This page details the
Class Action for Reproductive Rights
File in the Southern District of Iowa
Wilson et al v. Trump et al
by Sondra Wilson. Written April 25, 2025. Updated August 23, 2025.

As Governor, not only do I plan to codify the right to abortion, I have already filed a petition to commence Wilson et al v. Trump et al, demanding restitution damages for five classes of persons who have been impacted by various political attacks happening due to color of law crimes occurring nationally and from within our state. I am currently in the process of preparing an amended petition and building this website to alert the public.

This page contains a public notice, to help Iowans understand why the constitutional right to abortion supersedes majority rule, followed by an initial draft of the “abortion rights” section of the Amended Petition for Wilson et al v. Trump et al.

 

Public Notice
Why Abortion Rights Are Protected by the U.S. Constitution

Many people believe abortion is just a political issue, one that can be decided by votes in a state legislature. That is not true. Abortion is a constitutional right, and the Constitution overrides majority rule.

The Ninth Amendment Protects Unenumerated Rights

The Ninth Amendment to the U.S. Constitution provides that “[t]he enumeration in the Constitution, of certain rights, shall not be construed to deny or disparage others retained by the people” (U.S. Const. amend. IX). This means that the rights written in the Bill of Rights are not the only rights people have. Americans also retain other fundamental liberties, even if they are not spelled out word for word. These are called “unenumerated rights.”

One of these unenumerated rights is the right to control one’s own reproductive choices, including whether to continue or end a pregnancy. For nearly fifty years, the Supreme Court recognized abortion as part of this liberty in Roe v. Wade (1973) and reaffirmed it in Planned Parenthood v. Casey (1992).

As Justice Benjamin Cardozo explained, bills of rights are not meant to narrowly define liberty but to guarantee its preservation: “Bills of rights give assurance to the individual of the preservation of his liberty. They do not define the liberty they promise” (Cardozo, 1928, p. 97).

The Constitution Is Stronger Than Majority Votes

The Constitution exists to protect individuals from the will of the majority when the majority seeks to strip away fundamental freedoms. That is why freedom of speech, freedom of religion, and freedom from cruel punishment do not disappear just because a majority of people vote against them.

As the Supreme Court declared in West Virginia State Board of Education v. Barnette (1943):

“The very purpose of a Bill of Rights was to withdraw certain subjects from the vicissitudes of political controversy… Fundamental rights may not be submitted to vote; they depend on the outcome of no elections” (p. 638).

In other words, even if many people or even an entire state believe abortion is wrong, they cannot vote away your constitutional liberty.

Separation of Church and State Exists for a Reason

Many who oppose abortion do so from personal or religious belief. They are entitled to those beliefs — but the government is not allowed to impose them on everyone else. That is why the Constitution separates church and state.

The Framers knew that religious majorities, left unchecked, could use the law to force their beliefs on minorities. That is precisely what has happened with abortion bans. Legislators turned private moral opinions into law, depriving millions of people of a personal freedom the Constitution protects (Levy, 1994).

Abortion as an Unalienable Right

The Declaration of Independence affirms that all people are endowed with unalienable rights — rights that cannot be taken away by government — including “life, liberty, and the pursuit of happiness” (1776). Control over one’s own body, health, and future is inseparable from liberty and happiness.

Veterans fought and died to defend these rights. It dishonors their sacrifice to allow politicians to strip away liberties guaranteed by the Constitution.

Why This Matters

When Iowa legislators passed the six-week abortion ban, and when Governor Kim Reynolds signed it into law, they did not just pass “a policy.” They violated the Constitution. By acting “under color of law” to deprive people of rights, they committed both a crime and a civil wrong.

• Crime: Federal law (18 U.S.C. §§ 241–242) makes it illegal for officials to conspire to take away constitutional rights.

• Tort: Civil rights laws (42 U.S.C. §§ 1983, 1985, 1986) give people the right to sue when their liberties are taken.

Abortion is not a privilege that governments may grant or withhold at will. It is a fundamental constitutional right — rooted in the Ninth Amendment, protected by the Fourteenth, and inseparable from the very meaning of liberty.

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👉 Bottom line: No legislature, no governor, no president, no court majority — and no religious belief system — can override the Constitution’s guarantee of liberty. The right to abortion is unalienable, and Americans must demand its restoration.

