A. Tyler Kelly

Publication Date


Document Type



“State constitutionalism . . . is . . . vital yet underdeveloped[.]” The right to pursue one’s chosen profession free from unreasonable government interference is inherent in the Georgia Constitution’s Due Process Clause, and a recognition of such economic liberty reappears throughout the jurisprudence of the Supreme Court of Georgia. With the passage of the Patient Protection and Affordable Care Act (ACA) in 2010, the federal government delegated to the states the responsibility of navigating new policy which led insurance companies to reimburse a host of medical services from licensed professionals. At the time of the ACA’s passage, Georgia faced an epidemic in infant mortality, maternal morbidity, and premature births. People like Mary Jackson, a hospital-employed Certified Lactation Counselor, and organizations such as Reaching Our Sisters Everywhere, Inc. (ROSE), served on the front lines, supporting and assisting mothers with lactation care and breastfeeding.