The Legal Aid Justice Center urges your approval of the Regulations to ensure that pregnant prisoners are protected from harmful shackling before, during and after birth.  We have represented and spoken with women who have suffered increased pain from the shackling and also experienced very  high anxiety about the safety of their babies.

We offer the following reasons for the Regulations:

1.Shackling incarcerated pregnant women increases the risks to the mother's health and to the baby's health.  Using restraints is particularly dangerous during labor and delivery when women most need freedom to move and medical staff may need to conduct emergency procedures.

2. Restrictions proposed will not create safety issues for correctional or medical staff.  Where states have reduced shackling, none have documented pregnant women escaping or causing harm to themselves, security staff, medical staff or the public.

3.Procedures for compliance witll ensure needed accountability.

4. Virginia prisons have already placed limits on the use of restraints for pregnant women prisoners.

Thank you for the opportunity to comment.

Abigail Turner