does persuasive essay mean

Persuasive Essay

Definition of persuasive essay.

The term “persuasive” is an adjective derived from verb “persuade,” which means “to convince somebody.” A persuasive essay is full of all the convincing techniques a writer can employ. It presents a situation, and takes a stand – either in its favor, or against it – to prove to readers whether it is beneficial or harmful for them.

Why Persuasion?

The question arises why persuasion if the people are already aware of everything. Its answer is that each person’s ability of seeing and understanding things depend on his vision. He believes only what he sees or is told about. If another side of the coin is shown, the people do not believe so easily. That is why they are presented with arguments supported with evidences , statistics and facts. Persuasion is done for these reasons:

• A Better World : To ask the people that if they accept your argument , it will be good for them to take action and make the world a better place.
• A Worse World : It means that if readers do not do what they are asked to do, the world will become a worse place.
• Call to Action : It means to persuade or tempt readers to do what the writer wants them to do.

Difference Between a Persuasive Essay and an Argumentative Essay

A persuasive essay is intended to persuade readers to do certain things, or not to do certain things. It is the sole aim of the writer to coax or tempt readers, and force them to do certain things or take actions. However, an argumentative essay intends to make readers see both sides of the coin. It is up to them to select any of the two. In other words, an argumentative essay presents both arguments; both for and against a thing, and leaves the readers to decide. On the other hand, a persuasive essay intends to make readers do certain things. Therefore, it presents arguments only about one aspect of the issue.

Examples of Persuasive Essay in Literature

Example #1: our unhealthy obsession and sickness (by frank furedi).

“Governments today do two things that I object to in particular. First they encourage introspection, telling us that unless men examine their testicles, unless we keep a check on our cholesterol level, then we are not being responsible citizens. You are letting down yourself, your wife, your kids, everybody. We are encouraged continually to worry about our health. As a consequence, public health initiatives have become, as far as I can tell, a threat to public health. Secondly, governments promote the value of health seeking. We are meant always to be seeking health for this or that condition. The primary effect of this, I believe, is to make us all feel more ill.”

This is an excerpt from a persuasive essay of Frank Furedi. It encourages people to think about how the government is helping public health. Both the arguments of persuasion start with “First” in the first line and with “Secondly” in the second last line.

Example #2: We Are Training Our Kids to Kill (by Dave Grossman)

“Our society needs to be informed about these crimes, but when the images of the young killers are broadcast on television, they become role models. The average preschooler in America watches 27 hours of television a week. The average child gets more one-on-one communication from TV than from all her parents and teachers combined. The ultimate achievement for our children is to get their picture on TV. The solution is simple, and it comes straight out of the sociology literature: The media have every right and responsibility to tell the story , but they must be persuaded not to glorify the killers by presenting their images on TV.”

This is an excerpt from Grossman’s essay. He is clearly convincing the public about the violent television programs and their impacts on the kids. See how strong his arguments are in favor of his topic.

Example #3: The Real Skinny (by Belinda Luscombe)

“And what do we the people say? Do we rise up and say, ‘I categorically refuse to buy any article of clothing unless the person promoting it weighs more than she did when she wore knee socks?’ Or at least, ‘Where do I send the check for the chicken nuggets?’ Actually, not so much. Mostly, our responses range from ‘I wonder if that would look good on me?’ to ‘I don’t know who that skinny-ass cow is, but I hate her already.’

Just check the strength of the argument of Belinda Luscombe about purchasing things. The beauty of her writing is that she has made her readers think by asking rhetorical questions and answering them.

Function of a Persuasive Essay

The major function of a persuasive essay is to convince readers that, if they take a certain action, the world will be a better place for them. It could be otherwise or it could be a call to an action. The arguments given are either in the favor of the topic or against it. It cannot combine both at once. That is why readers feel it easy to be convinced.

Related posts:

• Elements of an Essay
• Narrative Essay
• Definition Essay
• Descriptive Essay
• Types of Essay
• Analytical Essay
• Argumentative Essay
• Cause and Effect Essay
• Critical Essay
• Expository Essay
• Process Essay
• Explicatory Essay
• An Essay on Man: Epistle I
• Comparison and Contrast Essay

Post navigation

• Improving Your Grades
• Article Use (a, an, the…)
• Apostrophes
• Run-On Sentences
• Parts of Speech
• Pronunciation
• Types of Writing
• Choosing the Right Words
• How Can I Make My Sentences Clearer?
• Varying Sentence Length
• Varying Sentence Structure
• Word Form: Comparative and Superlative Adjectives
• Use SEMICOLONS (;) For Emphasis
• Sentence Structure: For and Since
• Sentence Structure: Order of adjectives
• Preposition Problems: Prepositions of Time
• Sentence Structure: Tag Questions
• Word Choice: Personal Pronouns
• Using Evidence
• Research & Documentation
• Cover Letters
• The Secret to Eye Contact
• Three Keys for Better Slide Design
• Know your audience – presentation skills
• Lying With Charts

Select Page

What Is a Persuasive Essay?

Posted by 11trees | Types of Writing

A persuasive essay explains a specific topic and attempts to persuade the audience that your point of view is the most informed, logical and valid perspective on the topic. This genre is also known as the argumentative essay.

While an expository essay written for an exam or a standardized test may have a persuasive element, most persuasive or argumentative essays are written out of class and require extensive research. The research may include several kinds of sources:

• Articles from high-quality non-scholarly magazines or journals (for example, The Atlantic, Harpers, Scientific American, etc.)
• Scholarly or non-scholarly books
• Scholarly or technical journal articles
• Government agency websites
• Statistical analysis
• Interviews with experts

Persuasive essays use such research both to educate the audience about the topic and to supply evidence supporting the writer’s opinions.

The main goal of an argumentative paper is to persuade your audience that your view is among the most compelling opinions on the topic. You should attempt to persuade even those who start out strongly disagreeing with you. To do that, you need to show that you’re very well-informed about your topic.

What Are the Elements of a Persuasive Essay?

A persuasive essay does have certain baseline requirements that are standard in nearly every essay type:

• A clear thesis or controlling idea that establishes and sustains your focus.
• An opening paragraph that introduces the thesis.
• Body paragraphs that use specific research evidence to illustrate your informative or argumentative points.
• Smooth transitions that connect the ideas of adjoining paragraphs in specific, interesting ways.
• Use of counterarguments to summarize and refute opposing positions.
• A conclusion that emphasizes your central idea without being repetitive.

How Do You Write a Persuasive Essay?

One common formula for the persuasive paper is the 5-Paragraph Essay. If you don’t have much experience with essay writing, this is a good method to start with, since it’s basic and straightforward. The 5-Paragraph Essay incorporates the elements listed above in the following basic structure:

• Introductory paragraph with a clear, concise thesis.
• Three body paragraphs that offer evidence and analysis connecting that evidence to the thesis.
• A concluding paragraph that sums up the paper by reevaluating the thesis in light of the evidence discussed in the essay’s body.

While the 5-paragraph structure gives you a helpful formula to work with, it’s only one among many valid options, and its suitability will depend on other factors like the length and complexity of your essay. If you’re writing a paper that’s more than 3 or 4 pages long, it should be more than 5 paragraphs. In most cases, the structure of a longer essay will be similar to that of the 5-paragraph essay, with an introduction, a conclusion and body paragraphs performing the same basic functions—only the number of body paragraphs will increase. The length of the paragraphs may also increase slightly in proportion to the length of the essay.

Composing a Persuasive Essay: A Process Guide

Preliminary Steps

• Begin by reading the assignment carefully to make sure you understand it. Then find a topic that fits the assignment. It’s important that you narrow your topic so that it’s directly relevant to the assignment. But make sure your topic is not so narrow that it lacks significance. It’s best if you find a topic that you’re really interested in—this will make the work more enjoyable for you and will probably lead to higher quality research and writing.
• Before starting your research, make a list of facts—everything you already know about your topic. This list may be long or short depending on your level of knowledge.
• Make another list, this time of your ideas and opinions on the topic. Begin with the strongest opinions and list them in descending order according to your level of conviction.
• Ask yourself why you hold these opinions. It’s important to clarify your own views on the topic so you don’t get too overwhelmed by expert opinions when you begin your research. But you should also be open to changing these opinions if facts and logic warrant such change.
• Try to come up with an original, debatable perspective on your topic and write a tentative thesis statement that reflects your view concisely. Being original in this case doesn’t mean you have to come up with some earth-shattering revelation about human nature—it just means you should stay away from general, bland, or obvious ideas that most people would readily agree with.
• Familiarize yourself with the resources of your school’s library—the physical books and periodicals and the online databases. Describe your project ideas to a librarian and ask for recommendations on where to look for the resources you need.
• The main purpose of your research is to for you to become very well-informed about your topic. Immerse yourself in all the relevant factual data AND acquaint yourself with the most prominent, compelling opinions on the central issues.
• Look for sources that include unusual aspects of your topic, or unconventional perspectives on it—these may provide interesting, surprising angles from which to approach your argument.
• Read your sources critically and ask yourself what informs the various perspectives on your topic. Which sources seem best informed? Which use the most compelling logic? Which are guided more by ideology or assumptions than by credible evidence?
• Take notes on your sources as you read them. Summarize the parts of each source that are relevant to your thesis. In addition to the summary, write down your thoughts on the facts and opinions laid out in these sources. Critique the sources you disagree with. This note-taking will help you to process the research material and develop your perspective on the topic.

Composing and Revising

• Once you’ve compiled some research, revisit your tentative thesis statement and revise it according to what you’ve learned—see if you can make it more specific or original. Think of the thesis as your opening statement in a debate with people whose views oppose yours.
• Sift your research notes and sources for examples you can use to discuss conflicting opinions on your topic and to illustrate your own views. Each example should have some clear connection to your central idea.
• Your essay should devote one body paragraph to each of your major ideas and examples. So begin an outline by writing a topic sentence about each major example for each of your body paragraphs. Since the topic sentence will be part of each paragraph transition, it should make a clear, logical connection between your thesis and the evidence that paragraph will discuss.
• Complete your outline by thinking of an interesting, meaningful way to end the essay. Remember that the conclusion should sum up your central points without merely repeating what you’ve said earlier. You might suggest the larger implications of what the essay has discussed and analyzed. One way to do this is to offer a concise review of what you’ve covered combined with a reasonable forecast or recommendations for the future.
• You might want to experiment with writing the body paragraphs before you write your introduction. The details of analysis in the body of the paper often help you to determine more precisely how to word your thesis and the sentences that surround it.
• Define  your key terms or ideas.
• Describe  and  analyze  specific examples of your topic.
• Summarize  and  evaluate  contrasting opinions on your topic.
• Compare  and  contrast  your examples and their relation to your thesis.
• Connect  your examples explicitly to your central idea and to each other.
• Use plenty of quotations and paraphrase of your sources to support your analysis and argument. Integrate the quotes into your own sentences so the discussion reads more smoothly.
• Make sure you cite ALL information that comes from your sources, whether quotations or paraphrase. Use the citation format required by the class or the assignment—MLA, APA, etc. The Writers’ Toolkit citation tools will make the process easy for you by automating the format.
• Polish your essay through revision to make it artful, original, and interesting. Avoid clichéd language or the most obvious examples. You want your reader to learn something new and compelling, whether it’s an unusual fact or a novel perspective on your topic.

Related Posts

How to Write a College Admissions Essay

July 27, 2017

Tips and Tricks to Narrative Essays

What is a Narrative Essay?

What Is an Expository Essay?

• Verbs (ESL)
• Auxiliary Verbs
• Prepositions
• Sentence Structure
• Word Choice
• Coherence and Cohesion
• Information Literacy
• Adjusting Expectations
• Audience, Purpose, and Tone
• Writing Advice
• Slide Design
• Non-verbal Communication
• Writing Assignment Ideas

Persuasive Essay: A Guide for Writing

Ever found yourself wrestling with the challenge of convincing others through your writing? Look no further – our guide is your go-to roadmap for mastering the art of persuasion. In a world where effective communication is key, this article unveils practical tips and techniques to help you produce compelling arguments that captivate your audience. Say goodbye to the struggles of conveying your message – let's learn how to make your persuasive essay informative and truly convincing.

What Is a Persuasive Essay

Persuasive essays are a form of writing that aims to sway the reader's viewpoint or prompt them to take a specific action. In this genre, the author employs logical reasoning and compelling arguments to convince the audience of a particular perspective or stance on a given topic. The persuasive essay typically presents a clear thesis statement, followed by well-structured paragraphs that provide evidence and examples supporting the author's position. The ultimate goal is to inform and influence the reader's beliefs or behavior by appealing to their emotions, logic, and sense of reason. If you need urgent help with this assignment, use our persuasive essay writing service without hesitation.

Which Three Strategies Are Elements of a Persuasive Essay

Working on a persuasive essay is like building a solid argument with three friends: ethos, pathos, and logos. Ethos is about trustworthiness, like when someone vouches for your credibility before making a point. Picture it as your introduction, earning trust from the get-go. Then comes pathos, your emotional storyteller. It's all about making your readers feel something, turning your essay into an experience rather than just a bunch of words. Lastly, logos is your logical thinker, using facts and solid reasoning to beef up your argument. These three work together to engage both the heart and mind of your audience. So, let's see how this trio can take your arguments from so-so to memorable.

In a persuasive essay, ethos functions much like introducing your friend as the go-to expert in their field before they share their insights with a new group. It's about showcasing the writer's credibility, expertise, and trustworthiness through a mix of personal experience, professional background, and perhaps even endorsements. Readers are more likely to buy into an argument when they believe the person presenting it knows their stuff and has a solid ethical standing, creating a foundation of trust. Does this information seem a bit confusing? Then simply type, ‘ write my paper ,’ and our writers will help you immediately.

Now, let's consider pathos – the emotional connection element. Imagine a movie that entertains and makes you laugh, cry, or feel a rush of excitement. Pathos in a persuasive essay aims to tap into your emotions to make you feel something. It's the storyteller in the essay weaving narratives that resonate personally. By sharing relatable anecdotes, vivid imagery, or emotionally charged language, writers can create a powerful connection with readers, turning a dry argument into a compelling human experience that leaves a lasting impression.

Lastly, logos is the cool-headed, logical friend who always has the facts straight. In a persuasive essay, logos presents a strong, well-reasoned argument supported by evidence, data, and solid reasoning. The backbone holds the essay together, appealing to the reader's sense of logic and reason. This might include citing research studies, providing statistical evidence, or employing deductive reasoning to build a solid case. So, think of ethos as your trustworthy friend, pathos as the emotional storyteller, and logos as the rational thinker – together, they create a persuasive essay that speaks to the heart and stands up to critical scrutiny. Choose the persuasive essay format accordingly, depending on how you’d like to approach your readers.

Persuasive Essay Outline

Creating an outline for persuasive essay is like sketching a plan for your argument, which is the GPS to help your readers follow along smoothly. Start with an engaging intro that grabs attention and states your main point. Then, organize your body paragraphs, each focusing on one important aspect or evidence backing up your main idea. Mix in ethos (credibility), pathos (emotion), and logos (logic) throughout to make your argument strong. Don't forget to address opposing views and show why your stance is the way to go. Finally, wrap things up with a strong conclusion that reinforces your main points. Here’s a general outline for a persuasive essay:

How to start a persuasive essay? Introduction. 

• Hook. Start with a captivating anecdote, surprising fact, or thought-provoking question to grab the reader's attention.
• Background. Provide context for the issue or topic you're addressing.
• Thesis Statement. Clearly state your main argument or position.

Body Paragraphs

Paragraph 1

• Topic Sentence. Introduce the first key point supporting your thesis.
• Supporting Evidence. Include facts, statistics, or examples that back up your point.
• Ethos, Pathos, Logos. Incorporate elements of persuasion to strengthen your argument.

Paragraph 2

• Topic Sentence. Introduce the second key point supporting your thesis.
• Supporting Evidence. Provide relevant information or examples to bolster your argument.
• Ethos, Pathos, Logos. Continue integrating persuasive elements for a well-rounded appeal.

Paragraph 3

• Topic Sentence. Introduce the third key point supporting your thesis.
• Supporting Evidence. Present compelling evidence or examples.
• Ethos, Pathos, Logos. Ensure a balanced use of persuasive strategies.

Counterargument

• Address opposing views. Acknowledge and counter opposing arguments.
• Refutation. Explain why the counterargument is invalid or less convincing.
• Summarize main points. Recap the key arguments from the body paragraphs.
• Call to Action. Encourage readers to take a specific stance, consider your perspective, or engage in further discussion.

Closing Statement

• Leave a lasting impression. End with a powerful statement that reinforces your thesis and strongly impacts the reader.

We recommend you study our guide on how to write an argumentative essay as well, as these two types of assignments are the most common in school and college.

Take Your Persuasive Writing to the Next Level!

Give us your task to amaze your readers with our tried-and-true methods

How to WritHow to Write a Persuasive Essay

Writing a persuasive essay typically follows a structured format that begins with a compelling introduction, where the writer captures the reader's attention with a hook, provides background information on the topic, and presents a clear thesis statement outlining the main argument. The body paragraphs delve into supporting evidence and key points, each focusing on a specific aspect of the argument and incorporating persuasive elements such as ethos, pathos, and logos. Counterarguments are addressed and refuted to strengthen the overall stance. The conclusion briefly summarizes the main points, reiterates the thesis, and often includes a call to action or a thought-provoking statement to leave a lasting impression on the reader. Follow these tips if you want to learn how to write a good persuasive essay up to the mark: 

Choose a Strong Topic

Selecting a compelling topic is crucial for a persuasive essay. Consider issues that matter to your audience and elicit strong emotions. A well-chosen topic captures your readers' interest and provides a solid foundation for building a persuasive argument. If you’re low on ideas, check out a collection of persuasive essay topics from our experts.

Research Thoroughly

Thorough research is the backbone of a persuasive essay. Dive into various sources, including academic journals, reputable websites, and books. Ensure that your information is current and reliable. Understanding the counterarguments will help you anticipate objections and strengthen your position.

