Abortions became illegal by statute, in Britain in 1803 and various anti-abortion statutes began to appear in the United States from the 1820s codifying or expanding the common law rules. In 1821, a Connecticut law targeted apothecaries who sold poisons to women for purposes of abortion; and New York made post-quickening abortions a felony and pre-quickening abortions a misdemeanor eight years later. It is sometimes argued that the early American abortion laws were motivated not by ethical concerns about abortion but by concern about the safety of the procedure. However, some legal theorists point out that this theory is inconsistent with the fact that abortion was punishable regardless of whether any harm befell the pregnant woman and the fact that many of the early laws punished not only the doctor or abortionist, but also the woman who hired them. [ 6 ]