On December 1, 1928, 23-year-old Esther V. Wahlstrom died in Chicago from complications of a criminal abortion. Dr. Lou E. Davis was held by the coroner for murder by abortion on December 12. She was indicted for felony murder on December 15.
Esther'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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