Brainstorm a Solid Thesis Statement

Your thesis statement serves as the central point of your essay. It should be clear, concise, and specific, outlining your stance. Consider it a guideline for your readers, guiding them through your argument. A strong thesis statement sets the tone for the entire essay and helps maintain focus.

Organize Your Thoughts

A rigid persuasive essay structure is key to creating a desired effect on readers. Begin with an engaging introduction that introduces your topic, provides context, and ends with a clear thesis statement. The body paragraphs should each focus on a single point that supports your thesis, providing evidence and examples. Transition smoothly between paragraphs to ensure a cohesive flow. Conclude with a powerful summary that reinforces your main points and leaves a lasting impression.

Develop Compelling Arguments

Each body paragraph should present a persuasive argument supported by evidence. Clearly articulate your main points and use examples, statistics, or expert opinions to strengthen your claims. Make sure to address potential counterarguments and refute them, demonstrating the robustness of your position.

• Use Persuasive Language

Employ language that is strong, clear, and persuasive. Be mindful of your tone, avoiding overly aggressive or confrontational language. Appeal to your audience's emotions, logic, and credibility. Use rhetorical devices like anecdotes or powerful metaphors to make your writing more engaging and memorable.

Revise and Edit

The final step is revising and editing your essay. Take the time to review your work for clarity, coherence, and grammar. Ensure that your arguments flow logically and eliminate any unnecessary repetition. Consider seeking feedback from peers or mentors to gain valuable perspectives on the strength of your persuasive essay. You should also explore the guide on how to write a synthesis essay , as you’ll be dealing with it quite often as a student.

Tips for Writing a Persuasive Essay

The most important aspect of writing a persuasive essay is constructing a compelling and well-supported argument. A persuasive essay's strength hinges on the clarity and persuasiveness of the main argument, encapsulated in a robust thesis statement. This central claim should be clearly articulated and supported by compelling evidence, logical reasoning, and an understanding of the target audience. Here are more tips for you to consider:

• Write a Compelling Hook

Begin your essay with a captivating hook that grabs the reader's attention. This could be a surprising fact, a thought-provoking question, a relevant quote, or a compelling anecdote. A strong opening sets the tone for the rest of the essay.

• Establish Credibility

Build your credibility by demonstrating your expertise on the topic. Incorporate well-researched facts, statistics, or expert opinions that support your argument. Establishing credibility enhances the persuasiveness of your essay.

• Clearly Articulate Your Thesis

Craft a clear and concise thesis statement that outlines your main argument. This statement should convey your position on the issue and provide a path for the reader to follow throughout the essay. Note that if you use custom essay writing services , a thesis is automatically included in the assignment.

• Organize Your Arguments Effectively

Structure your essay with a logical flow. Each paragraph should focus on a single point that supports your thesis. Use transitional phrases to guide the reader smoothly from one idea to the next. This organizational clarity enhances the persuasive impact of your essay.

• Address Counterarguments

Anticipate and address potential counterarguments to strengthen your position. Acknowledge opposing viewpoints and provide compelling reasons why your stance is more valid. This demonstrates a thorough understanding of the topic and reinforces the credibility of your argument.

Choose words and phrases that evoke emotion and engage your reader. Employ rhetorical devices, such as metaphors, similes, or vivid language, to make your argument more compelling. Pay attention to tone, maintaining a respectful and persuasive demeanor.

• Appeal to Emotions and Logic

Strike a balance between emotional appeal and logical reasoning. Use real-life examples, personal stories, or emotional anecdotes to connect with your audience. Simultaneously, support your arguments with logical reasoning and evidence to build a robust case.

• Create a Strong Conclusion

Summarize your main points in the conclusion and restate the significance of your thesis. End with a powerful call to action or a thought-provoking statement that leaves a lasting impression on the reader. A strong conclusion reinforces the persuasive impact of your essay.

Persuasive Essay Examples

Explore the persuasive essay examples provided below to gain a deeper comprehension of crafting this type of document.

Persuasive Essay Example: Are Women Weaker Than Men Today?

Students should explore persuasive essay examples as they provide valuable insights into effective argumentation, organizational structure, and the art of persuasion. Examining well-crafted samples allows students to grasp various writing techniques, understand how to present compelling evidence, and observe the nuanced ways in which authors address counterarguments. Additionally, exposure to diverse examples helps students refine their own writing style and encourages critical thinking by showcasing the diversity of perspectives and strategies. Here are two excellent persuasive essay examples pdf for your inspiration. If you enjoy the work of our writers, buy essay paper from them and receive an equally quality document prepared individually for you.

Example 1: “The Importance of Incorporating Financial Literacy Education in High School Curriculum”

This essay advocates for the imperative inclusion of financial literacy education in the high school curriculum. It emphasizes the critical role that early exposure to financial concepts plays in empowering students for lifelong success, preventing cycles of debt, fostering responsible citizenship, adapting to technological advancements, and building a more inclusive society. By arguing that financial literacy is a practical necessity and a crucial step towards developing informed and responsible citizens, the essay underscores the long-term societal benefits of equipping high school students with essential financial knowledge and skills.

Example 2: “Renewable Energy: A Call to Action for a Sustainable Future”

This persuasive essay argues for the urgent adoption of renewable energy sources as a moral imperative and a strategic move towards mitigating climate change, fostering economic growth, achieving energy independence, and driving technological innovation. The essay emphasizes the environmental, economic, and societal benefits of transitioning from conventional energy to renewable alternatives, asserting that such a shift is not just an environmentally conscious choice but a responsible investment in the sustainability and well-being of the planet for current and future generations.

Knowing how to write a persuasive essay is essential for several reasons. Firstly, it cultivates critical thinking and analytical skills, requiring students to evaluate and organize information effectively to support their arguments. This process enhances their ability to assess different perspectives and make informed decisions. The persuasive essay format also equips students with valuable communication skills, teaching them to articulate ideas clearly and convincingly. As effective communicators, students can advocate for their viewpoints, contributing to a more engaged and informed society. This proficiency extends beyond academic settings, proving crucial in various professional and personal scenarios. If you’d like to expedite the process, consider using our essay service , which saves time and brings positive grades.

Want to Easily Influence Your Readers?

Buy your persuasive essay right away to start using words to change the world!

What are the 7 Tips for Persuasive Essays?

How do i make a persuasive essay, related articles.

persuasive essay

What is persuasive essay definition, usage, and literary examples, persuasive essay definition.

A persuasive essay (purr-SWEY-siv ESS-ey) is a composition in which the essayist’s goal is to persuade the reader to agree with their personal views on a debatable topic. A persuasive essay generally follows a five-paragraph model with a thesis, body paragraphs, and conclusion, and it offers evidential support using research and other persuasive techniques.

Persuasive Essay Topic Criteria

To write an effective persuasive essay, the essayist needs to ensure that the topic they choose is polemical, or debatable. If it isn’t, there’s no point in trying to persuade the reader.

For example, a persuasive essayist wouldn’t write about how honeybees make honey; this is a well-known fact, and there’s no opposition to sway. The essayist might, however, write an essay on why the reader shouldn’t put pesticides on their lawn, as it threatens the bee population and environmental health.

A topic should also be concrete enough that the essayist can research and find evidence to support their argument. Using the honeybee example, the essayist could cite statistics showing a decline in the honeybee population since the use of pesticides became prevalent in lawncare. This concrete evidence supports the essayist’s opinion.

Persuasive Essay Structure

The persuasive essay generally follows this five-paragraph model.

Introduction

The introduction includes the thesis, which is the main argument of the persuasive essay. A thesis for the essay on bees and pesticides might be: “Bees are essential to environmental health, and we should protect them by abstaining from the use of harmful lawn pesticides that dwindle the bee population.”

The introductory paragraph should also include some context and background info, like bees’ impact on crop pollination. This paragraph may also include common counterarguments, such as acknowledging how some people don’t believe pesticides harm bees.

Body Paragraphs

The body consists of two or more paragraphs and provides the main arguments. This is also where the essayist’s research and evidential support will appear. For example, the essayist might elaborate on the statistics they alluded to in the introductory paragraph to support their points. Many persuasive essays include a counterargument paragraph to refute conflicting opinions.

The final paragraph readdresses the thesis statement and reexamines the essayist’s main arguments.

Types of Persuasive Essays

Persuasive essays can take several forms. They can encourage the reader to change a habit or support a cause, ask the reader to oppose a certain practice, or compare two things and suggest that one is superior to the other. Here are thesis examples for each type, based on the bee example:

• Call for Support, Action, or Change : “Stop using pesticides on your lawns to save the environmentally essential bees.”
• Call for Opposition : “Oppose the big businesses that haven’t conducted environmental studies concerning bees and pesticides.”
• Superior Subject : “Natural lawn care is far superior to using harmful pesticides.”

The Three Elements of Persuasion

Aristotle first suggested that there were three main elements to persuading an audience: ethos, pathos, and logos. Essayists implement these same tactics to persuade their readers.

Ethos refers to the essayist’s character or authority; this could mean the writer’s name or credibility. For example, a writer might seem more trustworthy if they’ve frequently written on a subject, have a degree related to the subject, or have extensive experience concerning a subject. A writer can also refer to the opinions of other experts, such as a beekeeper who believes pesticides are harming the bee population.

Pathos is an argument that uses the reader’s emotions and morality to persuade them. An argument that uses pathos might point to the number of bees that have died and what that suggests for food production: “If crop production decreases, it will be impoverished families that suffer, with perhaps more poor children having to go hungry.” This argument might make the reader empathetic to the plight of starving children and encourage them to take action against pesticide pollution.

The logos part of the essay uses logic and reason to persuade the reader. This includes the essayist’s research and whatever evidence they’ve collected to support their arguments, such as statistics.

Terms Related to Persuasive Essays

Argumentative Essays

While persuasive essays may use logic and research to support the essayist’s opinions, argumentative essays are more solely based on research and refrain from using emotional arguments. Argumentative essays are also more likely to include in-depth information on counterarguments.

Persuasive Speeches

Persuasive essays and persuasive speeches are similar in intent, but they differ in terms of format, delivery, emphasis, and tone .

In a speech, the speaker can use gestures and inflections to emphasize their points, so the delivery is almost as important as the information a speech provides. A speech requires less structure than an essay, though the repetition of ideas is often necessary to ensure that the audience is absorbing the material. Additionally, a speech relies more heavily on emotion, as the speaker must hold the reader’s attention and interest. In Queen Elizabeth I’s “Tilbury Speech,” for example, she addresses her audience in a personable and highly emotional way: “My loving people, We have been persuaded by some that are careful of our safety, to take heed how we commit our selves to armed multitudes for fear of treachery; but I assure you I do not desire to live to distrust my faithful and loving people. Let tyrants fear.”

Examples of Persuasive Essay

1. Martin Luther King, Jr., “Letter From Birmingham Jail”

Dr. King directs his essay at the Alabama clergymen who opposed his call for protests. The clergymen suggested that King had no business being in Alabama, that he shouldn’t oppose some of the more respectful segregationists, and that he has poor timing. However, here, King attempts to persuade the men that his actions are just:

I am in Birmingham because injustice is here. Just as the prophets of the eight century B.C. left their villages and carried their ‘thus saith the Lord’ far beyond the boundaries of their hometowns, and just as the Apostle Paul left his village of Tarsus and carried the gospel of Jesus Christ to the far corners of the Greco-Roman world, so am I compelled to carry the gospel of freedom beyond my hometown.

Here, King is invoking the ethos of Biblical figures who the clergymen would’ve respected. By comparing himself to Paul, he’s claiming to be a disciple spreading the “gospel of freedom” rather than an outsider butting into Alabama’s affairs.

2. Garrett Hardin, “The Tragedy of Commons”

Hardin argues that a society that shares resources is apt to overuse those resources as the population increases. He attempts to persuade readers that the human population’s growth should be regulated for the sake of preserving resources:

The National Parks present another instance of the working out of the tragedy of commons. At present, they are open to all, without limit. The parks themselves are limited in extent—there is only one Yosemite Valley—whereas population seems to grow without limit. The values that visitors seek in the parks are steadily eroded. Plainly, we must soon cease to treat the parks as commons, or they will be of no value to anyone.

In this excerpt, Harden uses an example that appeals to the reader’s logic. If the human population continues to rise, causing park visitors to increase, parks will continue to erode until there’s nothing left.

Further Resources on Persuasive Essays

We at SuperSummary offer excellent resources for penning your own essays .

Find a list of famous persuasive speeches at Highspark.co .

Read up on the elements of persuasion at the American Management Association website.

Related Terms

• Argumentative Essay

Writing a Persuasive Essay

Persuasive essays convince readers to accept a certain perspective. Writing a persuasive essay therefore entails making an argument that will appeal to readers, so they believe what you say has merit. This act of appealing to readers is the art of persuasion, also known as rhetoric. In classical rhetoric, persuasion involves appealing to readers using ethos, pathos, and logos.

In this tutorial, we refer to the sample persuasive draft and final paper written by fictional student Maggie Durham.

THE ART OF PERSUASION

Ethos refers to establishing yourself as a credible source of information. To convince an audience of anything, they must first trust you are being earnest and ethical. One strategy to do this is to write a balanced discussion with relevant and reliable research that supports your claims. Reliable research would include quoting or paraphrasing experts, first-hand witnesses, or authorities. Properly citing your sources, so your readers can also retrieve them, is another factor in establishing a reliable ethos. When writing for academic purposes, expressing your argument using unbiased language and a neutral tone will also indicate you are arguing fairly and with consideration of others having differing views.

When you appeal to your readers’ emotions, you are using pathos. This appeal is common in advertising that convinces consumers they lack something and buying a certain product or service will fulfill that lack. Emotional appeals are subtler in academic writing; they serve to engage a reader in the argument and inspire a change of heart or motivate readers toward a course of action. The examples you use, how you define terms, any comparisons you draw, as well as the language choices you use can draw readers in and impact their willingness to go along with your ideas.

Consider that one purpose of persuasion is to appeal to those who do not already agree with you, so it will be important to show that you understand other points of view. You will also want to avoid derogatory or insulting descriptions or remarks about the opposition. You wouldn’t want to offend the very readers you want to persuade.

Establishing an appeal of logos is to write a sound argument, one that readers can follow and understand. To do this, the facts and evidence you use should be relevant, representative, and reliable, and the writing as a whole should be well organized, developed, and edited.

STEPS FOR WRITING PERSUASIVELY

Step one: determine the topic.

The first step in writing a persuasive essay is to establish the topic. The best topic is one that interests you. You can generate ideas for a topic by prewriting, such as by brainstorming whatever comes to mind, recording in grocery-list fashion your thoughts, or freewriting in complete sentences what you know or think about topics of interest.

Whatever topic you choose, it needs to be:

• Interesting : The topic should appeal both to you and to your intended readers.
• Researchable : A body of knowledge should already exist on the topic.
• Nonfiction : The information about the topic should be factual, not based on personal opinions or conspiracy theories.
• Important : Your reader should think the topic is relevant to them or worthy of being explored and discussed.

Our sample student Maggie Durham has selected the topic of educational technology. We will use Maggie’s sample persuasive draft and final paper as we discuss the steps for writing a persuasive essay.

Step Two: Pose a Research Question

Once you have a topic, the next step is to develop a research question along with related questions that delve further into the first question. If you do not know what to ask, start with one of the question words: What? Who? Where? When? Why? and How? The research question helps you focus or narrow the scope of your topic by identifying a problem, controversy, or aspect of the topic that is worth exploration and discussion. Some general questions about a topic would be the following:

• Who is affected by this problem and how?
• Have previous efforts or polices been made to address this problem? – What are they?
• Why hasn’t this problem been solved already?

For Maggie’s topic of educational technology, potential issues or controversies range from data privacy to digital literacy to the impact of technology on learning, which is what Maggie is interested in. Maggie’s local school district has low literacy rates, so Maggie wants to know the following:

• Are there advantages and/or disadvantages of technology within primary and secondary education?
• Which types of technology are considered the best in terms of quality and endurance?
• What types of technology and/or programs do students like using and why?
• Do teachers know how to use certain technologies with curriculum design, instruction, and/or assessment?

Step Three: Draft a Thesis

A thesis is a claim that asserts your main argument about the topic. As you conduct your research and draft your paper, you may discover information that changes your mind about your thesis, so at this point in writing, the thesis is tentative. Still, it is an important step in narrowing your focus for research and writing.

The thesis should

1. be a complete sentence,

2. identify the topic, and

3. make a specific claim about that topic.

In a persuasive paper, the thesis is a claim that someone should believe or do something. For example, a persuasive thesis might assert that something is effective or ineffective. It might state that a policy should be changed or a plan should be implemented. Or a persuasive thesis might be a plea for people to change their minds about a particular issue.

Once you have figured out your research question, your thesis is simply the answer. Maggie’s thesis is “Schools should supply technology aids to all students to increase student learning and literacy rates.” Her next step is to find evidence to support her claim.

Step Four: Research

Once you have a topic, research question, and thesis, you are ready to conduct research. To find sources that would be appropriate for an academic persuasive essay, begin your search in the library. The Purdue Global Library has a number of tutorials on conducting research, choosing search teams, types of sources, and how to evaluate information to determine its reliability and usefulness. Remember that the research you use will not only provide content to prove your claim and develop your essay, but it will also help to establish your credibility as a reliable source (ethos), create a logical framework for your argument (logos), and appeal to your readers emotionally (pathos).

Step Five: Plan Your Argument; Make an Outline

Once you have located quality source information—facts, examples, definitions, knowledge, and other information that answers your research question(s), you’ll want to create an outline to organize it. The example outline below illustrates a logical organizational plan for writing a persuasive essay. The example outline begins with an introduction that presents the topic, explains the issue, and asserts the position (the thesis). The body then provides the reasoning for the position and addresses the opposing viewpoints that some readers may hold. In your paper, you could modify this organization and address the opposing viewpoints first and then give the reasoning for your viewpoints, or you can alternate and give one opposing viewpoint then counter that with your viewpoint and then give another opposing viewpoint and counter that with your viewpoint.

