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  • Human Rights Research Center

Sovereignty and God’s Law: Anti-Choice Violence is a Larger Warning from the American Far-Right

June 20, 2024

In 2022, Xavier Batten, Tibet Ergal, and active-duty United States Marine Chance Brannon firebombed a California reproductive health clinic. While Batten and Brannon received multi-year sentences earlier in 2024, Ergal awaits a decision following pleading guilty to all charges. In 2023, Philip J. Buyno drove through the front of an Illinois commercial building with the intention to set the premises ablaze to prevent a reproductive clinic from opening.

These two incidents faced legal repercussions but have yet to be officially classified as acts of terrorism despite fitting several legal and governmental definitions of the term. Though the Federal Bureau of Investigation (FBI) was hesitant to declare violent anti-choice acts as terrorism in the 1980s, the 1990s forced a more stringent approach following an uptick in murders, kidnapping, and bombings. Religious groups turned to a more protest-heavy approach following the terrorism panic after the events of September 11, 2001. However, per the Civil Rights Division of the United States Department of Justice, there have been almost as many federal cases involving attacking reproductive centers–many under the Freedom of Access to Clinic Entrances (FACE) Act–since 2020 than in the entire decade prior.

In 2022, law enforcement mobilized to an extreme prior to the Supreme Court decision announcement overturning 1973 Roe v. Wade. In tandem with increased policing, the COVID-19 pandemic saw right-wing causes increasingly mobilizing on anti-choice actions. Online communities and end-to-end encryption social media apps like WhatsApp and Telegram have increased the ability for decentralized extremist organizing. The 2020s is proving to be a renewed era for right-wing mobilization and anti-choice terror is no exception, alongside legislative rollbacks on reproductive freedom.  


Though attacks on reproductive health care centers occurred as early as the 1970s, full-fledged anti-choice terror was not nationally organized until the 1980s by the extremist Army of God (AOG). The terrorist-designated organization famously detonated a bomb in Atlanta’s Centennial Olympic Park in 1996, injuring at least 75. The group perpetrated murders, kidnappings, stalkings, bombings, arson, and even anthrax threats on clinics, patients, and, most commonly, health care providers.

The doctrine driving anti-choice extremists is that targeting abortion care providers counts as “justifiable homicide.” AOG produced a manual that–alongside directing readers on where and how to acquire and manufacture explosives–provides a religious call to murder:

Our Most Dread Sovereign Lord God requires that whosoever sheds man's blood, by man shall his blood be shed. Not out of hatred of you, but out of love for the persons you exterminate, we are forced to take arms against you.

This biblical justification relies on an extreme belief that places precedent for religious law over the law of the land, also called the “Doctrine of the Lesser Magistrate”. This specific type of extremism calls for the believer to risk their own life or wellbeing to demonstrate or preach doctrine. Though these have slowed due to the FACE Act and terrorist designation of Army of God which deterred less extreme actors, new tactics quickly emerged that continued to have deadly repercussions.

Groups like Operation Rescue–famous for “informational” university campus demonstrations relying on graphic imagery–innovated doxxing campaigns to maneuver around the FACE Act. This included publicizing the names and locations of individual health care providers so as to not be directly engaged in violence. Their information led to the murder of Dr. George Tiller. The group’s senior vice president provided the day-to-day schedule of the physician to his murderer Scott Roeder upon request. The VP herself served a two-year prison sentence for a clinic bombing in 1987.

This is largely how anti-choice organizations operate today: doxxing providers and clinics. This allows them to claim no direct responsibility should an act of violence occur due to their circulated information. Individual actors carry out the violence, threats, and harassment while “activists” provide the knowledge required and rallies at which to network.

By the Numbers

According to the National Consortium for the Study of Terrorism and Responses to Terrorism’s (START) 2013 Department of Homeland Security (DHS) report, in the 1990s, anti-choice violence was the most common form of domestic terrorism at 26%. This dropped to only 7% in the 2000s only because domestic terrorism began to diversify. Animal rights and environmentalist terror grew in popularity. The National Abortion Federation’s (NAF) annual Violence and Disruption Reports did not actually show a decrease in actions as the 2000s went on–just a change in tactics to avoid a classification as “terrorism”. In fact, overall anti-choice actions, violent or otherwise, have increased in sheer numbers exponentially over the last 30 years.

