The plaintiff in Means v. United States Conference of Catholic Bishops sought to hold the US Conference of Catholic Bishops responsible for promulgating Ethical and Religious Directives for Catholic Health Care Services that dictated the substandard care she received after her water sbroke when she was eighteen weeks pregnant. The Sixth Circuit dismissed her case for lack of personal jurisdiction and failure to state a claim under state negligence law, reasoning that the defendants’ promulgation and adoption of the Directives was passive conduct providing no basis for foreseeing harm to patients. Leslie Griffin’s feminist judgment grants Means’ request to recognize that the defendants owed her a duty not to promote an ethical theory that foreseeably harms patients by actively interfering with their access to needed medical treatment. Maya Manian’s commentary situates the case in the ongoing conflict between religious freedom and access to appropriate miscarriage management, treatment for ectopic pregnancies, abortion care, tubal ligation surgery, and access to contraception—highlighting that abortion care is interconnected with health care more broadly.