The outline below also considers the alternatives to the position—certainly, there are other ways to think about or address the issue or situation. Considering the alternatives can be done in conjunction with looking at the opposing viewpoints. You do not always have to disagree with other opinions, either. You can acknowledge that another solution could work or another belief is valid. However, at the end of the body section, you will want to stand by your original position and prove that in light of all the opposing viewpoints and other perspectives, your position has the most merit.

Sample Outline of a Persuasive Argument

• 1. Introduction: Tell them what you will tell them.
• a. Present an interesting fact or description to make the topic clear and capture the reader’s attention.
• b. Define and narrow the topic using facts or descriptions to illustrate what the situation or issue is (and that is it important).
• c. Assert the claim (thesis) that something should be believed or done about the issue. (Some writers also briefly state the reasons behind this claim in the thesis as Maggie does in her paper when she claims that schools should supply tablets to students to increase learning , engagement, and literacy rates ).
• 2. Body: Tell them.
• a. Defend the claim with logical reasons and practical examples based on research.
• b. Anticipate objections to the claim and refute or accommodate them with research.
• c. Consider alternate positions or solutions using examples from research.
• d. Present a final point based on research that supports your claim in light of the objections and alternatives considered.
• 3. Conclusion: Tell them what you told them.
• a. Recap the main points to reinforce the importance of the issue.
• b. Restate the thesis in new wording to reinforce your position.
• c. Make a final remark to leave a lasting impression, so the reader will want to continue this conversation and ideally adopt the belief or take the action you are advocating.

In Maggie’s draft, she introduced the topic with facts about school ratings in Texas and then narrowed the topic using the example of her local school district’s literacy rates. She then claimed the district should provide each student a tablet in order to increase learning (and thus, literacy rates).

Maggie defends her claim with a series of examples from research that proved how access to tablets, technology-integrated curriculums, and “flipped classrooms” have improved literacy rates in other districts. She anticipates objections to her proposal due to the high cost of technology and counter argues this with expert opinions and examples that show partnerships with businesses, personalized curriculums that technology makes possible, and teacher training can balance the costs. Maggie included an alternative solution of having students check out tablets from the library, but her research showed that this still left students needing Wi-Fi at home while her proposal would include a plan for students to access Wi-Fi.

Maggie concluded her argument by pointing out the cost of not helping the students in this way and restated her thesis reaffirming the benefits, and then left the reader with a memorable quote.

Click here to see Maggie’s draft with feedback from her instructor and a peer. Sample Persuasive Draft

Feedback, Revision, and Editing

After you write a draft of your persuasive essay, the next step is to have a peer, instructor, or tutor read it and provide feedback. Without reader feedback, you cannot fully know how your readers will react to your argument. Reader feedback is meant to be constructive. Use it to better understand your readers and craft your argument to more appropriately appeal to them.

Maggie received valuable feedback on her draft from her instructor and classmate. They pointed to where her thesis needed to be even more specific, to paragraphs where a different organization would make her argument more convincing, to parts of the paper that lacked examples, sentences that needed revision and editing for greater clarity, and APA formatting that needed to be edited.

Maggie also took a critical look at her paper and looked back at her writing process. One technique she found helpful was to read her paper aloud because it let her know where her wording and organization were not clear. She did this several times as she revised and again as she edited and refined her paper for sentence level clarity and concision.

In the end, Maggie produced a convincing persuasive essay and effective argument that would appeal to readers who are also interested in the way technology can impact and improve student learning, an important topic in 2014 when this paper was written and still relevant today.

Click here to see Maggie’s final draft after revising and editing. Sample Persuasive Revised

Share this:

• Click to email a link to a friend (Opens in new window)
• Click to share on Facebook (Opens in new window)
• Click to share on Reddit (Opens in new window)
• Click to share on Twitter (Opens in new window)
• Click to share on LinkedIn (Opens in new window)
• Click to share on Pinterest (Opens in new window)
• Click to print (Opens in new window)

Follow Blog via Email

Enter your email address to follow this blog and receive email notifications of new posts.

Email Address

• RSS - Posts
• RSS - Comments
• COLLEGE WRITING
• USING SOURCES & APA STYLE
• EFFECTIVE WRITING PODCASTS
• LEARNING FOR SUCCESS
• PLAGIARISM INFORMATION
• FACULTY RESOURCES
• Student Webinar Calendar
• Academic Success Center
• Writing Center
• About the ASC Tutors
• DIVERSITY TRAINING
• PG Peer Tutors
• PG Student Access

Subscribe to Blog via Email

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

• College Writing
• Using Sources & APA Style
• Learning for Success
• Effective Writing Podcasts
• Plagiarism Information
• Faculty Resources
• Tutor Training

Twitter feed

Home / Guides / Writing Guides / Paper Types / How to Write a Persuasive Essay

How to Write a Persuasive Essay

The entire point of a persuasive essay is to persuade or convince the reader to agree with your perspective on the topic. In this type of essay, you’re not limited to facts. It’s completely acceptable to include your opinions and back them up with facts, where necessary.

Guide Overview

• Be assertive
• Use words that evoke emotion
• Make it personal
• Topic selection hints

Tricks for Writing a Persuasive Essay

In this type of writing, you’ll find it is particularly helpful to focus on the emotional side of things. Make your reader feel what you feel and bring them into your way of thinking. There are a few ways to do that.

Be Assertive

A persuasive essay doesn’t have to be gentle in how it presents your opinion. You really want people to agree with you, so focus on making that happen, even if it means pushing the envelope a little. You’ll tend to get higher grades for this, because the essay is more likely to convince the reader to agree. Consider using an Persuasive Essay Template to understand the key elements of the essay.

Use Words that Evoke Emotion

It’s easier to get people to see things your way when they feel an emotional connection. As you describe your topic, make sure to incorporate words that cause people to feel an emotion. For example, instead of saying, “children are taken from their parents” you might say, “children are torn from the loving arms of their parents, kicking and screaming.” Dramatic? Yes, but it gets the point across and helps your reader experience the

Make it Personal

By using first person, you make the reader feel like they know you. Talking about the reader in second person can help them feel included and begin to imagine themselves in your shoes. Telling someone “many people are affected by this” and telling them “you are affected by this every day” will have very different results.

While each of these tips can help improve your essay, there’s no rule that you have to actually persuade for your own point of view. If you feel the essay would be more interesting if you take the opposite stance, why not write it that way? This will require more research and thinking, but you could end up with a very unique essay that will catch the teacher’s eye.

Topic Selection Hints

A persuasive essay requires a topic that has multiple points of view. In most cases, topics like the moon being made of rock would be difficult to argue, since this is a solid fact. This means you’ll need to choose something that has more than one reasonable opinion related to it.

A good topic for a persuasive essay would be something that you could persuade for or against.

Some examples include:

• Should children be required to use booster seats until age 12?
• Should schools allow the sale of sugary desserts and candy?
• Should marijuana use be legal?
• Should high school students be confined to school grounds during school hours?
• Should GMO food be labeled by law?
• Should police be required to undergo sensitivity training?
• Should the United States withdraw troops from overseas?

Some topics are more controversial than others, but any of these could be argued from either point of view . . . some even allow for multiple points of view.

As you write your persuasive essay, remember that your goal is to get the reader to nod their head and agree with you. Each section of the essay should bring you closer to this goal. If you write the essay with this in mind, you’ll end up with a paper that will receive high grades.

Finally, if you’re ever facing writer’s block for your college paper, consider WriteWell’s template gallery to help you get started.

EasyBib Writing Resources

Writing a paper.

• Academic Essay
• Argumentative Essay
• College Admissions Essay
• Expository Essay
• Persuasive Essay
• Research Paper
• Thesis Statement
• Writing a Conclusion
• Writing an Introduction
• Writing an Outline
• Writing a Summary

EasyBib Plus Features

• Citation Generator
• Essay Checker
• Expert Check Proofreader
• Grammar Checker
• Paraphrasing Tools

Plagiarism Checker

• Spell Checker

How useful was this post?

Click on a star to rate it!

We are sorry that this post was not useful for you!

Let us improve this post!

Tell us how we can improve this post?

Grammar and Plagiarism Checkers

Grammar Basics

Plagiarism Basics

Writing Basics

Upload a paper to check for plagiarism against billions of sources and get advanced writing suggestions for clarity and style.

Get Started

How to Write a Persuasive Essay: From a Definition to Paper Writing

4 August 2023

last updated

Students use reasons to demonstrate the validity of controversial ideas when writing a persuasive essay. Basically, argumentative compositions encourage readers to accept a specific stand on a current issue. Convincing papers persuade persons who read to change their thoughts and ideas. In this case, writers rely on brainstorming, researching, structuring the work in different sections, and proofreading. Moreover, 10 steps on how to write a persuasive essay improve the overall quality, credibility, and applicability of papers. Firstly, preparing several drafts aligns arguments with discussed ideas. Then, meeting rubrics improves overall outcomes during rewriting. However, peer review remains an essential step toward writing better papers. In turn, additional tips include a persuasive introduction, unbiased opinions, and adequate details. Besides, conclusions show that persuasive essays must provide sufficient support for debatable topics.

Key Features of How to Write an Outstanding Persuasive Essay

Nowadays, essay writing is a typical task for all students, and learners at various levels of education commonly write persuasive essays. They master their skills as a means of providing an opinion on different topics. For example, writers develop their arguments to persuade their audience. In this case, an in-depth discussion concerning persuasive writing focuses on its definition, supporting evidence section, and rebuttal section. Persuasive essays must express one’s opinion clearly, while proper knowledge of how to write a persuasive essay can help learners to encourage readers to accept a specific viewpoint. Persuasive essay writing skills demonstrate one’s creativity and communicate a strong emotion, covering brainstorming, researching, structuring, and proofreading methods. Besides, compelling persuasive compositions include a personal connection to the topic. Convincing introductions should contain a summary of the main points, opposing ideas, and rebuttals. Successful writers include a strong thesis statement to express the main arguments provided in their essays. As a result, this article on how to write a persuasive essay remains helps to organize persuasive papers.

Definition of What Is a Persuasive Essay and Its Meaning

Persuasive essays mean a specific type of academic paper. Basically, the main aim of writing a persuasive essay is to convince readers that a particular opinion is correct, and students should support their persuasive essay topics using valid arguments and making a claim, striving to show readers that it is reasonable. Moreover, persuasive writing requires learners to explain their positions in an organized manner. It not only addresses all relevant perspectives but also demonstrates the superiority of the author’s point of view. In turn, the development of a persuasive argument requires an unbiased approach to a particular topic. It is because authors provide not only a complete argument but also a comprehensive discussion. Therefore, a persuasive essay can be defined as a piece of writing that works to coerce an audience to accept a given position concerning a controversial topic.

Purpose of a Persuasive Essay

Persuasive essays use reasons to demonstrate the validity of ideas. For instance, the purpose of persuasive essays is to encourage readers to accept a particular viewpoint. Compelling compositions convince persons who read to act in a specific way. Basically, the hypothesis in persuasive papers relies on a value or a policy:

• approval of specific values or standards;
• disapproval of specific subjects;
• a call for the adoption of the change in beliefs or policies.

Writers debate an issue that affects them, society, or country since they know how to write a persuasive essay. Basically, outstanding compositions contain the definition of an item and show both sides of an argument. Moreover, writing a good persuasive essay means taking a clear stand on the problem, considering the third person, and following formal language for discussion.

Use of a Persuasive Essay

A persuasive essay is used to advance an individual’s opinion to the audience through evidence-based writing, which persuades readers of its objectivity. In particular, there are two main sections in the body of such an essay: supporting evidence and rebuttal. Each of these sections plays a vital role in convincing the audience of the validity of an argument. Thus, this type of essay is essential because it prepares young minds for the development of sophisticated objective arguments that contribute positively to academia.

Evidence Section of a Persuasive Essay

A segment of the body in a persuasive essay is designed to discuss evidence supporting the author’s main argument. For instance, a significant portion of body paragraphs contains evidence from experts acquired during research on an issue. In this case, a crucial aspect of a persuasive speech is the provision of facts that have been established through studies with irreproachable methodologies. Also, detailed explanations must support the evidence. These aspects demonstrate logical reasoning and a clear link to a thesis statement. Hence, the choice of evidence used to support the author’s central claim has a significant impact on an essay’s overall persuasion effect.

Rebuttal Part in Persuasive Essays

Students include a rebuttal section within the body of a persuasive essay. In particular, this section is equally important. It allows authors to explain the flaws of the other competing lines of thought. For example, the rebuttal portion of a persuasive essay contributes to the coercion effect. Moreover, it shows the audience that writers have considered alternative opinions and found them to be deficient. Hence, an effective persuasive essay must display a high level of objectivity in identifying the shortcomings of opposing opinions.

Other Features

Persuasive essays are a stepping stone toward objective scientific arguments. Basically, the consistent practice of skills in a persuasive essay develops the ability to argue objectively by integrating reasons, evidence, and logic. In this case, objective arguments are the foundation of the scientific language of disagreement, which is independent of personal biases. Consequently, such works prepare learners for participation in the academic sphere through the contribution of new arguments or refuting existing arguments.

Criteria for Writing Persuasive Essays

1. knowledge.

Persuasive essays express one’s opinion clearly. The following points are essential in preparing persuasive essays:

• stating the problem, opinion, and solution clearly;
• including sufficient evidence and details to support opinions;
• presenting and summarizing essential issues in introduction and conclusion parts.

2. Thinking

Persuasive essays demonstrate one’s creativity and express strong emotions. In particular, these compositions contain logical and reasonable ideas organized in a sequence. Besides, students must connect ideas with covered opinions. In turn, the following points are essential for demonstrating higher thinking abilities:

• supporting ideas with details and reasons;
• presenting personal reasons for supporting arguments;
• demonstrating a high level of understanding of essential concepts from secondary sources.

3. Communication

Persuasive essays rely on explicit expressions and logical organization of ideas. One must:

• present opinions clearly;
• demonstrate formal voice, style, and tone;
• use correct spelling, grammar, and punctuations;
• implement fluent sentences and paragraphs when organizing arguments or ideas.

4. Application

If students understand how to write a persuasive essay, they include personal connections to persuasive speech topics . Moreover, writers must:

• use information from external sources to support opinions;
• demonstrate an understanding of the importance of the topic.

10 Steps on How to Write a Good Persuasive Essay

1. brainstorming.

Students brainstorm to generate ideas that support assigned themes. In this case, they can use several ways of creating the necessary concepts for supporting argumentative topics:

• Free writing – One writes quickly without stopping, editing, and self-correcting. The process makes students aware of what they already know, think, and feel on essay topics .
• Subject Tree – Scholars must note down related ideas and connect them with the main topic. For example, students use a tree structure to organize thoughts that support the main ideas presented.
• List – The process involves listing ideas that support the topic.
• Clustering – The step involves drawing a circle that contains the main topic. Basically, writers list other ideas related to the concept on the ring’s sides.
• Outline – Learners create a composition framework, which includes the main points. In turn, the process consists of breaking down the main topic into sub-points.  

2. Researching

Researching involves gathering information from libraries or other credible sources by considering how to write a persuasive essay. Basically, students may use the Internet as a suitable source of credible information. In turn, acceptable sources include reference works, books, and scholarly articles. However, writers should observe the following points:

• assessing a site for timeliness and reputability;
• considering the website’s purpose of the site;
• evaluating the website’s reliability and the author’s credibility;
• gathering all the source information and covering credentials during citing;
• avoiding all forms of plagiarism during writing.

3. Developing a Thesis Statement

A thesis statement links ideas presented in the composition. For instance, a strong thesis statement contains a claim and supporting details. In turn, effective thesis statements:

• make an assertion and take a stance;
• generalize information;
• do not include facts;
• contain debatable information;
• appear as the last sentence in the introduction.

Supporting details reinforce and sustain the main argument. In particular, different organization methods on how to write a persuasive essay make academic papers compelling. For example, scholars use problem-solution, cause-effect, and statement of reason organization writing techniques. Moreover, strong thesis statements combine claims and supporting details in one sentence. In turn, one may change the composition’s direction based on the pattern for organizing the evidence.

4. How to Write a Persuasive Essay With a Good Introduction

The introduction contains the composition’s most general information. Basically, writers set the essay’s road map in the opening paragraph. In turn, important points include:

• Definition – The introduction identifies, defines, and describes discussed topics. The student describes the main ideas discussed in the subject.
• Relevance – The first section shows the importance, concept, and theme in the composition. Compelling opening paragraphs explain how the essay impacts society.
• Thesis Statement – Students put the thesis statement as the last sentence in a composition.

5. Writing Body Paragraphs

The body contains adequate details that support the main arguments. For instance, compelling papers address each supporting aspect in a separate and fully developed section. Moreover, including necessary evidence leads to compelling papers, covering how to write a persuasive essay. In this case, argumentative works include:

• topic sentence in every paragraph;
• topic sentence that summarizes the supporting details;
• every paragraph supports a single idea.

6. Writing Opposing Arguments

Persuasive essays provide opposing views. Basically, writers state and explain different concepts in articles. In this case, specific approaches show how a person with conflicting thoughts may clash with the main arguments.

7. Writing Rebuttal Claims

Writers must provide an application that opposes counterclaims. For example, effective rebuttals show the weaknesses in the contrasting arguments. Sometimes, one may agree with some concepts in the refutations. Moreover, compelling compositions indicate the student’s thoughts on the contradictions.   

8. Writing a Conclusion

The conclusion closes the persuasive essay. Scholars rewrite the thesis statement and words it differently to follow the rules of how to write a persuasive essay. Closing paragraphs reiterate and summarize the main points of compositions. In this case, writers should observe the following points:

• Relevance – Conclusions repeat the importance of the topic;
• Review – Closing elements reiterates the points discussed in the body;
• Summary – The last item in a persuasive essay recaps the main points.

9. Rewriting

Students should rewrite first drafts and effect necessary changes that make persuasive papers readable. Basically, scholars follow the following points:

• Learners rewrite first drafts and incorporate appropriate modifications. In this case, the process makes persuasive essays suitable for the target audience.
• Rewriting papers several times ensures that compositions meet the required standard on how to write a persuasive essay.
• Rubrics play an essential role in determining the effectiveness of achieving significant concepts in essays. 
• Second and subsequent drafts ensure that papers meet the required academic standards.

