DiscoverLaw on FilmNever Rarely Sometimes Always (Guest: Alexa Kolbi-Molinas) (episode 14)
Never Rarely Sometimes Always (Guest: Alexa Kolbi-Molinas) (episode 14)

Never Rarely Sometimes Always (Guest: Alexa Kolbi-Molinas) (episode 14)

Update: 2023-11-07


Never Rarely Sometimes Always (2020) centers on the struggles faced by 17-year-old Autumn Callahan (Sidney Flanigan) to obtain an abortion after learning that she’s pregnant. Autumn travels from her small town in central Pennsylvania to New York City, where she seeks to obtain the abortion, accompanied by her cousin Skylar (Talia Ryder). Autumn and Skylar must overcome a series of obstacles and persevere in what is ultimately a traumatizing experience. Written and directed by Eliza Hittman, the film was released in the twilight of the Roe/Casey era, the nearly 50-year period when abortion was recognized as a constitutional right in the United States before the Supreme Court eliminated the right in 2022 in Dobbs v. Jackson Women’s Health Organization. The film not only offers a window into this critical period but also highlights the real-world obstacles many women continue to face in obtaining abortions even in states where it remains legal. Our guest to talk about the film and the current state of reproductive freedom in America is Alexa Kolbi-Molinas, Deputy Director of the Reproductive Freedom Project of the American Civil Liberties Union.


0:00      Introduction
3:35      Abortion at the time of the film’s release in 2020
6:53      Even before Dobbs, abortion was out of reach for many women
8:20      The challenges for minors and women in abusive relationships
10:03   A pitch perfect depiction of a crisis pregnancy center
14:00   Medication abortions
17:03   Parental consent requirements, Casey, and the undue burden test
25:47   The obstacles Autumn faces in the film
33:56   Navigating the unwelcome advances of the male teen Jasper
37:07   The real-life experiences women go through to get abortions
40:11   “Never Rarely Sometimes Always”
44:56   The care people in abortion clinics provide for their patients
50:02   The increased demand for abortion in states where it is legal
53:48   Abortion after Dobbs
57:21   Abortion wins at the ballot

Further reading:

Cohen, David S., Donley, Greer & Rebouché, Rachel, “The New Abortion Battleground,” 123 Columbia L. Rev. (2022)

Fry, Naomi, "Never Rarely Sometimes Always: A Human Tale of Reproductive Rights” The New Yorker (Apr. 13, 2020)

Human Rights Watch, “Human Rights Crisis: Abortion in the United States after Dobbs” (Apr. 18, 2023)

Wayne, Miriam, “Burying Abortion in Stigma: The Fundamental Right No One Wants to Discuss; Abortion Portrayal on Film and Television," 16 Va. Sports & Entertainment L.J. 216 (2017)

Wilkinson, Alissa, “Why Hollywood keeps getting abortion wrong,” Vox (Aug. 9, 2022)

Ziegler, Mary & Siegel, Reva, “How the end of Roe turned into a threat to American democracy,” L.A. Times (June 23, 2023)

Law on Film is created and produced by Jonathan Hafetz. Jonathan is a professor at Seton Hall Law School. He has written many books and articles about the law. He has litigated important cases to protect civil liberties and human rights while working at the ACLU and other organizations. Jonathan is a huge film buff and has been watching, studying, and talking about movies for as long as he can remember.
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Never Rarely Sometimes Always (Guest: Alexa Kolbi-Molinas) (episode 14)

Never Rarely Sometimes Always (Guest: Alexa Kolbi-Molinas) (episode 14)

Jonathan Hafetz