BU Law Students and Programs Partner on a Comment to the FDA
The Boston University Program on Reproductive Justice (BUPRJ), Immigrants’ Rights and Human Trafficking Program, and Racial Justice and Movement Lawyering Clinic have collaborated to jointly submit a comment urging the Food and Drug Administration (FDA) to safeguard and expand access to abortion medication and telehealth services. The comment, which was submitted on October 11, 2025, advocated in favor of several citizen petitions seeking to protect the continued ability to obtain mifepristone and requested that the FDA not take any action that would reduce patient access to the medication.
The comment was drafted by BU Law students Georgia Aguilar (’27) and Emma Persons (’27) under the supervision of Professor and Associate Dean of Clinical and Experiential Education Julie Dahlstrom, Professor and Director of the Racial Justice and Movement Lawyering Clinic Caitlin Glass, and BUPRJ Executive Director Sapna Khatri.
“As reproductive healthcare becomes increasingly constrained in the United States, the need for data-driven policymaking could not be more urgent,” shares Aguilar. “This comment demonstrates that without meaningful access to mifepristone, any promise of health equity remains largely out of reach.”
Anchored in reproductive justice and public health principles, the comment emphasizes that any restrictions on mifepristone are especially harmful to communities that already face significant barriers to accessing reproductive healthcare, including immigrants, survivors of gender-based violence, youth, Black and brown communities, low-income populations, and uninsured populations, among others.
“The expertise from Professors Khatri, Dahlstrom, and Glass was crucial in helping us shed light on the perspective of marginalized communities in the fight for abortion access,” shares Persons. “Our comment details how important both research-backed policymaking and access to reproductive healthcare are to the health of these communities especially.”
Persons is a research assistant for Professor Dahlstrom and a participant in the Racial Justice and Movement Lawyering Clinic while Aguilar serves as a BUPRJ research assistant and student attorney in the Immigrants’ Rights and Human Trafficking Program.
“We are grateful for the opportunity to partner with these important BU Law clinics on this comment and for the leadership of BU Law students Georgia Aguilar (’27) and Emma Persons (’27),” shared Professor Khatri on behalf of BUPRJ. She continued, “This collaborative project exemplifies how academic partnerships and programs like BUPRJ can drive real-world change while training students with hands-on practical experience.”
Since the initial comment was submitted to the FDA, it has been shared with Congress and was part of the evidentiary record for a recent Senate health committee hearing on abortion drugs. Additionally, the groups recently submitted a supplemental FDA Comment providing additional new research about the causal link between gender-based violence and lack of access to abortion services.