Using the NAF reports, clearer patterns of radicalization and tactic changes come forward. In the period from 1990 to 1999, direct attacks and attempts of bombing, murder, and kidnappings were much more common than today. This waning is likely due to the reversal of FBI willingness to classify anti-choice groups and actions as terrorism leading to more stringent sentences.

From 2020 to 2022 alone, there were over 4,010 violent incidents. This accounts for 70% of all attacks against providers and patients total from 2010 to 2019. Similarly, per the NAF reports, all threats of violence against providers and patients from 2020 to 2022–through mail, phone, e-mail, social media and on-site graffiti–account for nearly 77% of all threats occurring from 2010 to 2019 in a fraction of the time.

Non-lethal tactics like intimidation and clinic disruption boomed in the 2000s comparatively- jumping from a mere 36,509 at the height of the direct action era of the 1990s to 117,444 in the 2000s, 558,847 in the entirety of the 2010s, and 427,404 from just 2020 to 2022.

Physical and digital stalking of providers showed a stark increase in only a single year from 2021 to 2022–229% in all states, with 913% in states like California and Illinois–labeled “protective states”–that provide more security for reproductive rights. Burglary, clinic invasion, bomb threats, and obstruction each saw popularity grow that year. The FACE Act makes obstruction the easiest anti-choice crime to prosecute as demonstrated by blockades making up a majority of related federal charges since 2020. Arson, as seen in the California and Illinois cases, also increased year over year, though at a slower rate.

Notably, in 2022, there were four threats of bio-attacks–a tactic that decreased significantly following the 2001 Amerithrax anthrax attacks. 2002 had the highest instance of bioweapon threats with 554, likely hoping to piggyback on the national panic surrounding the attacks. Previously, no year after 2003 had more than three threats until 2022, with most having none.

Equally concerning is that it is not only single-issue anti-choice groups and individuals carrying out violence, threats, or property damage. The Southern Poverty Law Center notes that in the first half of 2022 alone, the Proud Boys–an armed neo-fascist organization designated as a terrorist organization in Canada, its country of origin–harassed 28 reproductive rights events. According to START, a significant percentage of the Proud Boys membership have military and law enforcement experience. Batten himself was a Marine and has links to the far-right, white supremacist belief in accelerationism, or the belief in creating conditions for a race war. In short, this means armed military-trained individuals are facing off with civilians over reproductive care.

If the California and Illinois attacks–alongside FACE Act convictions–are an indication of trends to come, it is likely that infrastructure terrorism against reproductive clinics will increase. Threats against individuals, stalkings, and other personal attacks are likely to incur heavier hate- or terrorism-related charges and convictions as opposed to property damage.

However, it is important to note that emerging trends in the larger political structure could point to a rise in more serious anti-choice crime. The changes occurring in the American right-wing are focusing more on religious sovereignty than on traditional conservative concerns like tax issues and social service cuts. Reproductive rights are quickly becoming part of a web of issues that the new, religious right is painting as an attack on “American values” to an unprecedented extreme.

The Rest of the Right

Historically, the American right-wing has lagged behind the left in terms of cross-issue, collaborative organizing. The post-2020 era is a clear departure from this tradition. The right is returning to tradition akin to the 1970s anti-Equal Rights Amendment informal coalition of Stop ERA and the still operating Eagle Forum. Today sees right-wing organizations like the Alliance for Defending Freedom focusing less on single issues instead favoring linking LGBTQIA rights, racial equity movements, religious diversity, and immigration as interconnected. The Donald Trump-led Make America Great Again (MAGA) movement has attempted to overturn social policy on those issues, normalizing fringe social attitudes after over a decade of relative growth. MAGA-aligned candidates often upholding extreme views in the 2022 midterm elections saw far more success than Republican candidates still seen as more “mainstream”.

Anti-choice organizations reflect the MAGA movement’s oftentimes reluctant alliance with establishment conservative parties. Operation Rescue’s breakaway organization Operation Save America (OSA) is still functioning and calling for a turn away from the Republican Party toward religious rule. The latter hosted a 2023 event in Atlanta, Georgia that included veiled calls to violence and allusions to right-wing intersectionality highlighting non-abortion related conspiracies involving COVID-19, gun rights, the LGBTQIA community, the 2020 presidential election, the Great Replacement Theory, and, most alarmingly, the Doctrine of the Lesser Magistrate. Speakers called for a “more militant mindset” and stated “you’re going to shed blood in the womb, you’re going to reap it in the streets'' with little elaboration.

