxygen they produced.

We suspect the reason cyanobacteria gather at this depth in Deming Lake is that there is more iron there than at the top of the lake. Just like humans need iron for red blood cells, cyanobacteria need lots of iron to help catalyze the reactions of photosynthesis.

A likely reason we can’t measure any oxygen in this layer is that in addition to cyanobacteria, there are a lot of other bacteria here. After a good long life of a few days, the cyanobacteria die, and the other bacteria feed on their remains. These bacteria rapidly use up any oxygen produced by still photosynthesizing cyanobacteria the way a fire does as it burns through wood.

We know there are lots of bacteria here based on how cloudy the water is, and we see them when we inspect a drop of this water under a microscope. But we need another way to measure photosynthesis besides measuring oxygen levels.

Long-running lakeside laboratory

The other important function of photosynthesis is converting carbon dioxide into sugars, which eventually are used to make more cells. We need a way to track whether new sugars are being made, and if they are, whether it’s by photosynthetic cyanobacteria. So we fill glass bottles with samples of water from this lake layer and seal them tight with rubber stoppers.

We drive the 3 miles back to the Itasca Biological Station and Laboratories where we will set up our experiments. The station opened in 1909 and is home base for us this week, providing comfy cabins, warm meals and this laboratory space.

In the lab, we inject our glass bottle with carbon dioxide that carries an isotopic tracer. If cyanobacteria grow, their cells will incorporate this isotopic marker.

We had a little help to formulate our questions and experiments. University of Minnesota students attending summer field courses collected decades worth of data in Itasca State Park. A diligent university librarian digitized thousands of those students’ final papers.

My students and I pored over the papers concerning Deming Lake, many of which tried to determine whether the cyanobacteria in the chlorophyll-rich layer are doing photosynthesis. While most indicated yes, those students were measuring only oxygen and got ambiguous results. Our use of the isotopic tracer is trickier to implement but will give clearer results.

woman holds a clear plastic bag aloft, she and man are seated in boat
Graduate students Michelle Chamberlain and Zackry Stevenson about to sink the bottles for incubation in Deming Lake.
Elizabeth Swanner, CC BY-ND

That afternoon, we’re back on the lake. We toss an anchor; attached to its rope is a clear plastic bag holding the sealed bottles of lake water now amended with the isotopic tracer. They’ll spend the night in the chlorophyll-rich layer, and we’ll retrieve them after 24 hours. Any longer than that and the isotopic label might end up in the bacteria that eat the dying cyanobacteria instead of the cyanobacteria themselves. We tie off the rope to a floating buoy and head back to the station’s dining hall for our evening meal.

Iron, chlorophyll, oxygen

The next morning, as we wait for the bottles to finish their incubation, we collect water from the different layers of the lake and add some chemicals that kill the cells but preserve their bodies. We’ll look at these samples under the microscope to figure out how many cyanobacteria are in the water, and we’ll measure how much iron is inside the cyanobacteria.

That’s easier said than done, because we have to first separate all the “needles” (cyanobacteria) from the “hay” (other cells) and then clean any iron off the outside of the cyanobacteria. Back at Iowa State University, we’ll shoot the individual cells one by one into a flame that incinerates them, which liberates all the iron they contain so we can measure it.

rowboat with one woman in it on a lake with woodsy shoreline
Biogeochemist Katy Sparrow rows a research vessel to shore.
Elizabeth Swanner, CC BY-ND

Our scientific hunch, or hypothesis, is that the cyanobacteria that live in the chlorophyll- and iron-rich layer will contain more iron than cyanobacteria that live in the top lake layer. If they do, it will help us establish that greater access to iron is a motive for living in that deeper and dimmer layer.

These experiments won’t tell the whole story of why it took so long for Earth to build up oxygen, but they will help us to understand a piece of it – where oxygen might have been produced and why, and what happened to oxygen in that environment.

Deming Lake is quickly becoming its own attraction for those with a curiosity about what goes on beneath its tranquil surface – and what that might be able to tell us about how new forms of life took hold long ago on Earth.The Conversation

Elizabeth Swanner, Associate Professor of Geology, Iowa State University

This article is republished from The Conversation under a Creative Commons license. Read the original article.

