Cenzon-DeCarlo v. Mount Sinai Hospital

I missed this opinion from a couple of weeks ago (but thankfully John Breen didn't!): the Second Circuit has ruled, not surprisingly, that the Church Amendment does not create a private right of action by which a nurse who was forced to participate in a late-term abortion may sue to vindicate her right of conscience.  As Robin Wilson has argued, if the Dep't of Health and Human Services declines to enforce the Church Amendment, a private right of action may be needed.