On March 16, 1869, Magdalena Philippi died of complications of an abortion performed on her, evidently by a Dr. Gabriel Wolff.
Although Magdalena was four or five months pregnant, prosecutors had no way of proving that she had felt movement in the fetus, so they could not prosecute Dr. Wolff.
The next day, a bill was introduced in Albany to eliminate the quickening distinction in prosecuting abortion cases. This would make it easier to prosecute abortionists like Wolff.
Magdalena's abortion was typical of illegal abortions in that it was performed by a physician.
For more on pre-legalization abortion, see The Bad Old Days of Abortion
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