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The Conversation

Being alone has its benefits − a psychologist flips the script on the ‘loneliness epidemic’

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theconversation.com – Virginia Thomas, Assistant Professor of Psychology, Middlebury – 2025-04-04 07:18:00

Studies show that choosing ‘me time’ is not a recipe for loneliness but can boost your creativity and emotional well-being.
FotoDuets/iStock via Getty Images Plus

Virginia Thomas, Middlebury

Over the past few years, experts have been sounding the alarm over how much time Americans spend alone.

Statistics show that we’re choosing to be solitary for more of our waking hours than ever before, tucked away at home rather than mingling in public. Increasing numbers of us are dining alone and traveling solo, and rates of living alone have nearly doubled in the past 50 years.

These trends coincided with the surgeon general’s 2023 declaration of a loneliness epidemic, leading to recent claims that the U.S. is living in an “anti-social century.”

Loneliness and isolation are indeed social problems that warrant serious attention, especially since chronic states of loneliness are linked with poor outcomes such as depression and a shortened lifespan.

But there is another side to this story, one that deserves a closer look. For some people, the shift toward aloneness represents a desire for what researchers call “positive solitude,” a state that is associated with well-being, not loneliness.

As a psychologist, I’ve spent the past decade researching why people like to be alone – and spending a fair amount of time there myself – so I’m deeply familiar with the joys of solitude. My findings join a host of others that have documented a long list of benefits gained when we choose to spend time by ourselves, ranging from opportunities to recharge our batteries and experience personal growth to making time to connect with our emotions and our creativity.

YouTube video
Being alone can help remind people who they are.

So it makes sense to me why people live alone as soon as their financial circumstances allow, and when asked why they prefer to dine solo, people say simply, “I want more me time.”

It’s also why I’m not surprised that a 2024 national survey found that 56% of Americans considered alone time essential for their mental health. Or that Costco is now selling “solitude sheds” where for around US$2,000 you can buy yourself some peace and quiet.

It’s clear there is a desire, and a market, for solitude right now in American culture. But why does this side of the story often get lost amid the warnings about social isolation?

I suspect it has to do with a collective anxiety about being alone.

The stigma of solitude

This anxiety stems in large part from our culture’s deficit view of solitude. In this type of thinking, the desire to be alone is seen as unnatural and unhealthy, something to be pitied or feared rather than valued or encouraged.

This isn’t just my own observation. A study published in February 2025 found that U.S. news headlines are 10 times more likely to frame being alone negatively than positively. This type of bias shapes people’s beliefs, with studies showing that adults and children alike have clear judgments about when it is – and importantly when it is not – acceptable for their peers to be alone.

This makes sense given that American culture holds up extraversion as the ideal – indeed as the basis for what’s normal. The hallmarks of extraversion include being sociable and assertive, as well as expressing more positive emotions and seeking more stimulation than the opposite personality – the more reserved and risk-averse introverts. Even though not all Americans are extraverts, most of us have been conditioned to cultivate that trait, and those who do reap social and professional rewards. In this cultural milieu, preferring to be alone carries stigma.

But the desire for solitude is not pathological, and it’s not just for introverts. Nor does it automatically spell social isolation and a lonely life. In fact, the data doesn’t fully support current fears of a loneliness epidemic, something scholars and journalists have recently acknowledged.

In other words, although Americans are indeed spending more time alone than previous generations did, it’s not clear that we are actually getting lonelier. And despite our fears for the eldest members of our society, research shows that older adults are happier in solitude than the loneliness narrative would lead us to believe.

YouTube video
It’s all a balancing act – along with solitude, you need to socialize.

Social media disrupts our solitude

However, solitude’s benefits don’t automatically appear whenever we take a break from the social world. They arrive when we are truly alone – when we intentionally carve out the time and space to connect with ourselves – not when we are alone on our devices.

My research has found that solitude’s positive effects on well-being are far less likely to materialize if the majority of our alone time is spent staring at our screens, especially when we’re passively scrolling social media.

This is where I believe the collective anxiety is well placed, especially the focus on young adults who are increasingly forgoing face-to-face social interaction in favor of a virtual life – and who may face significant distress as a result.

Social media is by definition social. It’s in the name. We cannot be truly alone when we’re on it. What’s more, it’s not the type of nourishing “me time” I suspect many people are longing for.

