The following Note outlines the legal and social history of women's common law immunity leading up to the passage of Utah's statute in Part I. Part II analyzes the legislative history of the Utah self-abortion provision prior to its passage as H.B. 462. Part III examines the relationship between state police power and the movement to create gender equality under the law, specifically under the Utah criminal laws involving rape and domestic violence. In Part IV, I posit that the inconsistency of the self-abortion prosecution law with other Utah provisions undermines gender equality and the efficacy of Utah's police power.