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References

Barnette, W. V. State Bd. of Educ., 319 U.S. 624 (1943).
Cardozo, B. N. (1928). The paradoxes of legal science. Columbia University Press.
Declaration of Independence, U.S. (1776).
Levy, L. W. (1994). The establishment clause: Religion and the First Amendment. University of North Carolina Press.
Planned Parenthood v. Casey, 505 U.S. 833 (1992).
Roe v. Wade, 410 U.S. 113 (1973).
U.S. Const. amend. IX.

The following will be dropped into the amended petition for Wilson et al v. Trump et al. To collaborate on this, contact WildWillpowerPAC@gmail.com.

Amended Petition — Reproductive Rights Section

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Overview of Case

This case arises from a coordinated and ongoing conspiracy by federal and state officials, political parties, and legislators to deprive Plaintiffs of reproductive rights secured by the U.S. Constitution. Plaintiffs bring this action pro se under the Ninth and Fourteenth Amendments, the Civil Rights Act (42 U.S.C. §§ 1983, 1985, 1986), and multiple provisions of Title 18 of the United States Code, including conspiracy against rights (18 U.S.C. § 241), deprivation of rights under color of law (18 U.S.C. § 242), extortion (18 U.S.C. § 872), perjury of oath (18 U.S.C. § 1621), conspiracy to defraud the United States (18 U.S.C. § 371), and racketeering (18 U.S.C. §§ 1961–1964).

Defendants include President Donald J. Trump; the Republican National Committee (RNC); Iowa Governor Kimberly K. Reynolds; the Republican Party of Iowa; and ninety Republican legislators of the Iowa House and Senate, all named in their personal capacities. Defendants acted knowingly, willfully, and in concert to strip Plaintiffs and the protected class of a longstanding prescriptive liberty: the right to abortion, recognized in Roe v. Wade (1973), reaffirmed in Planned Parenthood v. Casey (1992), and extinguished by partisan capture in Dobbs v. Jackson Women’s Health Organization (2022).

The injury is continuous and ongoing. By enacting and enforcing Iowa’s six-week abortion ban (HF 732), Defendants deprived Plaintiffs of reproductive liberty, denied medically necessary care, and subjected an entire class of persons—those capable of pregnancy—to unequal treatment under color of law. These actions violate the Ninth and Fourteenth Amendments, federal civil rights statutes, and constitute criminal conduct under Title 18.

The conspiracy is further aggravated by Defendants’ reliance on “states’ rights” arguments, the same legal justification once invoked to defend slavery and segregation. Such reasoning cannot override constitutional liberty. As the Supreme Court held in West Virginia State Board of Education v. Barnette (1943), “fundamental rights may not be submitted to vote; they depend on the outcome of no elections” (p. 638).

Plaintiffs seek the following relief:

• Declaratory judgment that HF 732 is unconstitutional and that Dobbs was structurally defective;

• Injunctive relief permanently barring enforcement of HF 732 and similar laws;

• Compensatory and punitive damages under §§ 1983, 1985, and 1986;

• Treble damages and forfeiture under the Racketeer Influenced and Corrupt Organizations Act (RICO);

• Criminal referral for violations of 18 U.S.C. §§ 241, 242, 872, 1621, and 371;

• Attorney’s fees and costs pursuant to 42 U.S.C. § 1988; and

• Such other relief as this Court deems just and equitable.

This case is brought not only as a matter of right, but as a matter of legal duty. Under 42 U.S.C. § 1986, any person with knowledge of a conspiracy to deprive constitutional rights, and the power to prevent it, must act. Plaintiffs act here in fulfillment of that duty.

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Reproductive Rights Are Protected by the U.S. Constitution

I. Constitutional Foundations and the Ninth Amendment

The Ninth Amendment guarantees that rights not specifically enumerated in the Bill of Rights are nonetheless “retained by the people” (U.S. Const. amend. IX). Reproductive rights fall within this retained liberty. As Black’s Law Dictionary (10th ed.) defines, bills of rights “give assurance to the individual of the preservation of his liberty. They do not define the liberty they promise.”

Justice Benjamin Cardozo explained:

“Bills of rights give assurance to the individual of the preservation of his liberty. They do not define the liberty they promise. … Liberty became identified with the reign of law. ‘Freedom of men under government,’ says Locke, ‘is to have a standing rule to live by…’ The individual may not be singled out from among his fellows, and made the victim of the shafts of malice” (Cardozo, 1928, p. 97).

By criminalizing abortion, Defendants singled out a class of persons—those capable of pregnancy—for deprivation of liberty, violating the Ninth and Fourteenth Amendments.