True solitude turns attention inward. It’s a time to slow down and reflect. A time to do as we please, not to please anyone else. A time to be emotionally available to ourselves, rather than to others. When we spend our solitude in these ways, the benefits accrue: We feel rested and rejuvenated, we gain clarity and emotional balance, we feel freer and more connected to ourselves.

But if we’re addicted to being busy, it can be hard to slow down. If we’re used to looking at a screen, it can be scary to look inside. And if we don’t have the skills to validate being alone as a normal and healthy human need, then we waste our alone time feeling guilty, weird or selfish.

The importance of reframing solitude

Americans choosing to spend more time alone is indeed a challenge to the cultural script, and the stigmatization of solitude can be difficult to change. Nevertheless, a small but growing body of research indicates that it is possible, and effective, to reframe the way we think about solitude.

For example, viewing solitude as a beneficial experience rather than a lonely one has been shown to help alleviate negative feelings about being alone, even for the participants who were severely lonely. People who perceive their time alone as “full” rather than “empty” are more likely to experience their alone time as meaningful, using it for growth-oriented purposes such as self-reflection or spiritual connection.

Even something as simple as a linguistic shift – replacing “isolation” with “me time” – causes people to view their alone time more positively and likely affects how their friends and family view it as well.

It is true that if we don’t have a community of close relationships to return to after being alone, solitude can lead to social isolation. But it’s also true that too much social interaction is taxing, and such overload negatively affects the quality of our relationships. The country’s recent gravitational pull toward more alone time may partially reflect a desire for more balance in a life that is too busy, too scheduled and, yes, too social.

Just as connection with others is essential for our well-being, so is connection with ourselves.The Conversation

Virginia Thomas, Assistant Professor of Psychology, Middlebury

This article is republished from The Conversation under a Creative Commons license. Read the original article.

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Measles can ravage the immune system and brain, causing long-term damage – a virologist explains

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theconversation.com – Peter Kasson, Professor of Chemistry and Biomedical Engineering, Georgia Institute of Technology – 2025-03-31 07:16:00

Measles infections send 1 in 5 people to the hospital.
wildpixel/ iStock via Getty Images Plus

Peter Kasson, Georgia Institute of Technology

The measles outbreak that began in west Texas in late January 2025 continues to grow, with 400 confirmed cases in Texas and more than 50 in New Mexico and Oklahoma as of March 28.

Public health experts believe the numbers are much higher, however, and some worry about a bigger resurgence of the disease in the U.S. In the past two weeks, health officials have identified potential measles exposures in association with planes, trains and automobiles, including at Washington Dulles International Airport and on an Amtrak train from New York City to Washington, D.C. – as well as at health care facilities where the infected people sought medical attention.

Measles infections can be extremely serious. So far in 2025, 14% of the people who got measles had to be hospitalized. Last year, that number was 40%. Measles can damage the lungs and immune system, and also inflict permanent brain damage. Three in 1,000 people who get the disease die. But because measles vaccination programs in the U.S. over the past 60 years have been highly successful, few Americans under 50 have experienced measles directly, making it easy to think of the infection as a mere childhood rash with fever.

As a biologist who studies how viruses infect and kill cells and tissues, I believe it is important for people to understand how dangerous a measles infection can be.

Underappreciated acute effects

Measles is one of the most contagious diseases on the planet. One person who has it will infect nine out of 10 people nearby if those people are unvaccinated. A two-dose regimen of the vaccine, however, is 97% effective at preventing measles.

When the measles virus infects a person, it binds to specific proteins on the surface of cells. It then inserts its genome and replicates, destroying the cells in the process. This first happens in the upper respiratory tract and the lungs, where the virus can damage the person’s ability to breathe well. In both places, the virus also infects immune cells that carry it to the lymph nodes, and from there, throughout the body.

YouTube video
Measles can wipe out immune cells’ ability to recognize pathogens.

What generally lands people with measles in the hospital is the disease’s effects on the lungs. As the virus destroys lung cells, patients can develop viral pneumonia, which is characterized by severe coughing and difficulty breathing. Measles pneumonia afflicts about 1 in 20 children who get measles and is the most common cause of death from measles in young children.

The virus can directly invade the nervous system and also damage it by causing inflammation. Measles can cause acute brain damage in two different ways: a direct infection of the brain that occurs in roughly 1 in 1,000 people, or inflammation of the brain two to 30 days after infection that occurs with the same frequency. Children who survive these events can have permanent brain damage and impairments such as blindness and hearing loss.

