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In a 2004 case in South Carolina - Planned Parenthood of South Carolina v. Rose - the 4th U.S. Circuit Court of Appeals, a traditionally conservative court, found the plates were private speech and that it was unconstitutional for a state to sell them without also offering a plate for abortion-rights advocates.

Virginia is covered by the 4th Circuit.

In 2006, the 6th U.S. Circuit Court of Appeals in Cincinnati allowed Tennessee to offer pro-life plates, deeming them speech protected by the First Amendment.

Mr. Albo said he fears that once pro-life activists are allowed a plate, then every interest group in the state will vie for them, flooding the Assembly with distracting legislation.