10. Proofreading and Editing

Proofreading papers comes as the last step on how to write a persuasive essay, determining the overall quality. In particular, students read essays several times and identifies significant ideas. For instance, primary goals include identifying common grammatical mistakes and other syntax errors. In this case, identifying spelling mistakes that lower the paper’s quality leads to better outcomes from readers. Other important concepts include the removal of grammatical errors that may affect the readability of a persuasive essay.

Peers play a significant role when proofreading written works. Basically, the authors of persuasive essays should ask scholars to read written essays for identifying hidden mistakes. In this case, an analysis of essays improves the overall outcomes of the target audience. Furthermore, peer-evaluation enhances the overall flow of information in the composition. In turn, embracing peers for proofreading or editing written works improves the overall quality.  

Recommendations for Writing a Persuasive Essay

Introduction

Persuasive essays contain compelling opening paragraphs, leading to relevance and readability of papers. If scholars are familiar with the rules of how to write a persuasive essay, they provide a summary of the main points, opposing ideas, and rebuttals. In turn, successful writers include a strong thesis statement for expressing the main arguments. Besides, a debatable thesis statement works best for persuasive essays.  

Outstanding writers provide compelling ideas for supporting core arguments. For instance, unbiased views and judgments influence the reader’s thoughts on a specific topic. Moreover, well-developed arguments enhance the overall quality of persuasive essays.  

Good writers present adequate information that supports the main arguments, counterarguments, and refutations. In this case, real-life examples make a persuasive essay compelling and useful. 

65 Tips for Writing Academic Persuasive Essays

The previous chapters in this section offer an overview of what it means to formulate an argument in an academic situation. The purpose of this chapter is to offer more concrete, actionable tips for drafting an academic persuasive essay. Keep in mind that preparing to draft a persuasive essay relies on the strategies for any other thesis-driven essay, covered by the section in this textbook, The Writing Process. The following chapters can be read in concert with this one:

• Critical Reading and other research strategies helps writers identify the exigence (issue) that demands a response, as well as what kinds of research to use.
• Generate Ideas covers prewriting models (such as brainstorming techniques) that allow students to make interesting connections and develop comprehensive thesis statements. These connections and main points will allow a writer to outline their core argument.
• Organizing is important for understanding why an argument essay needs a detailed plan, before the drafting stage. For an argument essay, start with a basic outline that identifies the claim, reasoning, and evidence, but be prepared to develop more detailed outlines that include counterarguments and rebuttals, warrants, additional backing, etc., as needed.
• Drafting introduces students to basic compositional strategies that they must be familiar with before beginning an argument essay. This current chapter offers more details about what kinds of paragraphs to practice in an argument essay, but it assumes the writer is familiar with basic strategies such as coherence and cohesion.

Classical structure of an argument essay

Academic persuasive essays tend to follow what’s known as the “classical” structure, based on techniques that derive from ancient Roman and Medieval rhetoricians. John D. Ramage, et. al outline this structure in Writing Arguments :

This very detailed table can be simplified. Most academic persuasive essays include the following basic elements:

• Introduction that explains why the situation is important and presents your argument (aka the claim or thesis).
• Reasons the thesis is correct or at least reasonable.
• Evidence that supports each reason, often occurring right after the reason the evidence supports.
• Acknowledgement of objections.
• Response to objections.

Keep in mind that the structure above is just a conventional starting point. The previous chapters of this section suggest how different kinds of arguments (Classical/Aristotelian, Toulmin, Rogerian) involve slightly different approaches, and your course, instructor, and specific assignment prompt may include its own specific instructions on how to complete the assignment. There are many different variations. At the same time, however, most academic argumentative/persuasive essays expect you to practice the techniques mentioned below. These tips overlap with the elements of argumentation, covered in that chapter, but they offer more explicit examples for how they might look in paragraph form, beginning with the introduction to your essay.

Persuasive introductions should move from context to thesis

Since one of the main goals of a persuasive essay introduction is to forecast the broader argument, it’s important to keep in mind that the legibility of the argument depends on the ability of the writer to provide sufficient information to the reader. If a basic high school essay moves from general topic to specific argument (the funnel technique), a more sophisticated academic persuasive essay is more likely to move from context  to thesis.

The great stylist of clear writing, Joseph W. Williams, suggests that one of the key rhetorical moves a writer can make in a persuasive introduction is to not only provide enough background information (the context), but to frame that information in terms of a problem or issue, what the section on Reading and Writing Rhetorically terms the exigence . The ability to present a clearly defined problem and then the thesis as a solution creates a motivating introduction. The reader is more likely to be gripped by it, because we naturally want to see problems solved.

Consider these two persuasive introductions, both of which end with an argumentative thesis statement:

Example B feels richer, more dramatic, and much more targeted not only because it’s longer, but because it’s structured in a “motivating” way. Here’s an outline of that structure:

• Hook: It opens with a brief hook that illustrates an emerging issue. This concrete, personal anecdote grips the reader’s attention.
• Problem: The anecdote is connected with the emerging issue, phrased as a problem that needs to be addressed.
• Debate: The writer briefly alludes to a debate over how to respond to the problem.
• Claim: The introduction ends by hinting at how the writer intends to address the problem, and it’s phrased conversationally, as part of an ongoing dialogue.

Not every persuasive introduction needs all of these elements. Not all introductions will have an obvious problem. Sometimes a “problem,” or the exigence, will be as subtle as an ambiguity in a text that needs to be cleared up (as in literary analysis essays). Other times it will indeed be an obvious problem, such as in a problem-solution argument essay.

In most cases, however, a clear introduction will proceed from context to thesis . The most attention-grabbing and motivating introductions will also include things like hooks and problem-oriented issues.

Here’s a very simple and streamlined template that can serve as rudimentary scaffolding for a persuasive introduction, inspired by the excellent book, They Say / I Say:  The Moves That Matter in Academic Writing :

Each aspect of the template will need to be developed, but it can serve as training wheels for how to craft a nicely structured context-to-thesis introduction, including things like an issue, debate, and claim. You can try filling in the blanks below, and then export your attempt as a document.

Define key terms, as needed

Much of an academic persuasive essay is dedicated to supporting the claim. A traditional thesis-driven essay has an introduction, body, and conclusion, and the support constitutes much of the body. In a persuasive essay, most of the support is dedicated to reasoning and evidence (more on that below). However, depending on what your claim does, a careful writer may dedicate the beginning (or other parts of the essay body) to defining key terms.

Suppose I wish to construct an argument that enters the debate over euthanasia. When researching the issue, I notice that much of the debate circles around the notion of rights, specifically what a “legal right” actually means. Clearly defining that term will help reduce some of the confusion and clarify my own argument. In Vancouver Island University’s resource “ Defining key terms ,” Ian Johnston  offers this example for how to define “legal right” for an academic reader:

Before discussing the notion of a right to die, we need to clarify precisely what the term legal right means. In common language, the term “right” tends often to mean something good, something people ought to have (e.g., a right to a good home, a right to a meaningful job, and so on). In law, however, the term has a much more specific meaning. It refers to something to which people are legally entitled. Thus, a “legal” right also confers a legal obligation on someone or some institution to make sure the right is conferred. For instance, in Canada, children of a certain age have a right to a free public education. This right confers on society the obligation to provide that education, and society cannot refuse without breaking the law. Hence, when we use the term right to die in a legal sense, we are describing something to which a citizen is legally entitled, and we are insisting that someone in society has an obligation to provide the services which will confer that right on anyone who wants it.

As the example above shows, academics often dedicate space to providing nuanced and technical definitions that correct common misconceptions. Johnston’s definition relies on research, but it’s not always necessary to use research to define your terms. Here are some tips for crafting definitions in persuasive essays, from “Defining key terms”:

• Fit the descriptive detail in the definition to the knowledge of the intended audience. The definition of, say, AIDS for a general readership will be different from the definition for a group of doctors (the latter will be much more technical). It often helps to distinguish between common sense or popular definitions and more technical ones.
• Make sure definitions are full and complete; do not rush them unduly. And do not assume that just because the term is quite common that everyone knows just what it means (e.g.,  alcoholism ). If you are using the term in a very specific sense, then let the reader know what that is. The amount of detail you include in a definition should cover what is essential for the reader to know, in order to follow the argument. By the same token, do not overload the definition, providing too much detail or using far too technical a language for those who will be reading the essay.
• It’s unhelpful to simply quote the google or dictionary.com definition of a word. Dictionaries contain a few or several definitions for important terms, and the correct definition is informed by the context in which it’s being employed. It’s up to the writer to explain that context and how the word is usually understood within it.
• You do not always need to research a definition. Depending on the writing situation and audience, you may be able to develop your own understanding of certain terms.

Use P-E-A-S or M-E-A-L to support your claim

The heart of a persuasive essay is a claim supported by reasoning and evidence. Thus, much of the essay body is often devoted to the supporting reasons, which in turn are proved by evidence. One of the formulas commonly taught in K-12 and even college writing programs is known as PEAS, which overlaps strongly with the MEAL formula introduced by the chapter, “ Basic Integration “:

Point : State the reasoning as a single point: “One reason why a soda tax would be effective is that…” or “One way an individual can control their happiness is by…”

Evidence : After stating the supporting reason, prove that reason with related evidence. There can be more than one piece of evidence. “According to …” or “In the article, ‘…,’ the author shows that …”

Analysis : There a different levels of analysis.  At the most basic level, a writer should clearly explain how the evidence proves the point, in their own words: “In other words…,” “What this data shows is that…” Sometimes the “A” part of PEAS becomes simple paraphrasing. Higher-level analysis will use more sophisticated techniques such as Toulmin’s warrants to explore deeper terrain. For more tips on how to discuss and analyze, refer to the previous chapter’s section, “ Analyze and discuss the evidence .”

Summary/So what? : Tie together all of the components (PEA) succinctly, before transitioning to the next idea. If necessary, remind the reader how the evidence and reasoning relates to the broader claim (the thesis argument).

PEAS and MEAL are very similar; in fact they are identical except for how they refer to the first and last part. In theory, it shouldn’t matter which acronym you choose. Both versions are effective because they translate the basic structure of a supporting reason (reasoning and evidence) into paragraph form.

Here’s an example of a PEAS paragraph in an academic persuasive essay that argues for a soda tax:

A soda tax would also provide more revenue for the federal government, thereby reducing its debt. point Despite Ernest Istook’s concerns about eroding American freedom, the United States has long supported the ability of government to leverage taxes in order to both curb unhealthy lifestyles and add revenue. According to Peter Ubel’s “Would the Founding Fathers Approve of a Sugar Tax?”, in 1791 the US government was heavily in debt and needed stable revenue. In response, the federal government taxed what most people viewed as a “sin” at that time: alcohol. This single tax increased government revenue by at least 20% on average, and in some years more than 40% . The effect was that only the people who really wanted alcohol purchased it, and those who could no longer afford it were getting rid of what they already viewed as a bad habit (Ubel). evidence Just as alcohol (and later, cigarettes) was viewed as a superfluous “sin” in the Early Republic, so today do many health experts and an increasing amount of Americans view sugar as extremely unhealthy, even addictive. If our society accepts taxes on other consumer sins as a way to improve government revenue, a tax on sugar is entirely consistent. analysis We could apply this to the soda tax and try to do something like this to help knock out two problems at once: help people lose their addiction towards soda and help reduce our government’s debt. summary/so what?

The paragraph above was written by a student who was taught the PEAS formula. However, we can see versions of this formula in professional writing. Here’s a more sophisticated example of PEAS, this time from a non-academic article. In Nicholas Carr’s extremely popular article, “ Is Google Making Us Stupid? “, he argues that Google is altering how we think. To prove that broader claim, Carr offers a variety of reasons and evidence. Here’s part of his reasoning:

Thanks to the ubiquity of text on the Internet, not to mention the popularity of text-messaging on cell phones, we may well be reading more today than we did in the 1970s or 1980s, when television was our medium of choice. But it’s a different kind of reading, and behind it lies a different kind of thinking—perhaps even a new sense of the self. point “We are not only  what  we read,” says Maryanne Wolf, a developmental psychologist at Tufts University and the author of  Proust and the Squid: The Story and Science of the Reading Brain . “We are  how we read.” Wolf worries that the style of reading promoted by the Net, a style that puts “efficiency” and “immediacy” above all else, may be weakening our capacity for the kind of deep reading that emerged when an earlier technology, the printing press, made long and complex works of prose commonplace. When we read online, she says, we tend to become “mere decoders of information.” evidence Our ability to interpret text, to make the rich mental connections that form when we read deeply and without distraction, remains largely disengaged. analysis

This excerpt only contains the first three elements, PEA, and the analysis part is very brief (it’s more like paraphrase), but it shows how professional writers often employ some version of the formula. It tends to appear in persuasive texts written by experienced writers because it reinforces writing techniques mentioned elsewhere in this textbook. A block of text structured according to PEA will practice coherence, because opening with a point (P) forecasts the main idea of that section. Embedding the evidence (E) within a topic sentence and follow-up commentary or analysis (A) is part of the “quote sandwich” strategy we cover in the section on “Writing With Sources.”

Use “they say / i say” strategies for Counterarguments and rebuttals

Another element that’s unique to persuasive essays is embedding a counterargument. Sometimes called naysayers or opposing positions, counterarguments are points of view that challenge our own.

Why embed a naysayer?

Recall above how a helpful strategy for beginning a persuasive essay (the introduction) is to briefly mention a debate—what some writing textbooks call “joining the conversation.” Gerald Graff and Cathy Birkenstein’s They Say / I Say explains why engaging other points of view is so crucial:

Not long ago we attended a talk at an academic conference where the speaker’s central claim seemed to be that a certain sociologist—call him Dr. X—had done very good work in a number of areas of the discipline. The speaker proceeded to illustrate his thesis by referring extensively and in great detail to various books and articles by Dr. X and by quoting long pas-sages from them. The speaker was obviously both learned and impassioned, but as we listened to his talk we found ourselves somewhat puzzled: the argument—that Dr. X’s work was very important—was clear enough, but why did the speaker need to make it in the first place? Did anyone dispute it? Were there commentators in the field who had argued against X’s work or challenged its value? Was the speaker’s interpretation of what X had done somehow novel or revolutionary? Since the speaker gave no hint of an answer to any of these questions, we could only wonder why he was going on and on about X. It was only after the speaker finished and took questions from the audience that we got a clue: in response to one questioner, he referred to several critics who had vigorously questioned Dr. X’s ideas and convinced many sociologists that Dr. X’s work was unsound.

When writing for an academic audience, one of the most important moves a writer can make is to demonstrate how their ideas compare to others. It serves as part of the context. Your essay might be offering a highly original solution to a certain problem you’ve researched the entire semester, but the reader will only understand that if existing arguments are presented in your draft. Or, on the other hand, you might be synthesizing or connecting a variety of opinions in order to arrive at a more comprehensive solution. That’s also fine, but the creativity of your synthesis and its unique contribution to existing research will only be known if those other voices are included.

Aristotelian argumentation embeds counterarguments in order to refute them. Rogerian arguments present oppositional stances in order to synthesize and integrate them. No matter what your strategy is, the essay should be conversational.

Notice how Ana Mari Cauce opens her essay on free speech in higher education, “ Messy but Essential “:

Over the past year or two, issues surrounding the exercise of free speech and expression have come to the forefront at colleges around the country. The common narrative about free speech issues that we so often read goes something like this: today’s college students — overprotected and coddled by parents, poorly educated in high school and exposed to primarily left-leaning faculty — have become soft “snowflakes” who are easily offended by mere words and the slightest of insults, unable or unwilling to tolerate opinions that veer away from some politically correct orthodoxy and unable to engage in hard-hitting debate. counterargument

This is false in so many ways, and even insulting when you consider the reality of students’ experiences today. claim

The introduction to her article is essentially a counteragument (which serves as her introductory context) followed by a response. Embedding naysayers like this can appear anywhere in an essay, not just the introduction. Notice, furthermore, how Cauce’s naysayer isn’t gleaned from any research she did. It’s just a general, trendy naysayer, something one might hear nowadays, in the ether. It shows she’s attuned to an ongoing conversation, but it doesn’t require her to cite anything specific. As the previous chapter on using rhetorical appeals in arguments explained, this kind of attunement with an emerging problem (or exigence) is known as the appeal to kairos . A compelling, engaging introduction will demonstrate that the argument “kairotically” addresses a pressing concern.

Below is a brief overview of what counterarguments are and how you might respond to them in your arguments. This section was developed by Robin Jeffrey, in “ Counterargument and Response “:

Common Types of counterarguments

• Could someone disagree with your claim?  If so, why? Explain this opposing perspective in your own argument, and then respond to it.
• Could someone draw a different conclusion from any of the facts or examples you present?  If so, what is that different conclusion? Explain this different conclusion and then respond to it.
• Could a reader question any of your assumptions or claims?  If so, which ones would they question? Explain and then respond.
• Could a reader offer a different explanation of an issue?  If so, what might their explanation be? Describe this different explanation, and then respond to it.
• Is there any evidence out there that could weaken your position?  If so, what is it? Cite and discuss this evidence and then respond to it.

If the answer to any of these questions is yes, that does not necessarily mean that you have a weak argument. It means, ideally and as long as your argument is logical and valid, that you have a counterargument. Good arguments can and do have counterarguments; it is important to discuss them. But you must also discuss and then respond to those counterarguments.

Responding to counterarguments

You do not need to attempt to do all of these things as a way to respond; instead, choose the response strategy that makes the most sense to you, for the counterargument that you have.

• If you agree with some of the counterargument perspectives, you can concede some of their points. (“I do agree that ….”, “Some of the points made by ____ are valid…..”) You could then challenge the importance/usefulness of those points. “However, this information does not apply to our topic because…”
• If the counterargument perspective is one that contains different evidence than you have in your own argument, you can explain why a reader should not accept the evidence that the counterarguer presents.
• If the counterargument perspective is one that contains a different  interpretation of evidence than you have in your own argument, you can explain why a reader should not accept the interpretation of the evidence that that your opponent (counterarguer) presents.
• If the counterargument is an acknowledgement of evidence that threatens to weaken your argument, you must explain why and how that evidence does not, in fact invalidate your claim.

