Examples of situations where an HTTP 451 error code could be displayed include web pages deemed a danger to national security, or web pages deemed to violate copyright, privacy, blasphemy laws, or any other law or court order.

After introduction of the GDPR in the EEA it became common practice for websites located outside the EEA to serve HTTP 451 errors to EEA visitors instead of trying to comply with this new privacy law. For instance, many regional U.S. news sites no longer serve web browsers from the EU.[4][5][6]


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The RFC is specific that a 451 response does not indicate whether the resource exists but requests for it have been blocked, if the resource has been removed for legal reasons and no longer exists, or even if the resource has never existed, but any discussion of its topic has been legally forbidden (see injunction).[7] Some sites have previously returned HTTP 404 (missing) or similar if they are not legally permitted to disclose that the resource has been removed. It is used in the United Kingdom by some Internet service providers utilising the Internet Watch Foundation blacklist, returning a 404 message or another error message instead of showing a message indicating the site is blocked.[8][9]

The status code was formally proposed in 2013 by Tim Bray, following earlier informal proposals by Chris Applegate[10] in 2008 and Terence Eden[11] in 2012. It was approved by the IETF on December 18, 2015.[12] It was published as in the Proposed Standard RFC 7725 in February 2016.

HTTP 451 was mentioned by the BBC's From Our Own Correspondent programme, as an indication of the effects of sanctions on Sudan and the inability to access Airbnb, the App Store, or other Western web services.[13]

When an entity intercepts the request and returns status 451, it should include a "Link" HTTP header field whose value is a URI reference identifying itself. The "Link" header field must then have a "rel" parameter whose value is "blocked-by". This is intended to identify the entity implementing the blocking (an ISP, DNS provider, caching system, etc.), not the legal authority mandating the block.[14] At an IETF hackathon, participants used a web crawler to discover that several implementations misunderstood this header and gave the legal authority instead.[15]

Decisions of the U.S. Supreme Court rarely attract much public interest. One news cycle and a few days' discussion in the op-ed section is probably the norm for even the most important and sweeping decisions. The average person probably has to cast back to a high school history course to recall the names of even a few landmark cases other than

Many other Americans, less attuned to public policy matters, hold a very different view of Roe v. Wade. They see Roe as being immutable, permanent, "settled law." "Abortion is a constitutional right." End of discussion. In thirty years, the Roe abortion license has been elevated by some to the stature of "freedom of speech," "trial by jury" and other bedrock American principles.

Roe has also become a lodestar for abortion advocates and the politicians who support their agenda. Any event or policy affecting a child before or near birth is minutely scrutinized for its potential to "undermine Roe v. Wade." Anything (and anyone) that threatens the shaky "constitutionality" of Roe must be stopped. For example, state laws which punish violent attacks on unborn children and their mothers are denounced as schemes "designed to chip away at the constitutional rights of women." Even expanding eligibility under the State Children's Health Insurance Program to provide prenatal care to children from conception onward is attacked as "a guerilla attack on abortion rights."2

Allegiance to Roe has become the sine qua non for presidential aspirants of one political party and a litmus test used by many politicians in evaluating judicial nominees. Senate filibusters are being used to block confirmation votes on nominees. Individuals who have received the American Bar Association's highest recommendation based on their knowledge of law, their integrity and judicial temperament are blocked chiefly because abortion lobbyists suspect they are not sufficiently deferential to Roe v. Wade.

Already two presidential candidates seeking election in 2004 have announced that, if elected, they would appoint no one to the Supreme Court "if they don't commit to supporting Roe v. Wade and a woman's right to choose." This, too, is an unprecedented admission. They strain to explain why their position does not constitute a single issue "litmus test" for judicial appointees: "The focus is on the constitutional right that Roe established in America," says one. "I want jurists to agree, to swear to uphold the Constitution." Are abortion and the Constitution really synonymous?