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II. Longstanding Prescriptive Right to Abortion

In Roe v. Wade (410 U.S. 113, 1973), the Supreme Court recognized that women possess the inherent right to choose abortion. For over fifty years, this right operated as a prescriptive constitutional liberty. Planned Parenthood v. Casey (505 U.S. 833, 1992) reaffirmed this principle, declaring: “at the heart of liberty is the right to define one’s own concept of existence” (p. 851).

Reproductive rights are further defined as “a person’s constitutionally protected rights relating to the control of his or her procreative activities; specifically, the cluster of civil liberties relating to pregnancy, abortion, and sterilization” (Black’s Law Dictionary, 10th ed.).

The Equal Protection Clause (U.S. Const. amend. XIV, § 1) extends these liberties to women, men, transgender, and nonbinary persons. The right to abortion is therefore a longstanding constitutional right across classes, protected against state interference.

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III. The Structural Defect in Dobbs and “States’ Rights” as Oppression

The majority in Dobbs v. Jackson Women’s Health Organization (597 U.S. 215, 2022) was composed of Justices whose partiality was known in advance—Neil Gorsuch, Brett Kavanaugh, and Amy Coney Barrett—appointed by Donald J. Trump specifically to overturn Roe. They were nominated and confirmed through partisan processes orchestrated by the Republican Party and RNC, not as neutral arbiters but as co-conspirators. Their decision was not impartial adjudication but partisan capture (Caperton v. A.T. Massey Coal Co., 556 U.S. 868, 2009; In re Murchison, 349 U.S. 133, 1955).

Defendants claim abortion is for “the states to decide.” This “states’ rights” justification is historically discredited. It was the same argument advanced in Dred Scott v. Sandford (60 U.S. 393, 1857) to defend slavery, and later to uphold segregation under Jim Crow. As the Court held in West Virginia State Board of Education v. Barnette (319 U.S. 624, 1943), fundamental rights “may not be submitted to vote; they depend on the outcome of no elections” (p. 638).

Thus, “states’ rights” cannot be invoked to deny reproductive liberty. It is a recycled framework for oppression, constitutionally void.

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IV. Ongoing Injury and Standing

Plaintiffs suffer a continuing injury: the loss of reproductive liberty secured for half a century. Denials of medically necessary abortion care—including ectopic pregnancy treatment—constitute ongoing constitutional and statutory violations. Each day HF 732 remains in effect perpetuates the injury.

42 U.S.C. § 1986 (2022) imposes a duty to act: any person with knowledge of a conspiracy to deprive rights, who has power to prevent it, and neglects to act, is personally liable. Defendants knowingly failed to prevent ongoing deprivation, and instead conspired to enact and enforce it.

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V. Crimes and Torts Under Federal Law

A. Color of Law Crimes

• 18 U.S.C. § 241 criminalizes conspiracies to injure or oppress individuals in the exercise of constitutional rights (Conspiracy against rights, 2022).

• 18 U.S.C. § 242 criminalizes willful deprivations of rights under color of law (Deprivation of rights under color of law, 2022).

B. Civil Conspiracy and Duty

• 42 U.S.C. § 1985(3) provides a right of action against conspirators who deprive persons or classes of equal protection (Conspiracy to interfere with civil rights, 2022).

• 42 U.S.C. § 1986 imposes liability for neglect to prevent such conspiracies (Action for neglect to prevent, 2022).

C. Extortion and Abuse of Office
Governor Kim Reynolds, by signing HF 732, unlawfully “took” a constitutionally protected right under color of office, constituting extortion under 18 U.S.C. § 872 (Extortion by officers or employees of the United States, 2022). Extortion includes “taking more than is due, or before it is due” (Bush v. State, 19 Ariz. 195, 1919).

D. Racketeering (RICO)
The Republican Party of Iowa and the RNC operated as enterprises engaged in racketeering activity (18 U.S.C. §§ 1961–1964, Racketeer Influenced and Corrupt Organizations Act, 2022). Civil RICO provides treble damages (18 U.S.C. § 1964(c)).

E. Perjury of Oath and High Crimes

• President Trump swore on January 20, 2025, to preserve, protect, and defend the Constitution (U.S. Const. art. II, § 1).

• Governor Reynolds swore on January 13, 2023, to support the U.S. and Iowa Constitutions (Des Moines Register, 2023).

By conspiring to strip rights, both violated their oaths, constituting perjury of oath under 18 U.S.C. § 1621 (Perjury, 2022) and conspiracy to defraud under 18 U.S.C. § 371 (Conspiracy to defraud the United States, 2022).