Yearslong consequences of infection

An especially alarming but still poorly understood effect of measles infection is that it can reduce the immune system’s ability to recognize pathogens it has previously encountered. Researchers had long suspected that children who get the measles vaccine also tend to have better immunity to other diseases, but they were not sure why. A study published in 2019 found that having a measles infection destroyed between 11% and 75% of their antibodies, leaving them vulnerable to many of the infections to which they previously had immunity. This effect, called immune amnesia, lasts until people are reinfected or revaccinated against each disease their immune system forgot.

Occasionally, the virus can lie undetected in the brain of a person who recovered from measles and reactivate typically seven to 10 years later. This condition, called subacute sclerosing panencephalitis, is a progressive dementia that is almost always fatal. It occurs in about 1 in 25,000 people who get measles but is about five times more common in babies infected with measles before age 1.

Researchers long thought that such infections were caused by a special strain of measles, but more recent research suggests that the measles virus can acquire mutations that enable it to infect the brain during the course of the original infection.

There is still much to learn about the measles virus. For example, researchers are exploring antibody therapies to treat severe measles. However, even if such treatments work, the best way to prevent the serious effects of measles is to avoid infection by getting vaccinated.The Conversation

Peter Kasson, Professor of Chemistry and Biomedical Engineering, Georgia Institute of Technology

This article is republished from The Conversation under a Creative Commons license. Read the original article.

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Supreme Court considers whether states may prevent people covered by Medicaid from choosing Planned Parenthood as their health care provider

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theconversation.com – Naomi Cahn, Professor of Law, University of Virginia – 2025-04-02 17:04:00

Planned Parenthood clinics, like this one in Los Angeles, are located across the United States.
Patrick T. Fallon/AFP via Getty Images

Naomi Cahn, University of Virginia and Sonia Suter, George Washington University

Having the freedom to choose your own health care provider is something many Americans take for granted. But the Supreme Court is weighing whether people who rely on Medicaid for their health insurance have that right, and if they do – is it enforceable by law?

That’s the key question at the heart of a case, Medina v. Planned Parenthood South Atlantic, that began during President Donald Trump’s first term in office.

“There’s a right, and the right is the right to choose your doctor,” said Justice Elena Kagan on April 2, 2025, during oral arguments on the case. John J. Bursch, the Alliance Defending Freedom lawyer who is representing South Carolina Director of Health and Human Services Eunice Medina, countered that none of the words in the underlying statute had what he called a “rights-creating pedigree.”

As law professors who teach courses about health and poverty law as well as reproductive justice, we think this case could affect access to health care for 72 million Americans, including low-income people and their children and people with disabilities.

Excluding Planned Parenthood

The case started with Julie Edwards, who is enrolled in Medicaid and lives in South Carolina. After she struggled to get contraceptive services, she was able to receive care from a Planned Parenthood South Atlantic clinic in Columbia, South Carolina.

Planned Parenthood, an array of nonprofits with roots that date back more than a century, is among the nation’s top providers of reproductive services. It operates two clinics in South Carolina, where Medicaid patients can get physical exams, cancer screenings, contraception and other services. It also provides same-day appointments and keeps long hours.

In July 2018, however, South Carolina Gov. Henry McMaster issued an executive order that barred health care providers in South Carolina that offer abortions from reimbursement through Medicaid.

That meant Planned Parenthood, a longtime target of conservatives’ ire, would no longer be reimbursed for any type of care for Medicaid patients, preventing Edwards from transferring all her gynecological care to that office as she had hoped to do.

Planned Parenthood and Edwards sued South Carolina, claiming that the state was violating the federal Medicare and Medicaid Act, which Congress passed in 1965, by not letting Edwards obtain care from the provider of her choice.

A ‘free-choice-of-provider’ requirement

Medicaid operates as a partnership between the federal government and the states. Congress passed the law that led to its creation based on its power under the Constitution’s spending clause, which allows Congress to subject federal funds to certain requirements.

Two years later, due to concerns that states were restricting which providers Medicaid recipients could choose, Congress added a “free-choice-of-provider” requirement to the program. It states that people enrolled in Medicaid “may obtain such assistance from any institution, agency, community pharmacy, or person, qualified to perform the service or services required.”