It is important to use  transitional phrases  in your paper to alert readers when you’re about to present an counterargument. It’s usually best to put this phrase at the beginning of a paragraph such as:

• Researchers have challenged these claims with…
• Critics argue that this view…
• Some readers may point to…
• A perspective that challenges the idea that . . .

Transitional phrases will again be useful to highlight your shift from counterargument to response:

• Indeed, some of those points are valid. However, . . .
• While I agree that . . . , it is more important to consider . . .
• These are all compelling points. Still, other information suggests that . .
• While I understand  . . . , I cannot accept the evidence because . . .

Further reading

To read more about the importance of counterarguments in academic writing, read Steven D. Krause’s “ On the Other Hand: The Role of Antithetical Writing in First Year Composition Courses .”

When concluding, address the “so what?” challenge

As Joseph W. Williams mentions in his chapter on concluding persuasive essays in Style ,

a good introduction motivates your readers to keep reading, introduces your key themes, and states your main point … [but] a good conclusion serves a different end: as the last thing your reader reads, it should bring together your point, its significance, and its implications for thinking further about the ideas your explored.

At the very least, a good persuasive conclusion will

• Summarize the main points
• Address the So what? or Now what? challenge.

When summarizing the main points of longer essays, Williams suggests it’s fine to use “metadiscourse,” such as, “I have argued that.” If the essay is short enough, however, such metadiscourses may not be necessary, since the reader will already have those ideas fresh in their mind.

After summarizing your essay’s main points, imagine a friendly reader thinking,

“OK, I’m persuaded and entertained by everything you’ve laid out in your essay. But remind me what’s so important about these ideas? What are the implications? What kind of impact do you expect your ideas to have? Do you expect something to change?”

It’s sometimes appropriate to offer brief action points, based on the implications of your essay. When addressing the “So what?” challenge, however, it’s important to first consider whether your essay is primarily targeted towards changing the way people  think  or  act . Do you expect the audience to do something, based on what you’ve argued in your essay? Or, do you expect the audience to think differently? Traditional academic essays tend to propose changes in how the reader thinks more than acts, but your essay may do both.

Finally, Williams suggests that it’s sometimes appropriate to end a persuasive essay with an anecdote, illustrative fact, or key quote that emphasizes the significance of the argument. We can see a good example of this in Carr’s article, “ Is Google Making Us Stupid? ” Here are the introduction and conclusion, side-by-side:

[Introduction]  “Dave, stop. Stop, will you? Stop, Dave. Will you stop, Dave?” So the supercomputer HAL pleads with the implacable astronaut Dave Bowman in a famous and weirdly poignant scene toward the end of Stanley Kubrick’s 2001: A Space Odyssey . Bowman, having nearly been sent to a deep-space death by the malfunctioning machine, is calmly, coldly disconnecting the memory circuits that control its artificial “ brain. “Dave, my mind is going,” HAL says, forlornly. “I can feel it. I can feel it.”

I can feel it, too. Over the past few years I’ve had an uncomfortable sense that someone, or something, has been tinkering with my brain, remapping the neural circuitry, reprogramming the memory. …

[Conclusion] I’m haunted by that scene in 2001 . What makes it so poignant, and so weird, is the computer’s emotional response to the disassembly of its mind: its despair as one circuit after another goes dark, its childlike pleading with the astronaut—“I can feel it. I can feel it. I’m afraid”—and its final reversion to what can only be called a state of innocence. HAL’s outpouring of feeling contrasts with the emotionlessness that characterizes the human figures in the film, who go about their business with an almost robotic efficiency. Their thoughts and actions feel scripted, as if they’re following the steps of an algorithm. In the world of 2001 , people have become so machinelike that the most human character turns out to be a machine. That’s the essence of Kubrick’s dark prophecy: as we come to rely on computers to mediate our understanding of the world, it is our own intelligence that flattens into artificial intelligence.

Instead of merely rehashing all of the article’s main points, Carr returns to the same movie scene from 2001  that he opened with. The final lines interpret the scene according to the argument he just dedicated the entire essay to presenting.

The entire essay should use rhetorical appeals strategically

The chapter “ Persuasive Appeals ” introduces students to logos, pathos, ethos, and kairos. Becoming familiar with each of those persuasive appeals can add much to an essay. It also reinforces the idea that writing argumentative essays is not a straightforward process of jotting down proofs. It’s not a computer algorithm.

• Logos (appeals to evidence and reasoning) is the foundational appeal of an argument essay. Clearly identifying the claim, then supporting that claim with reasoning and evidence will appeal to the reader’s logos demands. As the previous chapter on argumentation mentions, however, what constitutes solid evidence will vary depending on the audience. Make sure your evidence is indeed convincing to your intended reader.
• Pathos (appeals to emotion) are a crucial component and should permeate should every section of the essay. Personal anecdotes are an effective way to illustrate important ideas, and they connect with the reader at an emotional level. Personal examples also cultivate  voice .
• Ethos (appeals to character, image, and values) is essential to gaining the reader’s trust and assent. The tone of your essay (snarky, sincere, ironic, sarcastic, empathetic) is immensely important for its overall effect, and it helps build the reader’s image of you. A careful attention to high-quality research reinforces a sincere and empathetic tone. When supporting certain claims and sub-claims, it’s also important to identify implied beliefs (warrants) that your reader is most likely to agree with, and to undermine beliefs that might seem repugnant.
• Kairos (appeals to timeliness) impresses the reader with your attunement to the situation. This should be practiced especially in the introduction, but it can appear throughout the essay as you engage with research and other voices that have recently weighed in on the topic.

All of these appeals are already happening, whether or not they’re recognized. If they are missed, the audience will often use them against you, judging your essay as not being personable enough (pathos), or not in touch with commonly accepted values (ethos), or out of touch with what’s going on (kairos). These non-logical appeals aren’t irrational. They are crucial components to writing that matters.

Argument Outline Exercise

To get started on your argument essay, practice adopting from of the outlines from this Persuasive Essay Outline worksheet .

Write What Matters Copyright © 2020 by Joel Gladd is licensed under a Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License , except where otherwise noted.

Share This Book

What Is Persuasive Writing? (Complete Answer With Examples)

No matter what you do in life, you will probably find yourself needing to master persuasive writing.

What is persuasive writing?

Persuasive writing is a type of writing that is used to convince or persuade someone of something. It is often used in business and marketing contexts but can be used in any type of writing. Persuasive writing uses logical, emotional, and structural techniques to seek agreement and initiate change.

In this article, I will answer the most common questions related to “What is persuasive writing?”

What Is Persuasive Writing? (Detailed Answer)

Table of Contents

A more complete explanation of persuasive writing is that it is a type of writing that is used to try to change or influence the opinion of the reader.

It can be used in many different contexts, such as in business, politics, or marketing, but it can also be used in other types of writing, such as essays or articles.

These are the common characteristics of persuasive writing:

• Evidentiary support (facts, statistics, case studies, etc)
• Easy reading experience (transitions, word choice, etc)

In order to be persuasive, your writing must be well thought out, purposeful, and bookended with a strong introduction and conclusion.

Persuasive writing can be formal, informal, or even colloquial in style and tone.

As far as the point of view, you can use first-person, second-person, or third-person. No matter what point of view you use, keep the focus on the reader.

What Is the Purpose of Persuasive Writing?

The purpose of persuasive writing is to grab attention, compel readers to think differently, arouse emotions, challenge assumptions, facilitate agreement, change minds, and—ultimately—convince the reader to take a specific action.

For example, you can convince:

• Website visitors to sign up to your email newsletter
• Blog post readers to click on an affiliate link
• Your manager to allow you to work remotely
• Clients to buy your product or service
• A politician to fix a broken streetlight
• An artist to hire you as a ghostwriter for rappers
• A literary agent to represent your novel or book
• Your favorite writer to respond to your letter to an author
• Dissertation reviewers to give you higher marks
• Readers to positively comment on your Power Rangers Fan Fiction

3 Types of Persuasive Writing

The three major types of persuasive writing are ethos, pathos, and logos. In my opinion, the best persuasive writing includes all three.

Here are definitions and examples of all three types.

Ethos is the writer’s character or credibility.

In order to be persuasive, a writer must establish trust with the reader. One way to do this is by being transparent and honest about who you are and your credentials.

You can also build ethos by using credible sources, such as statistics, case studies, and expert opinions.

An example of ethos in persuasive writing is:

“As a lifelong resident of this community, I know the importance of keeping our streets clean. I urge you to vote in favor of the cleanup proposal.”

Pathos is the emotional appeal to the reader.

The persuasive writer must connect with the reader on an emotional level in order to convince others to agree with them.

You can use word choice, stories, and “emotional” language to trigger a guttural feeling response in readers.

Here is an example of pathos in persuasive writing:

“Please fix this streetlight. It’s been broken for weeks and it’s very unsafe. Our children play in this neighborhood and I’m worried about their safety.”

Logos is the logical appeal to the reader.

The persuasive writer must make a rational argument in order to be persuasive. You can use facts, statistics, and expert opinions to make your argument.

Here is an example of logos in persuasive writing:

“The national evidence shows that working remotely can increase productivity by up to 43%. My productivity is even higher at 47%. Please consider allowing me to work from home.”

13 Forms of Persuasive Writing

There are many forms of persuasive writing.

Here are 13 forms:

• Editorials —Opinion pieces that argue for or against a position.
• Letters to the Editor —Written responses to articles or editorials, often voicing an opinion.
• Print advertisements —Adversiting materials that try to sell a product or service.
• Sales letters —Written materials used to sell a product or service.
• Pamphlets —Flyers or brochures that promote a product, service, or cause.
• Songs —Emotional music-based lyrics to inspire unity and action.
• Social media postings —Tweets, posts, and pins that try to create agreement.
• Speeches —Presentations given before an audience in order to persuade them of an idea or course of action.
• Treatments —Proposals made to individuals or groups in order to influence them.
• Websites —Pages or sites that attempt to persuade the reader to take a desired action.
• Poems —Verses that try to convince the reader to believe in a certain idea or course of action.
• Email marketing —Messages that try to convince the recipient to buy a product or service.
• Personal essays —Narratives that argue for or against a position.

Related: Best AI Essay Writer (Tested & Solved)

What Is Persuasive Writing? (Examples)

One of the best ways to learn persuasive writing is to read actual examples.

Here are 5 persuasive writing examples to answer that question.

Example 1: Editorial on Car Accidents at an Intersection

It’s time for the city to take action and stop car accidents from happening at an intersection. There have been too many accidents at this intersection, and it’s only a matter of time before someone is killed.

The city needs to install a traffic light or stop sign to help control the flow of traffic.

This will help to prevent accidents from happening, and it will also make the intersection safer for pedestrians.

Example #2: Essay on Changing the School Mascot

The school should consider changing its mascot. There are many reasons why this is a good idea.

One reason is that the current mascot is offensive to some people.

Another reason is that the mascot doesn’t reflect the diversity of the school’s student body.

Changing the mascot would be a symbolic gesture that shows that the school values all of its students.

Example 3: Letter to the Editor about Gun Control

I am writing in support of gun control. I believe that we need stricter gun laws to prevent mass shootings from happening.

The current laws are not working, and we need to take action to make our schools and public places safer.

I urge you to join me in supporting gun control. It’s time for us to take a stand and make our voices heard.

Example 4: Advertisement for a Credit Card

Looking for a credit card that offers low-interest rates and no annual fees? Look no further!

Our credit card has everything you need and more. It offers 0% APR on purchases and balance transfers, and no annual fees.

Apply today and get started on your path to financial freedom!

Example 5: Email to Teacher to Allow Extra Credit for Class Participation

Hi Mrs. Jones,

I was wondering if I could get some extra credit for class participation. I have been trying to participate more in class, and I think it has improved my grades and helped the entire class feel more motivated.

Is there any way that I could get an extra point or two for my participation grade?

Thank you for your time and consideration!

What Is Persuasive Writing? (Famous Examples)

Here are a few famous examples of persuasive writing:

• Letter from Birmingham Jail by Martin Luther King Jr.
• Tilbury Speech by Queen Elizabeth I
• Common Sense by Thomas Paine
• Ain’t I A Woman by Sojourner Truth
• Declaration of Rights of the Women of the United States by Susan B. Anthony

What Is Persuasive Writing? (The Parts)

Persuasive writing is made up of several parts. To truly answer the question, “What is persuasive writing?” it’s helpful to understand these various parts.

Let’s explore the following four persuasive writing terms:

• Counterargument
• Call to action

What Is a Hook in Persuasive Writing?

A hook in persuasive writing is a technique that writers use to capture the reader’s attention. It’s a way to get the reader interested in what you have to say.

There are many different types of hooks, but some of the most common include:

Here is a good example of a hook in persuasive writing:

“Birth control is not about birth, it’s about control.”—Anonymous

This quotation is a good hook because it is provocative and makes the reader think. It gets them interested in the topic of birth control and makes them want to read more.

What Is a Claim in Persuasive Writing?

A claim in persuasive writing is a statement that you make to support your argument. It is your position on the topic that you are discussing.

Your claim should be clear, concise, and easy to understand. You should also be able to back it up with evidence.

Here is an example of a claim:

“Donating to Clean Water International will save thousands of innocent lives.”

What Is a Counterargument in Persuasive Writing?

A counterargument in persuasive writing is a statement that opposes your position.

It is an argument that the other person could make against you.

You should be prepared to address any counterarguments that the other person might raise. This will help you to strengthen your argument and convince the other person of your position.

Here is an example of a counterargument:

“Donating to Clean Water International is not a sustainable solution.”

What Is a Call to Action in Persuasive Writing?

A call to action is a request that the reader takes some specific action. It is a plea for the reader to help you achieve your goal.

Your call to action should be clear, specific, and actionable. You should also make it easy for the reader to take action.

Here is an example of a call to action:

“Please donate to Clean Water International today to help save thousands of lives tomorrow.”

Persuasive Writing Techniques & Tips

When writing to change hearts and minds, there are techniques and tips you can use to maximize your results.

Apply these proven persuasive writing techniques:

• Reframing —Presenting the issue in a different light.
• Framing —Using specific language to create a particular impression.
• Bandwagoning —Emphasizing that many people support your position.
• Pathos, Logos, & Ethos —Appealing to the reader’s emotions, logic, and association with authority.
• Figurative language —using creative language to make your argument more impactful (stories, analogies, similies, etc).
• Repetition —Using the same words or phrases to convince the reader. Repeating your claim.
• Language patterns —The artful use of phrases to subtely shift a reader’s thinking.
• Rhetorical questions —Asking the reader a question that forces them to think about the issue.
• Speak directly to the reader —Making a direct appeal to the reader.

When using these techniques, it’s important to be aware of your readers and their interests.

Tailor your message to match their needs, hopes, fears, and belief systems.

What Is a Persuassive Writing Map?

A persuasive writing map is a way to structure and organize your argument.

Here is a persuasive writing map that works well for me:

• Start with a strong and clear claim.
• State your reasons for supporting that claim.
• Include supportive evidence.
• Sprinkle in persuassive techniques.
• Address any counterarguments that the other person might raise.
• Finish with a short and simple call to action.

Using a persuasive writing map can help you stay on track and make sure that your argument is clear and easy to follow.

It can also help you to be more persuasive by addressing the other person’s interests and concerns in the most compelling way.

A persuasive writing map is also known as a persuasive writing outline.

How Is Persuasive Writing Different than Other Forms of Writing?

Persuasive writing is easy to confuse with different types of writing.

Many people ask me how persuasive writing is different from:

• Argumentative writing
• Expository writing
• Informational writing

Persuasive Writing vs. Argumentative Writing

Argumentative writing is a type of persuasive writing. It is a more formal type of writing that mainly uses evidence to support your position.

The big difference is that argumentative writing is based more on logic and reason.

Persuasive writing usually relies heavily on emotion-laden opinions.

Expository Writing vs. Persuasive Writing

Expository writing is a type of informative writing.

It is a less formal type of writing that explains a topic or idea.

The main difference between expository writing and persuasive writing is that persuasive writing attempts to convince the reader to take a specific action.

Informational Writing vs. Persuasive Writing

Informational writing is a type of non-fiction writing. It is a formal type of writing that provides information about a topic or idea.

Persuasive writing might inform but its main goal is to change thinking, feeling, and behavior.

Persuasive Writing vs. Narrative Writing

Narrative writing is a type of creative writing.

It tells a story and uses the writer’s own experiences to support the story.

The main difference between persuasive writing and narrative writing is that persuasive writing is non-fiction and uses evidence to support the argument, while narrative writing is fiction and does not have to be true.

However, narrative writing can include elements of persuasive writing.

Persuasive Writing vs. Technical Writing

Technical writing is a type of informative writing. It is a formal type of writing that provides information about a technical topic or idea.

Both types of writing are nonfiction.

One major difference is that technical writing is usually written for people who are already familiar with the general topic, while persuasive writing might be written for people who are not as familiar with the topic.

Technical writing also includes step-by-step guides on how to perform a specific task.

What Is Persuasive Writing for Kids?

Many kids start to learn persuasive writing in first or second grade.

As kids get older, their teachers give them more challenging persuasive writing assignments.

In high school and college, students often write persuasive essays, speeches, and arguments.

Here is a short video that goes over persuasive writing for kids:

What Is a Persuasive Writing Anchor Chart?

A persuasive writing anchor chart is a visual tool that helps younger students learn and remember the key elements of persuasive writing.

It typically includes:

• The 5 W’s (who, what, when, where, why)
• The 3 C’s (claim, clear evidence, clever reasoning)
• How to Appeal to Emotions
• How to Appeal to Logic
• How to use Persuassive Devices

A persuasive writing anchor chart might also give students sentence starters to help jog their creativity.

It serves as a kind of “Mad Lib” or “fill in the blank” template for students.

Why Is Persuasive Writing Important?