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VI. Defendants (Individually Named, in Their Personal Capacities)

The following Defendants, each acting in their individual capacity, knowingly and willfully conspired under color of law to deprive Plaintiffs of reproductive rights. Each Defendant is personally liable under 18 U.S.C. §§ 241, 242, 872, 1621, 371; 18 U.S.C. §§ 1961–1964 (RICO); and 42 U.S.C. §§ 1983, 1985, 1986.

A. Federal Co-Conspirators

1. Donald J. Trump (President of the United States)

2. Republican National Committee (RNC)

B. State Executive Co-Conspirators
3. Kimberly K. Reynolds (Governor of Iowa)
4. Republican Party of Iowa

C. State Legislative Co-Conspirators

(Iowa House Republicans who voted for HF 732)
5. Rep. Eddie Andrews (R-Johnston)
6. Rep. Brian Best (R-Glidden)
7. Rep. Brooke Boden (R-Indianola)
8. Rep. Jacob Bossman (R-Sioux City)
9. Rep. Steve Bradley (R-Cascade)
10. Rep. Taylor Collins (R-Mediapolis)
11. Rep. Dave Deyoe (R-Nevada)
12. Rep. Jon Dunwell (R-Newton)
13. Rep. Dean Fisher (R-Montour)
14. Rep. Joel Fry (R-Osceola)
15. Rep. Dan Gehlbach (R-Urbandale)
16. Rep. Tom Gerhold (R-Atkins)
17. Rep. Cindy Golding (R-Cedar Rapids)
18. Rep. Martin Graber (R-Fort Madison)
19. House Speaker Pat Grassley (R-New Hartford)
20. Rep. Stan Gustafson (R-Norwalk)
21. Rep. Bill Gustoff (R-Des Moines)
22. Rep. Austin Harris (R-Moulton)
23. Rep. Helena Hayes (R-New Sharon)
24. Rep. Robert Henderson (R-Sioux City)
25. Rep. Steven Holt (R-Denison)
26. Rep. Heather Hora (R-Washington)
27. Rep. Chad Ingels (R-Randalia)
28. Rep. Tom Jeneary (R-Le Mars)
29. Rep. Craig Johnson (R-Independence)
30. Rep. Megan Jones (R-Sioux Rapids)
31. Rep. Bobby Kaufmann (R-Wilton)
32. Rep. Shannon Latham (R-Sheffield)
33. Rep. Shannon Lundgren (R-Peosta)
34. Rep. Josh Meggers (R-Grundy Center)
35. Rep. Ann Meyer (R-Fort Dodge)
36. Rep. Gary Mohr (R-Bettendorf)
37. Rep. Norlin Mommsen (R-DeWitt)
38. Rep. Tom Moore (R-Griswold)
39. Rep. Carter Nordman (R-Panora)
40. Rep. Anne Osmundson (R-Volga)
41. Rep. Matthew Rinker (R-Burlington)
42. Rep. Mike Sexton (R-Rockwell City)
43. Rep. Brad Sherman (R-Williamsburg)
44. Rep. Jeff Shipley (R-Birmingham)
45. Rep. David Sieck (R-Glenwood)
46. Rep. Brent Siegrist (R-Council Bluffs)
47. Rep. Ray Sorensen (R-Greenfield)
48. Rep. Luana Stoltenberg (R-Davenport)
49. Rep. Henry Stone (R-Forest City)
50. Rep. Mark Thompson (R-Clarion)
51. Rep. Phil Thompson (R-Boone)
52. Rep. Charley Thomson (R-Charles City)
53. Rep. Mike Vondran (R-Davenport)
54. Rep. Skyler Wheeler (R-Hull)
55. Rep. John Wills (R-Spirit Lake)
56. Rep. Hans Wilz (R-Ottumwa)
57. Rep. Matt Windschitl (R-Missouri Valley)
58. Rep. Devon Wood (R-New Market)
59. Rep. Derek Wulf (R-Hudson)
60. Rep. David Young (R-Van Meter)

