to perform a post quickening abortion was the death penalty (section 1) and otherwise was transportation for fourteen years (section 2). In the 19th-century United States, there was little regulation of abortion, in the tradition of English common law, pre quickening abortions were considered at most a misdemeanor. These cases proved difficult to prosecute as the testimony of the mother was usually the only means to determine when quickening had occurred. The law was amended in 1828 and 1837 – the latter removed the distinction between women who were quick with child (late pregnancy) and those who were not. It also eliminated the death penalty as a possible punishment. The latter half of the 19th century saw abortion become increasingly punished. One writer justified this by claiming that the number of abortions among married women had increased markedly since 1840. The Offences against the Person Act 1861 created a new preparatory offence of procuring poison or instruments with intent to procure abortion. During the 1860s however abortion services were available in New York, New Orleans, Cincinnati, Louisville, Cleveland, Chicago and Indianapolis; with estimates of one abortion for every 4 live births . Anti-abortion statutes began to appear in the United States from the 1820s. A Connecticut law in 1821 targeted apothecaries who sold poisons to women for purposes of abortion, and New York made post-quickening abortions a felony and pre-quickening abortions a misdemeanor in 1829. Criminalization accelerated from the late 1860s, through the efforts of concerned legislators, doctors, and the American Medical Association. In 1873, the Comstock Law prohibited any methods of production or publication of information pertaining to the procurement of abortion, the prevention of conception, and the prevention of venereal disease, even to students of medicine. By 1909, the penalty for violating these laws became a $5000 fine and up to five years imprisonment. By 1910, nearly every state had anti-abortion laws; these were unevenly enforced at best. In contrast, in France social perceptions of abortion started to change. In the first half of the 19th century, abortion was viewed as the last resort for pregnant but unwed women. As writers began to write about abortion in terms of family planning for married women, the practice of abortion was reconceptualized as a logical solution to unwanted pregnancies resulting from ineffectual contraceptives. The formulation of abortion as a form of family planning for married women was made "thinkable" because