CHICAGO (AP) — Billboards with the words “STOP Child Gender Surgery.” Pamphlets warning about endangering minors. “PROTECT PARENTS’ RIGHTS” plastered on church bulletins.

That voters in nine states determine whether to enshrine abortion rights in their constitutions, opponents use parental rights and anti-transgender messages to try to undermine support for voting proposals.

The measures do not mention gender-affirming surgeries, and legal experts say changing existing laws on parental notification and consent regarding abortions and gender-affirming care for minors would require court action. But anti-abortion groups hoping to end a defeat at the polls have turned to type of language many Republican candidates across the country are using it in their own campaigns to rally their conservative Christian voters.

“It’s really strange to suggest that this amendment is about things like sex-reassignment surgery for minors,” said Matt Harris, an associate professor of political science at Park University in Parkville, Missouri, a state where abortion rights are on the ballot.

Since the U.S. Supreme Court struck down constitutional protections for abortion, voters in seven states, including conservative Kentucky, mountain and Ohiothey either protected abortion rights or defeated attempts to curtail them.

“If you can’t win by telling the truth, you need a better argument, even if that means capitalizing on the demonization of trans kids,” said Dr. Alex Dworak, a family medicine physician in Omaha. Nebraskawhere anti-abortion groups use the strategy.

Linking abortion rights ballot initiatives with parental rights and gender affirmation is one strategy borrowed from playing cards used in Michigan and Ohiowhere voters nevertheless enshrined the right to abortion in state constitutions.

Both states still require minors to obtain parental consent for abortion, and the new amendments have not yet affected parental involvement or gender-affirming care laws in either state, said David Cohen, a law professor at Drexel University.

“It’s just recycling the same strategiesCohen said.

In addition to Missouri and Nebraska, the states where voters are considering constitutional changes this fall are Montana, Arizona, Colorado, Florida, Maryland, Nevada and South Dakota.

Missouri’s abortion ballot measure has especially become a target. The amendment would prohibit the government from violating “a person’s fundamental right to reproductive freedom.”

Gov. Mike Parson and U.S. Sen. Josh Hawley, both Republicans, argued the proposal would allow minors to get abortions and sex-affirmation surgeries without parental involvement.

The amendment protects reproductive health services, “including, but not limited to,” a list of items such as prenatal care, childbirth, birth control and abortion. It doesn’t mention gender-affirming care, but Missouri state Sen. Mary Elizabeth Coleman, a Republican and attorney for the conservative Thomas More Society, said it’s possible they could be considered reproductive health services.

Several legal experts told The Associated Press that would require a court decision, which is unlikely.

“It would be a real stretch for any court to say that anything related to gender-affirming care counts as reproductive health care,” said Saint Louis University law and gender studies professor Marcia McCormick. She noted that the examples listed as reproductive health care in the Missouri amendment are all directly related to pregnancy.

Regarding parental consent for minors’ abortions, she pointed to an existing state law that is similarly worded to one that the U.S. Supreme Court found constitutional even before Roe v. Wade was overturned.

Most states have parental involvement laws, whether they require parental consent or notification. Even many Democratic-leaning states with explicit protections for transgender rights require parental involvement before abortion or sex-affirming care for minors, said Mary Ruth Ziegler, a law professor at the University of California, Davis School of Law.

A state high court would have to overturn such laws, which is highly unlikely from conservative majorities in many of the states with abortion on the ballot, experts said.

In New York, a proposed amendment to the state constitution would take place extend protection against discrimination to include ethnicity, national origin, age, disability, and “sex, including sexual orientation, gender identity, gender expression, pregnancy, pregnancy outcomes, and reproductive health care and autonomy.” The constitution already prohibits discrimination based on race, color, creed or religion.

The measure does not mention abortion, and experts say it could be more vulnerable to attack by opponents.

The Child Protection Coalition-NY calls it the “Parental Replacement Act.” But Sasha Ahuja, campaign director for New Yorkers for Equal Rights, said the measure “does not change the existing common sense laws that are already in place.”

Rick Weiland, co-founder of Dakotans for Health, the group behind it South Dakota The proposed amendment said it used the Roe v. Wade framework “almost word for word.”

“All you have to do is look back at what was allowed under Roe, and there have always been requirements for parental involvement,” Weiland said.

Caroline Woods, a spokeswoman for the anti-abortion group Life Defense Fund, said the measure “means loving parents will be taken completely out of the equation.” Weiland said those claims are part of a “steady stream of misinformation” from opponents.

If this campaign strategy failed in Michigan and Ohiowhy are anti-abortion groups banking on her for the november election?

Ziegler, a law professor at the University of California, Davis, said opponents of abortion rights know they could “play on a more favorable playing field” in more conservative states like Missouri or in states like Florida which have higher thresholds for adopting ballot measures.

“Anti-abortion groups are still looking for a winning recipe,” Ziegler said.

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Associated Press writer Geoff Mulvihill in Cherry Hill, New Jersey, contributed to this report.

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