This provision is at the core of this case. At issue is whether a civil rights statute provides a right for Medicaid beneficiaries to sue a state when their federal rights have been violated. Known as Section 1983, it was enacted in 1871.

Bursch, backed by the Trump administration, argued before the court that the absence of words like “right” in the Medicaid provision that requires states to provide a free choice of provider means that neither Edwards nor Planned Parenthood has the authority to file a lawsuit to enforce this aspect of the Medicaid statute.

Nicole A. Saharsky, Planned Parenthood’s lawyer, argued that the creation of a right shouldn’t depend on “some kind of magic words test.” Instead, she said it was clear that the Medicaid statute created “a right to choose their own doctor” because “it’s mandatory” that the state provide this option to everyone with health insurance through Medicaid.

She also emphasized that Congress wanted to protect “an intensely personal right” to be able “to choose your doctor, the person that you see when you’re at your most vulnerable, facing … some of the most significant … challenges to your life and your health.”

Restricting Medicaid funds

Through a federal law known as the Hyde Amendment, Medicaid cannot reimburse health care providers for the cost of abortions, with a few exceptions: when a patient’s life is at risk or her pregnancy is due to rape or incest. Some states do cover abortion when their laws allow it, without using any federal funds.

Therefore, Planned Parenthood only gets federal Medicaid funds for abortions in those limited circumstances.

McMaster explained that he removed “abortion clinics,” including Planned Parenthood, from the South Carolina Medicaid Program because he didn’t want state funds to indirectly subsidize abortions.

South Carolina “decided that Planned Parenthood was unqualified for many reasons, chiefly because they’re the nation’s largest abortion provider,” Bursch told the Supreme Court.

But only 3% of Planned Parenthood’s services nationwide last year were related to abortion. Its most common service is testing for sexually transmitted diseases. Across the nation, Planned Parenthood provides health care to more than 2 million patients per year, most of whom have low incomes.

Man with gray hair in a suit and red tie speaks at a podium.
South Carolina Gov. Henry McMaster speaks to a crowd during an election night party on Nov. 3, 2020, in Columbia.
Photo by Sean Rayford/Getty Images

Section 1983

Because the Medicaid statute itself does not allow an individual to sue, Edwards and Planned Parenthood are relying on Section 1983.

Lower courts have repeatedly upheld that the Medicaid statute provides Edwards with the right to obtain Medicaid-funded health care at her local Planned Parenthood clinic.

And the Supreme Court has long recognized that Section 1983 protects an individual’s ability to sue when their rights under a federal statute have been violated.

In 2023, for example, the court found such a right under the Medicaid Nursing Home Reform Act. The court held that Section 1983 confers the right to sue when a statute’s provisions “unambiguously confer individual federal rights.”

Consequences beyond South Carolina

The court’s decision in the Medina case on whether Medicaid patients can choose their own health care provider could have consequences far beyond South Carolina. Arkansas, Missouri and Texas have already barred Planned Parenthood from getting reimbursed by Medicaid for any kind of health care. More states could follow suit.

In addition, given Planned Parenthood’s role in providing expansive contraceptive care, disqualifying it from Medicaid could harm access to health care and increase the already-high unintended pregnancy rate in America.

The ramifications, likewise, could extend beyond the finances of Planned Parenthood.

If the court rules in South Carolina’s favor, states could also try to exclude providers based on other characteristics, such as whether their employees belong to unions or if they provide their patients with gender-affirming care, further restricting patients’ choices.

Or, as Kagan observed, states could go the opposite direction and exclude providers that don’t provide abortions and so forth. What’s really at stake, she said, is whether a patient is “entitled to see” the provider they choose regardless of what their state happens to “think about contraception or abortion or gender transition treatment.”

If the Supreme Court rules that Edwards does have a right to get health care at a Planned Parenthood clinic, the controversy would not be over. The lower courts would then have to decide whether South Carolina appropriately removed Planned Parenthood from Medicaid as an “unqualified provider.”

And if the Supreme Court rules in favor of South Carolina, then Planned Parenthood could still sue South Carolina over its decision to find them to be unqualified.The Conversation

Naomi Cahn, Professor of Law, University of Virginia and Sonia Suter, Professor of Law, George Washington University

This article is republished from The Conversation under a Creative Commons license. Read the original article.

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