abortion was not a winning political strategy. some anti-abortion activists grew more aggressive and violent in the face of political abandonment, culminating with the murder of dr. david gunn in 1993 and the passage of the freedom of access to clinic entrances act in 1994. with direct action discredited, anti-abortion organizations, including the national right to life committee, came to the forefront of the movement. these focused on legal tactics, including lobbying against late-term abortions and access to mifepristone and demanding legislation based on the purported abc link. more recently, anti-abortion organizations have turned to lobbying to increase obstacles to abortion, such as mandated counseling, waiting periods, and parental notification, and some feel that anti-abortion advocates treat abc as simply another tactic in their campaign against abortion. there have been ongoing and incremental legal challenges to abortion in the united states by anti-abortion groups. in 2005, a canadian anti-abortion organization put up billboards in alberta with large pink ribbons and the statement: "stop the cover-up", in reference to the abc hypothesis. the canadian breast cancer foundation was concerned by the misrepresentation of the state of scientific knowledge on the subject. the continued focus on the abc hypothesis by anti-abortion groups has fostered a confrontational political environment. anti-abortion advocates and scientists alike have responded with criticisms. the claims by anti-abortion advocates are sometimes referred to as pseudoscience. during the late 1990s, several members of the united states congress became involved in the abc issue. in a 1998 hearing on cancer research, u.s. representative tom coburn accused the national cancer institute of misleading the public by selectively releasing data. in 1999, shortly after the house debated fda approval of the abortion drug mifepristone, u.s. representative dave weldon wrote a "dear colleague" letter, enclosing an article from john kindley. in it, weldon expressed concern that the majority of studies indicated a possible abc link and that politicization was "preventing vital information from being given to women." as of 2019, abortion counseling materials in alaska, kansas, mississippi, oklahoma, and texas incorrectly assert a possible link between abortion and breast cancer, while minnesota materials correctly report no link. similar legislation requiring notification has also been introduced in 14 other states. an editor for the american journal of public health expressed concern that these bills propose warnings that do not agree with established scientific findings. bioethicist jacob m. appel argues that the mandatory disclosure statutes might be unconstitutional on "rational basis" grounds. childbirth is significantly more dangerous than abortion, data that is not required in any disclosure law but which is necessary for a meaningful understanding of risks. according to appel, "f the roughly fifty million abortions that have occurred in the united states since roe v. wade had all ended in full-term deliveries, approximately five hundred additional women would have died during childbirth." in may 2017, president donald trump appointed charmaine yoest, an anti-abortion activist and proponent of the abortion-breast cancer link, to the post of assistant secretary for public affairs in the department of health and human services. national cancer institute the national cancer institute (nci) has been a target of the anti-abortion movement for the conclusions presented on its website. a report from the committee on oversight and government reform found that in november 2002 the bush administration had altered the nci website. the previous nci analysis had concluded that, while some question regarding an association between abortion and breast cancer existed prior to the mid-1990s, a number of large and well-regarded studies had resolved the issue in the negative. the bush administration removed this analysis and replaced it with the following: he possible relationship between abortion and breast cancer has been examined in over thirty published studies since 1957. some studies have reported statistically significant evidence of an increased risk of breast cancer in women who have had abortions, while others have merely suggested an increased risk. other studies have found no increase in risk among women who have had an interrupted pregnancy. this alteration, which suggested that there was scientific uncertainty on the abc issue, prompted an editorial in the new york times describing it as an "egregious distortion" and a letter to the secretary of health and human services from members of congress. in response to the alteration the nci convened a three-day consensus workshop entitled early reproductive events and breast cancer on 24–26 february 2003. the workshop concluded that induced abortion does not increase a woman's risk of breast cancer, and that the evidence for this had been well established. afterwards, the director of epidemiology research for the american cancer society stated, "his issue has been resolved scientifically ... this is essentially a political debate." brind was the only attendee at the workshop to file a dissenting opinion as a minority report criticizing the conclusions. he contends the workshop evidence and findings were overly controlled by its organizers and that the time allotted was too short for a thorough review of the literature. north dakota lawsuit in january 2000, amy jo kjolsrud (née mattson), an anti-abortion counselor, sued the red river women's clinic in fargo, north dakota, alleging false advertising. the suit, kjolsrud v. mkb management corporation, alleged that the clinic was misleading women by distributing a brochure quoting a national cancer institute fact sheet on the abc hypothesis. the brochure stated: anti-abortion activists claim that having an abortion increases the risk of developing breast cancer and endangers future childbearing. none of these claims are supported by medical research or established medical organizations. (emphasis in original) the case was originally scheduled for 11 september 2001, but was delayed as a result of the terrorist attacks. on 25 march 2002, the trial began. after four days of testimony, judge michael mcguire ruled in favor of the clinic. linda rosenthal, an attorney from the center for reproductive rights characterized the decision as a rejection of "scare tactics". john kindley, one of the lawyers representing kjolsrud, highlighted the "individual's right to self-determination". kindley also wrote a 1998 wisconsin law review article outlining the viability of medical malpractice lawsuits based upon not informing patients considering abortion about the abc hypothesis. the decision was appealed and on 23 september 2003 the north dakota supreme court ruled that kjolsrud did not have standing and affirmed the lower court ruling dismissing the action. the appeal said that kjolsrud had not read the materials, and that after the lawsuit was filed, the brochures were updated to refute the breast cancer link, citing the national cancer institute.