Many Americans, including members of Congress, believe or act as if Roe v. Wade and the U.S. Constitution have equal authority. They are wrong, both as to Roe's place in American constitutional law and as to the duty of citizens and judges to follow it unquestioningly. Few decisions in the history of the Supreme Court have cried out so loudly for reversal, on both moral and legal grounds. And rarely has any decision been so fraught with conspicuous errors of law, fact and reasoning as the majority opinion in Roe.

This article is addressed to all who may think that Roe deserves a measure of deference as a landmark of constitutional law (notwithstanding its immoral outcome). Not so! Legally speaking, Roe is an abomination, and an embarrassment to lawyers and public officials who feel compelled to defend it.

As a matter of constitutional interpretation and judicial method, Roe borders on the indefensible. I say this as someone utterly committed to the right to choose, as someone who believes such a right has grounding elsewhere in the Constitution instead of where Roe placed it, and as someone who loved Roe's author like a grandfather. . . . . 


What, exactly, is the problem with Roe? The problem, I believe, is that it has little connection to the Constitutional right it purportedly interpreted. A constitutional right to privacy broad enough to include abortion has no meaningful foundation in constitutional text, history, or precedent. ...

The proof of Roe's failings comes not from the writings of those unsympathetic to women's rights, but from the decision itself and the friends who have tried to sustain it. Justice Blackmun's opinion provides essentially no reasoning in support of its holding. And in the almost 30 years since Roe's announcement, no one has produced a convincing defense of Roe on its own terms.7

Under the legal system established by the U.S. Constitution, the power to make laws is vested in Congress and retained by state legislatures. It is not the role of the Supreme Court to substitute the policy preferences of its members for those expressed in laws enacted by the people's elected representatives. The role of the judiciary in constitutional review is to determine if the law being challenged infringes on a constitutionally protected right.

Irrespective of what we may believe is wise or prudent policy in this difficult area, "the Constitution does not constitute us as 'Platonic Guardians' nor does it vest in this Court the authority to strike down laws because they do not meet our standards of desirable social policy, 'wisdom,' or 'common sense.'"8

In Roe v. Wade and its companion case, Doe v. Bolton, however, the Court struck down criminal laws of Texas and Georgia which outlawed certain abortions by finding that these laws (and those of the other 48 states) violated a "right of privacy" that "is broad enough to encompass a woman's decision whether or not to terminate her pregnancy." Such a right is nowhere mentioned in the Constitution nor derivable from values embodied therein.

I find nothing in the language or history of the Constitution to support the Court's judgment. The Court simply fashions and announces a new constitutional right for pregnant mothers ... and, with scarcely any reason or authority for its action, invests that right with sufficient substance to override most existing state abortion statutes. The upshot is that the people and the legislatures of the 50 states are constitutionally disentitled to weigh the relative importance of the continued existence and development of the fetus, on the one hand, against a spectrum of possible impacts on the mother, on the other hand. As an exercise of raw judicial power, the Court perhaps has authority to do what it does today; but, in my view, its judgment is an improvident and extravagant exercise of the power of judicial review that the Constitution extends to this Court.

The apparent purpose of the Roe opinion's long historical excursion is to create the impression that abortion had been widely practiced and unpunished until the appearance of restrictive laws in the prudishly Victorian 19th century. One example is adequate to show how distorted is Justice Harry Blackmun's rendition of history. He must overcome a huge hurdle in the person of Hippocrates, the "Father of Medicine," and his famous Oath which has guided medical ethics for over 2,000 years. The Oath provides in part: "I will give no deadly medicine to anyone if asked, nor suggest any such counsel; and in like manner I will not give to a woman a pessary to produce abortion."9 This enduring standard was followed until the Roe era and is reflected in Declarations of the World Medical Association through 1968: "I will maintain the utmost respect for human life, from the time of conception. ..."10 But Justice Blackmun dismisses this universal, unbroken ethical tradition as nothing more than the manifesto of a fringe Greek sect, the Pythagoreans, to which Hippocrates is alleged to have belonged!

William Blackstone's Commentaries on the Laws of England (1765-1769), an exhaustive and definitive discussion of English common law as it was adopted by the United States shows that the lives of unborn children were valued and protected, even if their beginning point was still thought to be "quickening" rather than conception:

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