A Murder Case Exposes What Happens When Minors Have No Abortion Options
A preliminary hearing in Los Angeles this week revealed that Celeste Rivas Hernandez, the 14-year-old allegedly murdered by singer D4vd (legal name David Anthony Burke), had been pregnant multiple times and had abortions beginning when she was 13. Prosecutors say Burke began sexually abusing her when she was 11 years old. He has pleaded not guilty to murder and sexual abuse charges.
The texts entered into evidence are a criminal record of child exploitation. They are also an inadvertent policy document. A minor, allegedly impregnated by her abuser, needed abortion access, multiple times, before she was old enough to drive.
21 States Now Restrict or Eliminate the Rape Exception
In at least 21 states, Celeste’s access to an abortion would have been legally restricted or eliminated under laws passed or triggered after the Supreme Court’s 2022 Dobbs decision. Some states with nominal rape exceptions require a police report, a waiting period, or provider certification before an abortion can proceed, requirements that can delay care past viability deadlines or deter abuse survivors from seeking it entirely.
21 states restrict or ban abortion in ways that limit rape and incest exceptions, per KFF’s July 2025 tracker
Celeste was in California, where abortion remains legal and accessible. But her case illustrates the direct medical consequence of abuse for minors everywhere: pregnancy, and the need for safe, timely termination, is not hypothetical. It is documented in court evidence.
Minors Face Compounding Legal Barriers
Even in states that technically allow abortion for rape survivors, minors face additional barriers. Parental involvement laws in 37 states require parental consent or notification before a minor can obtain an abortion. For a child whose abuser is an adult and whose abuse is secret, involving a parent may not be safe or possible. Judicial bypass options exist in most of those states, but they require a court filing, legal representation, and time, all while a pregnancy continues.
The Guttmacher Institute documented a 30 percent increase in minors traveling across state lines for abortion care between 2020 and 2023. That number does not capture minors who could not travel, did not know they could, or were controlled by their abusers.
What you can do now
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Call your U.S. senators at (202) 224-3121 and ask them to co-sponsor the EACH Woman Act, which would restore federal funding for abortions in cases of rape and incest for Medicaid enrollees. Name the bill directly.
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Contact your state attorney general and ask what state law says about abortion access for minor survivors of sexual abuse without parental consent. Find your AG at naag.org/find-my-ag. Ask specifically whether judicial bypass funding exists in your state.
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Urge your state legislators to remove police report requirements from rape exception laws. Many states require an official report to qualify, which abuse survivors, particularly children, are often unable or afraid to file. Contact your state house member through openstates.org.
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Support RAINN’s National Sexual Assault Hotline at 1-800-656-4673 if you or someone you know needs help. RAINN also maintains state-level legal resources for survivors, including minors seeking confidential care.
Sources
BBC News: Texts Reveal 14-Year-Old Allegedly Murdered by Singer D4vd Had Pregnancies and Abortions KFF: Rape and Incest Exceptions in State Abortion Bans, July 2025 Guttmacher Institute: Parental Involvement Laws for Minors Seeking Abortions by State Guttmacher Institute: Abortion Patients Traveling Out of State Post-Dobbs RAINN: State Laws on Confidential Care for Minor Survivors