Persuasive writing is important because it can be used in so many different contexts.

It’s a great way to get your point of view across or to convince someone to do something. Additionally, persuasive writing is an essential skill for business and marketing.

If you know how to write persuasively, you can write better resumes and cover letters.

That can get you a better job— with more pay.

If you sell anything (and, let’s be honest, we ALL sell something), you can attract more clients. You can also convert more clients into customers.

In school, you can get better grades. As an employee, you can foster better teamwork and move people to action.

Persuasive writing can also convince funders to give money to worthwhile causes, such as feeding children or bringing clean water to people in need.

In short, persuasive writing can make the world a better place for all of us to live.

Can You Use Persuasive Writing in Any Type of Writing?

Yes, persuasive writing can be used in any type of writing. However, it is often most effective when it is used in business or marketing contexts, where the goal is to change or influence the opinion of the reader.

You can apply persuasive writing tips and techniques to:

• School assignments (reports, essays)
• Nonfiction books
• Grant proposals
• Reviews (movies, books, products, etc)
• Blog posts and articles
• Love letters
• Writing a Dungeons and Dragons book
• Internal newsletter
• Affiliate marketing
• And much more!

What Are Some Tips for Writing Persuasively?

Here are some good tips for writing persuasively:

• Know your audience : In order to be persuasive, you must understand who you are trying to persuade.
• Start with a strong claim: In order to be persuasive, you must make a strong argument that is not easily deconstructed or debunked.
• Support your claim with evidence : This is where the rubber meets the road. You must back up your argument with facts, data, and expert testimony (if applicable).
• Use deep reasoning to explain the evidence: Once you have presented your evidence, you must then explain why it supports your argument.
• Make an emotional appeal: People are often persuaded more by emotion than logic. You can use powerful words and images to create an emotional response in your reader.
• Be succinct: Don’t ramble on and on. Get to the point and make your argument understandable by everyone.

Persuasive Writing Topics

There are an almost unlimited number of persuasive writing topics. Below you’ll find a few ideas to spark your own creativity.

Here is a list of possible persuasive writing topics to consider:

• Education: Should college be free?
• Dating: Is it bad to give up on dating and relationship?
• Prosperity: How to achieve financial prosperity
• Politics: Is it time for a new political party?
• Lifestyle: Veganism – pros and cons
• Environment: Should we all become vegetarians?
• Morality: Abortion – is it right or wrong?
• Art: Books are better than TV
• Texting: Do guys like good morning texts?
• Science: Is cloning moral?
• Technology: AI will one day take over the world
• Food: Is our food killing us?
• Energy: Should we all live off grid?
• Health: Is organic food better for you?
• Pets: Should exotic animals be kept as pets?
• Transport: The rise of the electric car
• Religion: Is there a God?
• Parenting: Raising a child in the internet age
• Gaming: Can a DM cheat at D&D?

Best Persuassive Writing Tools and Resources

I’ve been writing persuasively for over 20 years.

Here are my favorite persuasive writing tools and resources:

If you only try one tool, I highly recommend Jasper AI (formally known as Jarvis and Conversion.ai).

I use Jasper every day to automatically generate thousands of original words for persuasive writing, blog posts, contracts, and more.

Final Thoughts: What Is Persuasive Writing?

The next step in learning persuasive writing is lots of practice. You’ll get better the more you do it.

There are a ton of helpful articles on this site about how to write better.

Here are a few related posts hand-selected for you:

• How To Write An Editorial (Your Expert Cheat Sheet)
• How to Write an Ode (Step-by-Step with Examples)
• Time Skips in Writing: 27 Answers You Need To Know

Reading Rockets Hamilton University

Persuasive Essay Writing

How to Write a Persuasive Essay: A Step-by-Step Guide

13 min read

Published on: Jan 3, 2023

Last updated on: Jan 29, 2024

People also read

Easy and Unique Persuasive Essay Topics with Tips

The Basics of Crafting an Outstanding Persuasive Essay Outline

Ace Your Next Essay With These Persuasive Essay Examples!

Persuasive Essay About Gun Control - Best Examples for Students

Top Examples of Persuasive Essay about Covid-19

Learn How To Write An Impressive Persuasive Essay About Business

Learn How to Craft a Compelling Persuasive Essay About Abortion With Examples!

Make Your Point: Tips and Examples for Writing a Persuasive Essay About Online Education

Learn How To Craft a Powerful Persuasive Essay About Bullying

Craft an Engaging Persuasive Essay About Smoking: Examples & Tips

Learn How to Write a Persuasive Essay About Social Media With Examples

Craft an Effective Argument: Examples of Persuasive Essay About Death Penalty

Share this article

It's the night before the essay is due, and you haven't even started. Your mind is blank, and you have no idea what words will persuade your teacher. 

The good news is that some tips and tricks can make the process of writing a persuasive essay much easier.

In this blog, we'll break down the components of a persuasive essay and provide helpful tips and examples along the way. By the end, you should have all the guidelines to create a winning essay that will persuade your readers to see things your way.

Let's take a closer look at all these steps.

On This Page On This Page -->

What is a Persuasive Essay?

A persuasive essay presents logical arguments with emotional appeal.

Typically, persuasive essays begin with a question that the writer spends the essay arguing in favor of or opposition to. 

For example: should kids be allowed to play video games on weekdays? 

The writer would then spend the rest of the essay backing up their claim with reasons and evidence. 

Persuasive essays often include counterarguments. These arguments oppose the writer's position. 

By including counterarguments, persuasive essays become more interesting. They also force the writer to think critically about their position.

For example, an opponent of the previous argument might say that playing video games leads to poor grades. 

The original writer could deny this claim by pointing to studies that show no correlation between bad grades and playing video games.

The best persuasive essays are well-researched and use data to support their claims. 

However, persuasive essays are not just about logic. They also need to include emotional appeal. 

After all, people are more likely to be persuaded by an argument that speaks to their feelings. 

Elements of a Persuasive Essay 

When a persuasive essay is a task, you must keep these three greek terms in mind. They are:

• Ethos (appeal to ethics) 
• Pathos (appeal to emotion)
• Logos (appeal to logic)

A good essay will use all of these elements to convince the reader that the argument presented is valid. 

Let's take a closer look at each one.

Ethos - the Credibility Element 

The persuasive power of ethos lies in the character or credibility of the person making the argument. 

For an argument to be persuasive, the person presenting it must be someone that the audience trusts. 

This could be because they are an expert on the subject or because they have first-hand experience with it. Either way, ethos establishes the speaker's credibility and makes the audience more likely to trust what they have to say.

Pathos -the Emotional Element 

While ethos deals with the character of the person making the argument, pathos has to do with the audience's emotions. A persuasive argument will tap into the audience's emotions and use them to sway their opinion.

This could be done through stories or anecdotes that evoke an emotional response or by using language that stirs certain feelings.

Logos - the Logical Element 

The final element of persuasion is logos, which appeals to logic. A persuasive argument will use sound reasoning and evidence to convince the audience that it is valid. This could be done through data or using persuasive techniques like cause and effect.

Using all these elements of a persuasive essay can make your argument much more effective. 

How To Write a Persuasive Essay

Writing persuasive essays can be challenging, but they don't have to be.

With the following simple steps, you can quickly turn an ordinary essay into one that will make a lasting impression. 

Tough Essay Due? Hire a Writer!

How To Start a Persuasive Essay 

Here is a complete guide on how to start a persuasive essay. Follow them to compose a perfect essay every time. 

Brainstorm All Possible Angles 

The first step in writing a persuasive essay is brainstorming. You need to develop an angle for your essay that will make it unique and interesting. 

For example, let's say you're writing about the death penalty. A lot has been said on this topic, so it might be hard to find an angle that hasn't been covered already. 

But if you think about it, there are many different ways to approach the issue. 

Maybe you could write about the personal experiences of someone affected by the death penalty. Or maybe you could write about the economic costs of the death penalty. 

There are many possibilities here - it's all about thinking creatively.

Select Your Topic

Once you've brainstormed a few ideas, it's time to choose your topic. Pick the angle you think will most effectively persuade your reader. 

Once you've chosen your topic, it's time to research. Use statistics, expert opinions, and real-life examples to support your position. 

Choose Your Side

Now that you've researched, it's time to take a side in the debate. Remember, you must take a strong stance on one side of the issue. 

After deciding your stance, research and support it with evidence.

Appeal to Human Emotions 

One of the most effective ways to persuade someone is by appealing to their emotions. 

After all, we're not robots - we're human beings and always make decisions based on our feelings. 

Make your reader feel something, whether it's anger, sadness, empathy, or even amusement. You'll be well on convincing them of your point of view. 

Anticipate Possible Objections.

Of course, not everyone will agree, and that's okay! 

The important thing is that you anticipate some of those objections and address them head-on in your essay. 

This shows that you take your reader's objections seriously and are confident in your position. 

Organize Your Evidence 

Once you have all of your evidence collected, it's time to start organizing it into an outline for your essay.  

Organizing your essay is a key step in the writing process. It helps you keep track of all the evidence you've gathered and structure your argument in an organized way.

What Are The Steps To Write Your Persuasive Essay?

Now that you have your topic essay outline, it's time to move on to the actual writing.

Here are the steps you need to take:

Step 1: Create a Compelling Introduction

You want to hook your readers with a great opening for your persuasive essay, so they'll want to keep reading.

Here are 3 tips for writing an attention-grabbing introduction for your next essay.

• Use a strong hook statement

Your hook statement should immediately draw the reader in and make them want to learn more. 

A good hook statement will vary depending on whether you're writing for an academic or more casual audience. 

Still, some good options include a quote, an interesting statistic, or a rhetorical question.

• Make sure your thesis statement is clear and concise

Your thesis statement is the main argument of your essay, so it needs to be stated clearly and concisely in your introduction.

 A good thesis statement will be specific and limit the scope of your argument so that it can be fully addressed in the body of your paper.

• Use a transition

Transitions are important in writing for academic and non-academic audiences because they help guide the reader through your argument. 

A good transition will introduce the main point of your next paragraph while still maintaining the connection to the previous one.

Step 2: Write The Body Paragraphs

Here is a formula for structuring your body paragraphs in a persuasive essay. 

This formula will ensure that each body paragraph is packed with evidence and examples while still being concise and easy to read.

• The Topic Sentence

Every body paragraph should start with a topic sentence. A topic sentence is a key sentence that sums up the paragraph's main point. 

It should be clear, concise, and direct. 

For example, if you were writing a paragraph about the importance of exercise, your topic sentence might be this:

"Regular exercise is essential for good physical and mental health."

See how that sentence gives a clear overview of what the rest of the paragraph will be about.

• Relevant Supporting Sentences

Once your topic sentence is down, it's time to fill the rest of the paragraph with relevant supporting sentences. 

These sentences should provide evidence to support the claims made in the topic sentence. 

For the exercise example, we might use sentences like this:

"Exercise has been shown to improve heart health, reduce stress levels, and boost brain power."

"A sedentary lifestyle has been linked to an increased risk of obesity, heart disease, and type II diabetes."

See how each sentence ties back to the paragraph's main point. That's what you want your supporting sentences to do.

• Closing Sentence

Last but not least, every body paragraph should end with a closing (or transition) sentence. This sentence should briefly summarize the main points of the paragraph and introduce the next point that will be discussed in the following paragraph. 

For the exercise example, the closing sentence might look like this:

"So, as you can see, there are many compelling reasons to make exercise a regular part of your routine."

How to End a Persuasive Essay

The end of your essay is just as important as the introduction. You must leave your readers with a lasting impression and ensure your argument convinces them. 

To do this, you'll want to craft a persuasive conclusion that ties together all the points you have made in the essay.

Here is a video explaining the body paragraphs in a persuasive essay. Check it out for more information. 

Step 1: Write a Persuasive Conclusion

Here are a few tips to help make sure your persuasive essay conclusion is as effective and persuasive as possible. 

• Restate Your Thesis

Begin your essay conclusion by restating the thesis statement you began within your introduction. Doing so will remind readers of what you set out to prove and provide a sense of closure.

• Summarize Your Arguments

 You can also use your conclusion to summarize the main points of your argument. This will help readers recall the evidence you presented and reinforce why it supports your thesis. 

• Offer a Call to Action

Lastly, don't forget to include a call to action in your essay conclusion. This can be anything from a persuasive plea to a persuasive suggestion. 

Step 2:  Polish Up Your Essay

After you’re done with the essay, take a few minutes to read through it. Ensure that your persuasive points and evidence are clear, concise, and persuasive. 

Also, double-check for grammar, spelling, and punctuation mistakes. Ensure that all of your persuasive points are properly explained and make sense to the reader. 

If you’re not confident in your persuasive writing skills, you can enlist a friend or family member to read through it and provide feedback.

You can follow a proofreading checklist after completing your essay to ensure you are on track.

By following these steps, you’ll end up with a persuasive essay that will impress anyone who reads it!

Format Of A Persuasive Essay 

Once you have your persuasive essay topic, it's time to craft an essay structure. Crafting the perfect persuasive essay format is essential for ensuring your paper has maximum persuasive power.

Here are some tips for formatting an effective persuasive essay.

• Increase the Readability of Your Text 

Ensure that you have adhered to all the paragraphing requirements of your instructor. 

Double-check that your margins are set properly. A margin of 1 inch (2.5 cm) on all sides is the standard for most written documents.

This makes it easier for readers to focus and extract important information quickly.

• Use Easy-to-Read Font

Choose a font that is easy to read and professional. Stay away from script fonts or anything too fancy or difficult to read. Stick with basic fonts like Times New Roman, Arial, and Calibri.

• Keep a Defined Alignment

Align your persuasive essay to the left margin. This makes it easier for readers to follow along with your argument without having to do too much extra scrolling. 

By following these simple tips, you'll be able to craft the perfect persuasive essay format.

Persuasive Essay Examples

Here are some examples of persuasive essays that can help you get the gist of essay writing.

Persuasive essay on the preservation of nature

Persuasive essay examples pdf

Example of a persuasive essay about covid-19

Check out some more  persuasive essay examples  here for more inspiration.

Good Persuasive Essay Topics

The right persuasive essay topics can make or break your essay. Here are a few examples of persuasive essay topics that can help you. 

• Should the government increase taxes on sugary foods to reduce obesity? 
• Do standardized tests accurately measure student intelligence and aptitude? 
• Should studying a foreign language be mandatory in schools? 
• Should all high school students complete community service hours before graduating? 
• Are video games affecting the concentration and cognitive development of children? 
• Should genetically modified foods be labeled as such in stores? 
• Are the current copyright laws protecting artists and content creators enough? 
• Should college tuition be reduced for all students? 
• Is the use of animals in medical research ethical? 
• Should the use of drones be regulated by the government? 
• Should college athletes receive payment for their performance? 
• Should students be allowed to have cell phones in school? 
• Is drug testing in schools an effective way to prevent substance abuse? 
• Does social media promote a healthy lifestyle or contribute to cyber bullying? 
• Should the voting age be lowered to 16? 

If you’re stuck with choosing topics, these are great  persuasive essay topics  to get you started! 

Pick one of these and craft an essay that will leave your readers thinking. 

Tips to Write a Compelling Persuasive Essay

Here are a few tips and tricks to help you make a lasting impression on your reader:

Pick A Topic You're Passionate About

First, you need to choose a topic you're passionate about. It will be easier to write about the topic if you care about the essay. 

This will make it easier to develop persuasive arguments, and you'll be more motivated to do research.

Research Your Topic Thoroughly

After picking a persuasive essay topic, you need thorough research. This will help you gain a better understanding of the issue, which in turn will make your essay stronger. This will also ensure that you fully grasp all counterarguments on your topic.

Know Your Audience

Knowing your audience before writing is important. Are you writing to your classmates? Your teacher? The general public? Once you know your audience, you can tailor your argument to them. 

Knowing your audience will help determine the tone and approach of your essay.

Hook The Reader's Attention

The first few sentences of your essay are crucial - they must grab the reader's attention and make them want to keep reading. 

One way to do this is by starting with a shocking statistic or an interesting story. The reader will be instantly hooked and will be enticed to read more.

Research Both Sides 

A good persuasive essay will consider both sides of an issue and present a well-rounded view. This means researching both sides of the argument before taking a stance. 

Make sure to consider all the evidence before making up your mind - otherwise, your argument won't be as strong as it could be.

Ask Rhetorical Questions

Rhetorical questions are not meant to be answered but rather to make the reader think about the issue. 

For example, "How can we expect our children to succeed in school if they don't have enough resources?" 

Questions like this can help engage readers and get them thinking about solutions rather than just complaining about problems.

Emphasize Your Point

It's important to reiterate your main points throughout the essay so that readers don't forget what they are supposed to argue for or against by the time they reach the end of the paper.

Persuasive essays can be difficult to write, but following simple tips can help make the process easier. 

In this blog, we've outlined the components of a persuasive essay and provided some tips on how to write one. We also shared examples of persuasive essays that scored high marks on standardized tests. 

If you are looking for an essay writing service , look no further than CollegeEssay.org! Our experienced essay writer can provide the assistance you need to produce an essay that meets the highest standards.

Let our persuasive essay writer handle the hard work and get you started on your path to success.

Try our AI essay writer and elevate your writing to new heights today!

Frequently Asked Questions About Persuasive Essays

How long should a persuasive essay be.

Generally speaking, persuasive essays should be between 500-750 words. However, the length of your essay will depend on the instructions given by your teacher or professor.

What Techniques Are Used In Persuasive Essays?

Persuasive techniques include facts and statistics, emotion and logic, personal stories, analogies and metaphors, pathos, ethos, and logos.

How Do I Make My Persuasive Essay More Convincing?

To make your essay more convincing, cite reliable sources, use persuasive language, and provide strong evidence and arguments.

How Is Persuasive Writing Different From Argumentative Writing?

The main difference between persuasive and argumentative writing is that persuasive writing seeks to convince or persuade the reader. On the other hand, argumentative writing seeks to debate an issue.

