The Partial-Birth Abortion Ban Act, signed into law by President Bush in 2003, was upheld by the Supreme Court in 2007, making it the first regulation on an abortion procedure affirmed by the Roe v. Wade–supporting Court. The procedure (called D&E), during which a fetus is extracted from a woman’s womb during the second trimester, was found by Congress to be “gruesome and inhumane,” giving pro-life advocates legislative leeway to further restrictions that hinge on pain or cruelty inflicted on unborn children.