(Iowa Senate Republicans who voted for HF 732)
61. Sen. Mike Bousselot (R-Ankeny)
62. Sen. Waylon Brown (R-Osage)
63. Sen. Mark Costello (R-Imogene)
64. Sen. Chris Cournoyer (R-LeClaire)
65. Sen. Dan Dawson (R-Council Bluffs)
66. Sen. Rocky De Witt (R-Lawton)
67. Sen. Adrian Dickey (R-Packwood)
68. Sen. Dawn Driscoll (R-Williamsburg)
69. Sen. Jeff Edler (R-State Center)
70. Sen. Lynn Evans (R-Aurelia)
71. Sen. Julian Garrett (R-Indianola)
72. Sen. Jesse Green (R-Harcourt)
73. Sen. Kerry Gruenhagen (R-Walcott)
74. Sen. Dennis Guth (R-Klemme)
75. Sen. Carrie Koelker (R-Dyersville)
76. Sen. Tim Kraayenbrink (R-Fort Dodge)
77. Sen. Mark Lofgren (R-Muscatine)
78. Sen. Charlie McClintock (R-Alburnett)
79. Sen. Jeff Reichman (R-Montrose)
80. Sen. Dave Rowley (R-Spirit Lake)
81. Sen. Ken Rozenboom (R-Pella)
82. Sen. Sandy Salmon (R-Janesville)
83. Sen. Jason Schultz (R-Schleswig)
84. Sen. Tom Shipley (R-Nodaway)
85. Sen. Amy Sinclair (R-Allerton)
86. Sen. Annette Sweeney (R-Alden)
87. Sen. Jeff Taylor (R-Sioux Center)
88. Sen. Scott Webster (R-Bettendorf)
89. Sen. Cherielynn Westrich (R-Ottumwa)
90. Sen. Jack Whitver (R-Grimes)
91. Sen. Brad Zaun (R-Urbandale)
92. Sen. Dan Zumbach (R-Ryan)

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VII. Defendant Liability Table

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VIII. Prayer for Relief

Plaintiffs request that the Court:

1. Declare HF 732 unconstitutional and enjoin its enforcement.

2. Declare Dobbs structurally defective under the Due Process Clause and the Ninth and Fourteenth Amendments.

3. Enter judgment for Plaintiffs under 42 U.S.C. §§ 1983, 1985, and 1986.

4. Award compensatory and punitive damages.

5. Award treble damages and forfeiture under 18 U.S.C. §§ 1961–1964 (RICO).

6. Refer Defendants for criminal investigation under 18 U.S.C. §§ 241, 242, 872, 1621, and 371.

7. Award attorney’s fees and costs under 42 U.S.C. § 1988.

8. Grant such other relief as the Court deems just and proper.

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References

Amar, A. R. (1998). The Bill of Rights: Creation and reconstruction. Yale University Press.
Black’s Law Dictionary (10th ed.). (2014). Thomson Reuters.
Bush v. State, 19 Ariz. 195, 168 P. 508 (1919).
Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009).
Cardozo, B. N. (1928). The paradoxes of legal science. Columbia University Press.
Conspiracy against rights, 18 U.S.C. § 241 (2022). https://www.law.cornell.edu/uscode/text/18/241
Deprivation of rights under color of law, 18 U.S.C. § 242 (2022). https://www.law.cornell.edu/uscode/text/18/242
Dobbs v. Jackson Women’s Health Organization, 597 U.S. 215 (2022).
Dred Scott v. Sandford, 60 U.S. 393 (1857).
Ex parte Young, 209 U.S. 123 (1908).
Extortion by officers or employees of the United States, 18 U.S.C. § 872 (2022). https://www.law.cornell.edu/uscode/text/18/872
Griswold v. Connecticut, 381 U.S. 479 (1965).
Hafer v. Melo, 502 U.S. 21 (1991).
In re Murchison, 349 U.S. 133 (1955).
Loving v. Virginia, 388 U.S. 1 (1967).
Perjury, 18 U.S.C. § 1621 (2022). https://www.law.cornell.edu/uscode/text/18/1621
Planned Parenthood v. Casey, 505 U.S. 833 (1992).
Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. §§ 1961–1964 (2022). https://www.law.cornell.edu/uscode/text/18/1961
Roe v. Wade, 410 U.S. 113 (1973).
United States v. Virginia, 518 U.S. 515 (1996).
West Virginia State Board of Education v. Barnette, 319 U.S. 624 (1943).
Action for neglect to prevent, 42 U.S.C. § 1986 (2022). https://www.law.cornell.edu/uscode/text/42/1986
Civil action for deprivation of rights, 42 U.S.C. § 1983 (2022). https://www.law.cornell.edu/uscode/text/42/1983
Conspiracy to interfere with civil rights, 42 U.S.C. § 1985(3) (2022). https://www.law.cornell.edu/uscode/text/42/1985
Conspiracy to defraud the United States, 18 U.S.C. § 371 (2022). https://www.law.cornell.edu/uscode/text/18/371