Cathy A. (Literature, Marketing)

For more than five years now, Cathy has been one of our most hardworking authors on the platform. With a Masters degree in mass communication, she knows the ins and outs of professional writing. Clients often leave her glowing reviews for being an amazing writer who takes her work very seriously.

Paper Due? Why Suffer? That’s our Job!

Keep reading

• Privacy Policy
• Cookies Policy
• Terms of Use
• Refunds & Cancellations
• Our Writers
• Success Stories
• Our Guarantees
• Affiliate Program
• Referral Program
• AI Essay Writer

Disclaimer: All client orders are completed by our team of highly qualified human writers. The essays and papers provided by us are not to be used for submission but rather as learning models only.

Persuasive Essay | Meaning, Examples, Format, Structure and Elements

Persuasive Essay: There are many essay types, and one has to understand and learn the distinction between them. One of them is a Persuasive essay in which the writer’s task is to persuade the reader to approve a particular message or make certain decisions. It needs proper study and a solid understanding of both sides of the case.

It is essential to know about the format and other necessary tips for writing an effective persuasive essay. Now the point is to know about the Persuasive essay format. This article is penned down consisting of all the vital information about Persuasive essay examples, How to write a persuasive essay, Persuasive essay structures, etc. Read on to understand better about persuasive essays.

Persuasive Essay Format

• What do you mean by Persuasive essay?

How to write a persuasive essay?

Persuasive essay examples, how to structure a persuasive essay.

• Persuasive essay format.

Elements of Persuasive essays

How to write an introduction in a persuasive essay.

• Persuasive essay body paragraphs.
• How to write a conclusion in a persuasive essay?

What is a Persuasive essay?

In a persuasive essay, reason and arguments are used to persuade readers of the writer’s point of view, so strong evidence for arguments, such as research, asserting facts, etc., is essential. One must provide detailed arguments supporting them by satisfying evidence and reasonable explanations. A persuasive essay uses explanation to imply that certain beliefs are more acceptable than others in writing. Such an essay is aimed at convincing the readers to approve a particular opinion or act in a specific way. A persuasive essay must be established on sound thinking and must include valid evidence supporting the statement.

Things to learn to write a persuasive essay.

To take a standpoint

The decision regarding an issue, which side they are willing to take should be decided clearly, and the resolutions they want to suggest. One should be alert of any biases they might have that could reflect the argument.

To know the viewers

Viewers’ approval of the writer’s position should be determined. While writing, one must know both sides of the matter to contend to a point successfully.

You should thoroughly research the topic

The main thing about a persuasive essay is to provide comprehensive and unmistakable evidence, which is possible by library-based research.

The structure of the essay should be thought of

Evidence that needs to be included should be presented in a logical order.

Hard facts should support the argument

It can be gathered from study or personal knowledge. It would help if you used supportable statistics. It is crucial to back up the argument with data, and for further strengthening the argument in a persuasive essay, One should use one or two direct quotes from experts on the issue.

You should provide meaningful instances to modify and illustrate the argument.

In a persuasive or argument essay, the writer persuades the reader of their viewpoint on a particular issue; the writer argues why their perspective is proper and why the contrasting statement is false .

Topics like City life are better than country life; Teens should be competent to start driving at 14 rather than 16, School testing is not beneficial, High-speed internet access should be regulated as a social utility,y, etc. are some examples of Persuasive essay.

This is how a typical persuasive essay looks like:

• Introduction: This is where the topic is introduced. Why the content is so important and why a decision needs to be prepared should be discussed.
• Thesis : The writer should explain their point of view after researching thoroughly before writing to assure that the writing is well informed and helpful to the reader.
• Main body : Each paragraph should be used to bring up a new point to support the thesis. Once done with introducing the point, You should use evidence to confirm the saying.

The paragraphs should be linked jointly so that they flow appropriately and create a larger image.

• Conclusion: All the main arguments need to be tied together, and one should bring up nothing new here.

The structure is shown underneath:

Introduction

• Hook – engaging first sentence
• Background data – context to the argument needs to be provided, and you should notify the reader of the content.
• Definitions – any phrases that the reader might find different are to be defined.
• Thesis – an open, straightforward declaration of the main statement. This thesis will guide the rest of your essay, giving the reader a common idea of the way the argument will follow.

Each Body Paragraph

Only one point to be used to assist your thesis per paragraph

Topic sentence

• Reveals the primary indication of the passage
• Links back to support the thesis
• Evidence – information from a credible outside source and not their own opinion that favors the main idea of the paragraph
• Analysis – how the evidence supports the argument should be shown
• Tie up the essay – briefly sum up the central point
• Establish significance
• Bonus: give the reader energy to think

Persuasive essay format

Persuasive essay writing is about analysis, analyzing, and critical reasoning. One needs to know the audience inside out to put the best arguments to persuade them of their point. With that in mind, we need to format an essay so that it would enclose the issue logically and invariably.

One should start a persuasive essay with a topic and a belief they are going to prove. Then it would help if you wrote a few paragraphs, each with a new declaration and proof to assist in one’s point of view. Also, paragraphs can have counterarguments from opponents explaining his or their point of disagreeing with them.

Finally, in the end, formatting the essay with a conclusion is essential where the thesis again should be restated, summarizing all the opinions.

Parts of a Persuasive essay

Thesis statement.

The argument or the point writer is trying to make is found in the introductory paragraph.

This paragraph describes the situation, why the reader should look into it, and the point they are aiming to make.

Counterargument

The argument oppositions of readers’ viewpoints should be included beforehand in the essay. It is significant to illustrate the argument honestly, and the counterargument needs to be denied with writers’ main objections.

Body paragraphs

These paragraphs support the thesis with proof from reliable sources.

This paragraph completes the essay by clarifying the significant points and repeating the thesis.

Firstly we need to know the basic standards of persuasive writing and know the five factors of persuasion. The right combination of subjective and reasonable elements helps make the essay persuasive.

The basic precepts of persuasive writing, illustrated by Aristotle many years where he called them factors of rhetoric and were three:

• Ethos appeals to writers’ credibility and identity in which powerful resources are used to prove statements.
• Pathos focus on a reader’s morals, importance, and notions.
• Logos that is appealing to reason uses reasoning and proof to convince others to agree with us.

The introductory paragraph describes the problems and reasons the reader should care about, and the fact he is she intends to make is the thesis statement. The most significant portion of the introduction is the understandable and concise thesis statements, which define the writer’s viewpoint and the way that the whole essay is getting on.

The introduction needs to be exciting to encourage the reader to read the entire essay.

Persuasive essay body paragraphs

The essay’s body is the mainstream of the essay. The actual persuasion is done here to convince people to believe in the thesis. It should have at least three paragraphs, consisting of evidence for all statements.

You should include each separate point about the thesis in a body paragraph of its own, and any evidence, instances, stats, or quotations confirming that point are involved in the same paragraph. You should take the required time to examine each point and its meaning thoroughly.

Also, counteract the response of someone who might disagree with the thesis before they can make it. Realizing their arguments and agreeing on the point where necessary is a show of courage and belief on the writer’s part. On the other hand, failure to talk about an understandable opposing argument looks weak and incapable,

How to write conclusion for a persuasive essay?

In the conclusion of the essay, the reader should be at the point of concurring with the writer’s view. The conclusion is to strengthen what is already said. The conclusion should restate the thesis’s main points and explain their significance, then the writer’s main points.

It is essential to keep the data fresh in their minds. Knowing the format for writing has always been important. Understanding the elements of persuasive writing will help writers make the correct word choice to persuade the reader by statements that objective data can prove.

It should be written so that you can fulfill its purpose of convincing its readers towards certain opinions.

Leave a Comment Cancel reply

Save my name, email, and website in this browser for the next time I comment.

Have a language expert improve your writing

Run a free plagiarism check in 10 minutes, generate accurate citations for free.

• Knowledge Base
• How to write an argumentative essay | Examples & tips

How to Write an Argumentative Essay | Examples & Tips

Published on July 24, 2020 by Jack Caulfield . Revised on July 23, 2023.

An argumentative essay expresses an extended argument for a particular thesis statement . The author takes a clearly defined stance on their subject and builds up an evidence-based case for it.

Instantly correct all language mistakes in your text

Upload your document to correct all your mistakes in minutes

Table of contents

When do you write an argumentative essay, approaches to argumentative essays, introducing your argument, the body: developing your argument, concluding your argument, other interesting articles, frequently asked questions about argumentative essays.

You might be assigned an argumentative essay as a writing exercise in high school or in a composition class. The prompt will often ask you to argue for one of two positions, and may include terms like “argue” or “argument.” It will frequently take the form of a question.

The prompt may also be more open-ended in terms of the possible arguments you could make.

Argumentative writing at college level

At university, the vast majority of essays or papers you write will involve some form of argumentation. For example, both rhetorical analysis and literary analysis essays involve making arguments about texts.

In this context, you won’t necessarily be told to write an argumentative essay—but making an evidence-based argument is an essential goal of most academic writing, and this should be your default approach unless you’re told otherwise.

Examples of argumentative essay prompts

At a university level, all the prompts below imply an argumentative essay as the appropriate response.

Your research should lead you to develop a specific position on the topic. The essay then argues for that position and aims to convince the reader by presenting your evidence, evaluation and analysis.

• Don’t just list all the effects you can think of.
• Do develop a focused argument about the overall effect and why it matters, backed up by evidence from sources.
• Don’t just provide a selection of data on the measures’ effectiveness.
• Do build up your own argument about which kinds of measures have been most or least effective, and why.
• Don’t just analyze a random selection of doppelgänger characters.
• Do form an argument about specific texts, comparing and contrasting how they express their thematic concerns through doppelgänger characters.

Prevent plagiarism. Run a free check.

An argumentative essay should be objective in its approach; your arguments should rely on logic and evidence, not on exaggeration or appeals to emotion.

There are many possible approaches to argumentative essays, but there are two common models that can help you start outlining your arguments: The Toulmin model and the Rogerian model.

Toulmin arguments

The Toulmin model consists of four steps, which may be repeated as many times as necessary for the argument:

• Make a claim
• Provide the grounds (evidence) for the claim
• Explain the warrant (how the grounds support the claim)
• Discuss possible rebuttals to the claim, identifying the limits of the argument and showing that you have considered alternative perspectives

The Toulmin model is a common approach in academic essays. You don’t have to use these specific terms (grounds, warrants, rebuttals), but establishing a clear connection between your claims and the evidence supporting them is crucial in an argumentative essay.

Say you’re making an argument about the effectiveness of workplace anti-discrimination measures. You might:

• Claim that unconscious bias training does not have the desired results, and resources would be better spent on other approaches
• Cite data to support your claim
• Explain how the data indicates that the method is ineffective
• Anticipate objections to your claim based on other data, indicating whether these objections are valid, and if not, why not.

Rogerian arguments

The Rogerian model also consists of four steps you might repeat throughout your essay:

• Discuss what the opposing position gets right and why people might hold this position
• Highlight the problems with this position
• Present your own position , showing how it addresses these problems
• Suggest a possible compromise —what elements of your position would proponents of the opposing position benefit from adopting?

This model builds up a clear picture of both sides of an argument and seeks a compromise. It is particularly useful when people tend to disagree strongly on the issue discussed, allowing you to approach opposing arguments in good faith.

Say you want to argue that the internet has had a positive impact on education. You might:

• Acknowledge that students rely too much on websites like Wikipedia
• Argue that teachers view Wikipedia as more unreliable than it really is
• Suggest that Wikipedia’s system of citations can actually teach students about referencing
• Suggest critical engagement with Wikipedia as a possible assignment for teachers who are skeptical of its usefulness.

You don’t necessarily have to pick one of these models—you may even use elements of both in different parts of your essay—but it’s worth considering them if you struggle to structure your arguments.

Regardless of which approach you take, your essay should always be structured using an introduction , a body , and a conclusion .

Like other academic essays, an argumentative essay begins with an introduction . The introduction serves to capture the reader’s interest, provide background information, present your thesis statement , and (in longer essays) to summarize the structure of the body.

Hover over different parts of the example below to see how a typical introduction works.

The spread of the internet has had a world-changing effect, not least on the world of education. The use of the internet in academic contexts is on the rise, and its role in learning is hotly debated. For many teachers who did not grow up with this technology, its effects seem alarming and potentially harmful. This concern, while understandable, is misguided. The negatives of internet use are outweighed by its critical benefits for students and educators—as a uniquely comprehensive and accessible information source; a means of exposure to and engagement with different perspectives; and a highly flexible learning environment.

The body of an argumentative essay is where you develop your arguments in detail. Here you’ll present evidence, analysis, and reasoning to convince the reader that your thesis statement is true.

In the standard five-paragraph format for short essays, the body takes up three of your five paragraphs. In longer essays, it will be more paragraphs, and might be divided into sections with headings.

Each paragraph covers its own topic, introduced with a topic sentence . Each of these topics must contribute to your overall argument; don’t include irrelevant information.

This example paragraph takes a Rogerian approach: It first acknowledges the merits of the opposing position and then highlights problems with that position.

Hover over different parts of the example to see how a body paragraph is constructed.

A common frustration for teachers is students’ use of Wikipedia as a source in their writing. Its prevalence among students is not exaggerated; a survey found that the vast majority of the students surveyed used Wikipedia (Head & Eisenberg, 2010). An article in The Guardian stresses a common objection to its use: “a reliance on Wikipedia can discourage students from engaging with genuine academic writing” (Coomer, 2013). Teachers are clearly not mistaken in viewing Wikipedia usage as ubiquitous among their students; but the claim that it discourages engagement with academic sources requires further investigation. This point is treated as self-evident by many teachers, but Wikipedia itself explicitly encourages students to look into other sources. Its articles often provide references to academic publications and include warning notes where citations are missing; the site’s own guidelines for research make clear that it should be used as a starting point, emphasizing that users should always “read the references and check whether they really do support what the article says” (“Wikipedia:Researching with Wikipedia,” 2020). Indeed, for many students, Wikipedia is their first encounter with the concepts of citation and referencing. The use of Wikipedia therefore has a positive side that merits deeper consideration than it often receives.

Receive feedback on language, structure, and formatting

Professional editors proofread and edit your paper by focusing on:

• Academic style
• Vague sentences
• Style consistency

See an example

An argumentative essay ends with a conclusion that summarizes and reflects on the arguments made in the body.

No new arguments or evidence appear here, but in longer essays you may discuss the strengths and weaknesses of your argument and suggest topics for future research. In all conclusions, you should stress the relevance and importance of your argument.

Hover over the following example to see the typical elements of a conclusion.

The internet has had a major positive impact on the world of education; occasional pitfalls aside, its value is evident in numerous applications. The future of teaching lies in the possibilities the internet opens up for communication, research, and interactivity. As the popularity of distance learning shows, students value the flexibility and accessibility offered by digital education, and educators should fully embrace these advantages. The internet’s dangers, real and imaginary, have been documented exhaustively by skeptics, but the internet is here to stay; it is time to focus seriously on its potential for good.

If you want to know more about AI tools , college essays , or fallacies make sure to check out some of our other articles with explanations and examples or go directly to our tools!

• Ad hominem fallacy
• Post hoc fallacy
• Appeal to authority fallacy
• False cause fallacy
• Sunk cost fallacy

College essays

• Choosing Essay Topic
• Write a College Essay
• Write a Diversity Essay
• College Essay Format & Structure
• Comparing and Contrasting in an Essay

 (AI) Tools

• Grammar Checker
• Paraphrasing Tool
• Text Summarizer
• AI Detector
• Plagiarism Checker
• Citation Generator

An argumentative essay tends to be a longer essay involving independent research, and aims to make an original argument about a topic. Its thesis statement makes a contentious claim that must be supported in an objective, evidence-based way.

An expository essay also aims to be objective, but it doesn’t have to make an original argument. Rather, it aims to explain something (e.g., a process or idea) in a clear, concise way. Expository essays are often shorter assignments and rely less on research.

At college level, you must properly cite your sources in all essays , research papers , and other academic texts (except exams and in-class exercises).

Add a citation whenever you quote , paraphrase , or summarize information or ideas from a source. You should also give full source details in a bibliography or reference list at the end of your text.

The exact format of your citations depends on which citation style you are instructed to use. The most common styles are APA , MLA , and Chicago .

The majority of the essays written at university are some sort of argumentative essay . Unless otherwise specified, you can assume that the goal of any essay you’re asked to write is argumentative: To convince the reader of your position using evidence and reasoning.

In composition classes you might be given assignments that specifically test your ability to write an argumentative essay. Look out for prompts including instructions like “argue,” “assess,” or “discuss” to see if this is the goal.

Cite this Scribbr article

If you want to cite this source, you can copy and paste the citation or click the “Cite this Scribbr article” button to automatically add the citation to our free Citation Generator.

Caulfield, J. (2023, July 23). How to Write an Argumentative Essay | Examples & Tips. Scribbr. Retrieved April 2, 2024, from https://www.scribbr.com/academic-essay/argumentative-essay/

Is this article helpful?

Jack Caulfield

Other students also liked, how to write a thesis statement | 4 steps & examples, how to write topic sentences | 4 steps, examples & purpose, how to write an expository essay, what is your plagiarism score.

• More from M-W
• To save this word, you'll need to log in. Log In

Definition of persuasive

Examples of persuasive in a sentence.

These examples are programmatically compiled from various online sources to illustrate current usage of the word 'persuasive.' Any opinions expressed in the examples do not represent those of Merriam-Webster or its editors. Send us feedback about these examples.

Word History

15th century, in the meaning defined above

Dictionary Entries Near persuasive

persuasive definition

Cite this Entry

“Persuasive.” Merriam-Webster.com Dictionary , Merriam-Webster, https://www.merriam-webster.com/dictionary/persuasive. Accessed 2 Apr. 2024.

Kids Definition

Kids definition of persuasive, more from merriam-webster on persuasive.

Nglish: Translation of persuasive for Spanish Speakers

Britannica English: Translation of persuasive for Arabic Speakers

Subscribe to America's largest dictionary and get thousands more definitions and advanced search—ad free!

Can you solve 4 words at once?

Word of the day.

See Definitions and Examples »

Get Word of the Day daily email!

