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* Madsen v. Women's Health Center ( 1994 ) In a partial victory for Liberty Counsel, the United States Supreme Court defined the limits of injunctive relief available to abortion clinics against pickets and demonstrators.
The Court established the Madsen Test, which provides that injunctive relief can be granted when it is shown that the defendant has violated or imminently will violate some provision of law, there is a discernible danger of recurrent violations, and a following speech restrictive injunction may not burden speech more than necessary to serve a significant government interest.

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