With the passage of the Freedom of Access to Clinic Entrances Act (F.A.C.E.), and the Supreme Court’s decision in NOW v. Scheidler, pro-life activists who engage in civil disobedience will suffer far greater legal disabilities than have been placed upon other protest movements in American history. But following Madsen, pro-life demonstrators can now take advantage of protections not previously articulated by the Court. So long as they do not engage in repetitive illegalities, pro-life demonstrators can count on strong First Amendment guarantees.