An explosion of groups and think tanks like OSA, Moms for Liberty, Alliance Defending Freedom, American Virtue, End Abortion Now, and the Heritage Foundation are normalizing extremist beliefs using the veneer of respectability that comes from using rhetoric like “reason”, “liberty”, and “parental rights”. Christian Right extremists like OSA and the Idaho-based Christian nationalist Christ Church support think tank publications promoting whole abortion bans.

With the rise of groups promoting concepts like the Doctrine of the Lesser Magistrate, adherence to federal, state, and local laws may wane. Christian right and general hate groups alike target reproductive health clinics and rallies, with the SPLC noting multiple fascist and neo-Nazi groups having been involved in clinic disruption since 2018.

Militant support alongside spreading belief in the Doctrine of the Lesser Magistrate is concerning given the exponential increase in abortion-related violence since 2020. With support from various right-wing groups and stricter laws nationwide, extremists may be more likely to act as vigilantes in states more protective of reproductive rights, as seen in California and Illinois.



  • Accelerationism: The belief in destruction of modern liberal, multicultural democracy by heightening existing societal tensions like racism, sexism, and religious bigotry. For example, many white supremacists believe they can derive benefit from movements like Black Lives Matter, Palestine solidarity encampments, and pro-choice rallies due to their perception as divisive by centrist and moderate or even professed apolitical individuals.

  • Christian Right: A general term referring to a variety of movements and ideologies that share right-wing political beliefs that they see as inseparable from their Christian beliefs.

  • Christian Nationalism: More specific than the Christian Right, Christian Nationalism is the belief that legislation should reflect Christian values, specifically. Extreme forms of Christian Nationalism believe in a Christian religious state with, most often, some form of Protestant Evangelical Christianity as the mandated state church. It is not exclusive to the United States, with movements in countries across multiple continents and state churches established in countries like the United Kingdom.

  • Doctrine of the Lesser Magistrate: A Christian belief developed in 1550 that if a government on Earth makes a law that is in violation of the Christian God’s doctrine, then a citizen should follow the latter. Christian nationalists that follow the Doctrine of the Lesser Magistrate are willing to break laws on Earth and face consequences as they interpret such punishments as part of a holy mission or even martyrdom.

  • Doxxing: The act of revealing personal information of an individual or group to the public. This includes but is not limited to full name, work or home address, banking information, personal schedule, automobile identification, and social security numbers. Often, a person or group may intentionally share someone's private information with a hostile audience. For example, British right-wing commentator Milo Yiannapoulos was known for exposing transgender students’ personal information in his speeches at universities.

  • Great Replacement Theory: A conspiracy theory that more open immigration policies in Western nations is an attempt to slowly remove white political and cultural hegemony through interracial marriage and changing voter demographics. Variations of the theory may include antisemitic belief in Jewish elite control, a plot to establish Islamic Sharia Law, and attacks on language rights. Written versions of the Great Replacement Theory have existed since as early as the 1970s in French literature but gained popularity in the early 2010s in France, the United Kingdom, and the United States.

  • Justifiable Homicide: A situation where the benefit of committing homicide against someone outweighs the moral wrong of doing so. For example, hypothetically, it could be justifiable to kill a leader of a genocide to prevent further harm. In the context of this article, proponents of justifiable homicide argue that killing one abortion provider prevents thousands of abortions.

  • Make America Great Again: A term first widely used by then-presidential candidate Ronald Reagan in 1980. It has been subsequently used by presidents Bill Clinton and, most famously, Donald Trump. It has become a blanket term for anti-establishment right-wing movements and politicians that have pledged informal allegiance to Trump or Trump’s ideas. This includes anyone from Republican voters disillusioned with, most commonly, the established Republican or Libertarian parties to militias like the far-right Oath Keepers and the neo-fascist Proud Boys.

  • Terrorism: There is no agreed upon definition of the term–by scholars, governments, or law enforcement. For the purposes of this article, the Federal Bureau of Investigations defines terrorism as “unlawful use of force and violence against persons or property to intimidate or coerce a government, the civilian population, or any segment thereof, in furtherance of political or social objectives.”



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