Popular in Grammar & Usage

The tangled history of 'it's' and 'its', more commonly misspelled words, why does english have so many silent letters, your vs. you're: how to use them correctly, every letter is silent, sometimes: a-z list of examples, popular in wordplay, the words of the week - mar. 29, 10 scrabble words without any vowels, 12 more bird names that sound like insults (and sometimes are), 8 uncommon words related to love, 9 superb owl words, games & quizzes.

How will you prove that the drafts are original and unique?

Customer Reviews

Can you write my essay fast?

Our company has been among the leaders for a long time, therefore, it modernizes its services every day. This applies to all points of cooperation, but we pay special attention to the speed of writing an essay.

Of course, our specialists who have extensive experience can write the text quickly without losing quality. The minimum lead time is three hours. During this time, the author will find the necessary information, competently divide the text into several parts so that it is easy to read and removes unnecessary things. We do not accept those customers who ask to do the work in half an hour or an hour just because we care about our reputation and clients, so we want your essay to be the best. Without the necessary preparation time, specialists will not be able to achieve an excellent result, and the user will remain dissatisfied. For the longest time, we write scientific papers that require exploratory research. This type of work takes up to fourteen days.

We will consider any offers from customers and advise the ideal option, with the help of which we will competently organize the work and get the final result even better than we expected.

Emery Evans

Experts to Provide You Writing Essays Service.

You can assign your order to:

• Basic writer. In this case, your paper will be completed by a standard author. It does not mean that your paper will be of poor quality. Before hiring each writer, we assess their writing skills, knowledge of the subjects, and referencing styles. Furthermore, no extra cost is required for hiring a basic writer.
• Advanced writer. If you choose this option, your order will be assigned to a proficient writer with a high satisfaction rate.
• TOP writer. If you want your order to be completed by one of the best writers from our essay writing service with superb feedback, choose this option.
• Your preferred writer. You can indicate a specific writer's ID if you have already received a paper from him/her and are satisfied with it. Also, our clients choose this option when they have a series of assignments and want every copy to be completed in one style.

These kinds of ‘my essay writing' require a strong stance to be taken upon and establish arguments that would be in favor of the position taken. Also, these arguments must be backed up and our writers know exactly how such writing can be efficiently pulled off.

Can I hire someone to write essay?

Student life is associated with great stress and nervous breakdowns, so young guys and girls urgently need outside help. There are sites that take all the responsibility for themselves. You can turn to such companies for help and they will do all the work while clients relax and enjoy a carefree life.

Take the choice of such sites very seriously, because now you can meet scammers and low-skilled workers.

On our website, polite managers will advise you on all the details of cooperation and sign an agreement so that you are confident in the agency. In this case, the user is the boss who hires the employee to delegate responsibilities and devote themselves to more important tasks. You can correct the work of the writer at all stages, observe that all special wishes are implemented and give advice. You pay for the work only if you liked the essay and passed the plagiarism check.

We will be happy to help you complete a task of any complexity and volume, we will listen to special requirements and make sure that you will be the best student in your group.

Advertisement

Read the Florida Supreme Court’s Ruling on the Abortion Ban

• Share full article

The Florida Supreme Court overturned decades of legal precedent in ruling that the State Constitution’s privacy protections do not extend to abortion, effectively allowing Florida to ban the procedure after six weeks of pregnancy.

A PDF version of this document with embedded text is available at the link below:

Download the original document (pdf)

Supreme Court of Florida No. SC2022-1050 PLANNED PARENTHOOD OF SOUTHWEST AND CENTRAL FLORIDA, et al., Petitioners, VS. STATE OF FLORIDA, et al., Respondents. No. SC2022-1127 PLANNED PARENTHOOD OF SOUTHWEST AND CENTRAL FLORIDA, et al., Petitioners, VS. STATE OF FLORIDA, et al., Respondents. April 1, 2024 GROSSHANS, J. The Florida Constitution guarantees "the right to be let alone and free from governmental intrusion into . . . private life.” Art. I,

§ 23, Fla. Const. In this case, we are asked to determine if there is a conflict between the rights secured by this provision and a recently amended statute that shortens the window of time in which a physician may perform an abortion. See ch. 2022-69, § 4, Laws of Fla. (codified at section 390.0111(1), Florida Statutes (2022)). The parties have presented thoughtful arguments as to the scope of this provision, which has traditionally been referred to as the “Privacy Clause." Those legal arguments on the Privacy Clause's meaning are, in our view, distinct from the serious moral, ethical, and policy issues that are implicated in the subject matter of this case. Our analysis focuses on the Privacy Clause’s text, its context, and the historical evidence surrounding its adoption. After considering each of these sources and consistent with longstanding principles of judicial deference to legislative enactments, we conclude there is no basis under the Privacy Clause to invalidate the statute. In doing so, we recede from our prior decisions in which-relying on reasoning the U.S. Supreme Court has rejectedwe held that the Privacy Clause guaranteed the right to receive an abortion through the end of the second trimester. See generally In re T.W., 551 So. 2d 1186 (Fla. 1989); N. Fla. Women's Health & - 2

Counseling Servs., Inc. v. State, 866 So. 2d 612 (Fla. 2003); Gainesville Woman Care, LLC v. State, 210 So. 3d 1243 (Fla. 2017). For this reason, petitioners are not entitled to the temporary injunction granted by the trial court, and we approve the outcome reached by the First District Court of Appeal below.1 I This case involves a constitutional challenge to an amended Florida statute prohibiting abortions “if the physician determines the gestational age of the fetus is more than 15 weeks." § 390.0111(1), Fla. Stat. (2022); ch. 2022-69, § 8, Laws of Fla. (providing effective date of July 1, 2022). This prohibition does not apply if any of the following occurs: (a) Two physicians certify in writing that, in reasonable medical judgment, the termination of the pregnancy is necessary to save the pregnant woman's life or avert a serious risk of substantial and irreversible physical impairment of a major bodily function of the pregnant woman other than a psychological condition. (b) The physician certifies in writing that, in reasonable medical judgment, there is a medical necessity for legitimate emergency medical procedures for termination of the pregnancy to save the pregnant woman's life or avert a serious risk of imminent substantial and 1. We have jurisdiction. See art. V, § 3(b)(3), Fla. Const. (express-and-direct conflict). - 3

irreversible physical impairment of a major bodily function of the pregnant woman other than a psychological condition, and another physician is not available for consultation. (c) The fetus has not achieved viability under s. 390.01112 and two physicians certify in writing that, in reasonable medical judgment, the fetus has a fatal fetal abnormality. § 390.0111(1)(a)-(c). Prior to this change, the statute had restricted only late-term abortions. ² After this new law took effect, seven abortion clinics and one medical doctor (collectively Planned Parenthood)³ sued the State and others. Planned Parenthood alleged that the statute violated the Privacy Clause, which was added to the Florida Constitution in 1980. Located within the Declaration of Rights, the clause provides in full: 2. Specifically, the statute said, "No termination of pregnancy shall be performed on any human being in the third trimester of pregnancy unless one of [two] conditions is met." § 390.0111(1), Fla. Stat. (2021) (emphasis added). 3. The eight plaintiffs are Planned Parenthood of Southwest and Central Florida; Planned Parenthood of South, East, and North Florida; Gainesville Woman Care, LLC; A Woman's Choice of Jacksonville, Inc.; Indian Rocks Woman's Center, Inc.; St. Petersburg Woman's Health Center, Inc.; Tampa Woman's Health Center, Inc.; and Dr. Shelly Hsiao-Ying Tien. - 4

SECTION 23. Right of privacy.-Every natural person has the right to be let alone and free from governmental intrusion into the person's private life except as otherwise provided herein. This section shall not be construed to limit the public's right of access to public records and meetings as provided by law. With the complaint, Planned Parenthood filed a motion for temporary injunction, asking the trial court to block enforcement of the statute until it could rule on the merits of the constitutional challenge. In part, Planned Parenthood claimed that it was substantially likely to prevail in the lawsuit because it could demonstrate that the statute violates the Privacy Clause. In addition, Planned Parenthood argued that pregnant Floridians would be irreparably harmed absent a temporary injunction because the statute "would prohibit [them] from obtaining essential medical care and force them to remain pregnant and continue enduring the risks of pregnancy against their will." The statute, Planned Parenthood said, would also cause irreparable harm to itself and its staff by subjecting them to potential punitive consequences and interfering with the doctor-patient relationship. The State opposed Planned Parenthood's request for a temporary injunction. It argued that Planned Parenthood lacked - 5

standing to assert the privacy rights of its patients and, on the merits, could not establish any of the four requirements for a temporary injunction, let alone all four.4 After the State submitted its response, the U.S. Supreme Court issued a landmark decision on abortion in a case involving a Mississippi statute. See Dobbs v. Jackson Women's Health Org., 597 U.S. 215 (2022). In that decision, the Court ruled that the federal constitution does not guarantee a right to abortion. Id. at 231, 235-63, 292, 295. Based on this holding, the Court overturned Roe v. Wade, 410 U.S. 113 (1973), and Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833 (1992)—cases which had recognized a broad right to abortion under federal law. Dobbs, 597 U.S. at 292, 302 (expressly overruling Roe and Casey). In overruling those decisions, Dobbs "returned to the people and their elected representatives" "the authority to regulate abortion." Id. at 292. 4. Under Florida law, a party seeking a temporary injunction must prove four things: “(1) a substantial likelihood of success on the merits, (2) the unavailability of an adequate remedy at law, (3) irreparable harm absent entry of an injunction, and (4) that the injunction would serve the public interest." Fla. Dep't of Health v. Florigrown, LLC, 317 So. 3d 1101, 1110 (Fla. 2021). - 6

Several days after Dobbs issued, the trial court in this case held an evidentiary hearing on Planned Parenthood's motion for temporary injunction. Planned Parenthood called one witness and offered several exhibits. The State also presented witness testimony and documentary evidence. Deeming Planned Parenthood's evidence persuasive, the trial court entered a temporary injunction. It found that Planned Parenthood had third-party standing and satisfied all four temporary-injunction elements. In finding a likelihood of success on the merits, the court relied on our abortion jurisprudence. See generally T.W., 551 So. 2d at 1191-94 (Privacy Clause encompasses abortion); N. Fla. Women's Health, 866 So. 2d at 639 (reaffirming T.W.); Gainesville Woman Care, 210 So. 3d at 1246, 1253-55 (relying on T.W.). The court concluded that the statute was subject to strict scrutiny under that case law and determined that it either did not serve compelling interests or, in the alternative, was not the least restrictive means of achieving those interests. For the harm factor, the court ruled that both Planned Parenthood and its patients would suffer sufficient harm to support the requested relief. Rounding out its analysis, the court found no -7

adequate remedy at law and that an injunction would serve the public interests. The State appealed to the First District, triggering an automatic stay of the temporary injunction.5 Planned Parenthood asked the trial court and later the district court to vacate the automatic stay. Both courts, however, denied relief. State v. Planned Parenthood of Sw. & Cent. Fla., 342 So. 3d 863, 865-66 (Fla. 1st DCA 2022). As relevant here, in denying Planned Parenthood's motion to vacate, a divided panel of the First District held that Planned Parenthood could not establish irreparable harm as a result of the stay. Id. at 868-69. A few weeks later, the district court relied on essentially that same reasoning in reversing the temporary injunction—again, one judge dissented. State v. Planned Parenthood of Sw. & Cent. Fla., 344 So. 3d 637, 638 (Fla. 1st DCA 2022) ("[T]he non-final order granting the temporary injunction is reversed as [Planned Parenthood] could not assert irreparable harm on behalf of persons not appearing below."); id. (Kelsey, J., dissenting). 5. Fla. R. App. P. 9.310(b)(2) (automatic-stay provision triggered by filing of timely notice of appeal in certain situations). -8

Following these adverse rulings, Planned Parenthood asked us to review the First District's decisions, arguing that they conflict with our precedent. Accepting this jurisdictional argument, we granted review. II Planned Parenthood asks that we quash the district court's decisions and reinstate the temporary injunction. Relying on our precedent, it argues that the right to an abortion is secured by our constitution’s Privacy Clause. The State disputes Planned Parenthood's interpretation of the provision's text and asks us to reconsider our Privacy Clause jurisprudence or, at the very least, the abortion-related decisions. It argues that T.W.—our first case recognizing a right to abortion under the Privacy Clause-is flawed 6. In its brief, the State argues that Planned Parenthood lacks standing to challenge the new law. However, at oral argument, the Solicitor General urged us to decide this case on the merits. Oral Arg. at 50:52-51:06 (“We do think that the Court can assume for the sake of argument that the Plaintiffs have standing here and instead reach the merits. . . . That, I think, is what the Court should do.”). We view these statements as an abandonment of the State's standing argument. Thus, we proceed directly to the merits without passing upon any theory of standing articulated by the parties. - 9

in numerous respects, including that it failed to meaningfully consider the actual text of the provision at issue, failed to consider the history of the provision, and failed to give deference to the statute challenged in that case. Mindful of these fundamental concerns, we agree that our holding in T. W. should be reexamined.7 In T. W., this Court assessed a Privacy Clause challenge to a law that required unmarried minors to obtain parental consent or a substitute for consent to have an abortion. We held the challenged law to be incompatible with the protections afforded by the Privacy Clause, concluding that the right to abortion was embodied within the provision. T.W., 551 So. 2d at 1188, 1192-96; id. at 1197, 1201 7. As our discussion will show, we also emphasize the uniqueness of the competing interests implicated in abortion and the fact that the Supreme Court repudiated Roe and its underlying understanding of privacy. Because these factors relate to T. W. in a particularized way, we do not take up the State's invitation now to revisit the question of whether the Privacy Clause protects only "informational privacy" interests. Our jurisprudence before and after T. W. has understood the Privacy Clause to encompass certain decisional or autonomy rights, and today we do not revisit our precedents outside the abortion context. - 10

(Ehrlich, C.J., concurring specially).8 In the majority opinion, we discussed Roe v. Wade at length and ultimately adopted its definition of privacy along with its trimester and viability rules. See id. at 1190-94. Integral to the majority's analysis, T. W. emphasized recent Florida cases (primarily from the district courts) equating privacy with the right of personal decision-making in the specific context of refusing unwanted medical treatment. Id. at 1192. We also relied on Winfield v. Division of Pari-Mutuel Wagering, 477 So. 2d 544 (Fla. 1985)-a case involving privacy in financial institution records—to conclude that the provision “embraces more privacy interests" and "extends more protection to the individual in those interests, than does the federal Constitution." T.W., 551 So. 2d at 1192. Building on that, this Court made the following broad pronouncement: 8. Three justices, however, concluded that the challenged statute could be given a constitutional construction, though they accepted or assumed that the Privacy Clause conferred a right to abortion. T.W., 551 So. 2d at 1201-02 (Overton, J., concurring in part and dissenting in part); id. at 1202-04 (Grimes, J., concurring in part and dissenting in part); id. at 1204-05 (McDonald, J., dissenting). - 11 -

Florida's privacy provision is clearly implicated in a woman's decision of whether or not to continue her pregnancy. We can conceive of few more personal or private decisions concerning one's body that one can make in the course of a lifetime, except perhaps the decision of the terminally ill in their choice of whether to discontinue necessary medical treatment. Of all decisions a person makes about his or her body, the most profound and intimate relate to two sets of ultimate questions: first, whether, when, and how one's body is to become the vehicle for another human being's creation; second, when and how-this time there is no question of "whether"-one's body is to terminate its organic life. [Laurence H.] Tribe, American Constitutional Law 133738 (2d ed. 1988). The decision whether to obtain an abortion is fraught with specific physical, psychological, and economic implications of a uniquely personal nature for each woman. See Roe, 410 U.S. at 153. The Florida Constitution embodies the principle that “[f]ew decisions are more personal and intimate, more properly private, or more basic to individual dignity and autonomy, than a woman's decision . . . whether to end her pregnancy. A woman's right to make that choice freely is fundamental.” T.W., 551 So. 2d at 1192-93 (second alteration in original) (some citations omitted). This pronouncement was flawed in several respects. T. W. associated the language of the Privacy Clause with Roe's understanding of privacy; but it did not justify how that concept of privacy aligned with our constitution's text—i.e., “the right to be let alone and free from government intrusion into private life." T. W. - 12 -

also did not ask how Florida voters would have understood the text of the provision and how that understanding would be informed by Florida's long history of proscribing abortion. As a result of its analytical path, T. W. did not look to dictionaries, contextual clues, or historical sources bearing on the text's meaning. Instead, overlooking all these probative sources, it adopted Roe's notions of privacy and its trimester framework as matters of Florida constitutional law.9 Compounding these errors, the T.W. majority failed to apply longstanding principles of judicial deference to legislative enactments and failed to analyze whether the statute should be given the benefit of a presumption of constitutionality. Since Roe featured prominently in T. W., we think it fair to also point out that the T. W. majority did not examine or offer a reasoned response to the existing criticism of that decision or consider 9. In his dissent, Justice Labarga emphasizes "that T. W. was decided on state law grounds." Dissenting op. at 90. We agree that T.W. was not applying federal law to the challenged statute. However, T.W. relied heavily on Roe in interpreting the meaning of our constitution's Privacy Clause. Indeed, T. W. cited Roe over twenty times, it accepted Roe's concept of privacy without analysis, and it enacted a viability-trimester system that closely paralleled Roe's, without citing to any Florida precedent supporting that framework. - 13 -

whether it was doctrinally coherent. This was a significant misstep because Roe did not provide a settled definition of privacy rights. Controversial from the moment it was released, “Roe's constitutional analysis was far outside the bounds of any reasonable interpretation of the various constitutional provisions to which it vaguely pointed." Dobbs, 597 U.S. at 268. What's more, Roe "failed to ground its decision in text, history, or precedent.” Id. at 270. This left even progressive legal scholars baffled at how such a right could be gleaned from the constitution's text. Akhil R. Amar, Intratextualism, 112 Harv. L. Rev. 747, 778 (1999) ("As a precedent-follower, Roe simply stringcites a series of privacy cases involving marriage, procreation, contraception, bedroom reading, education, and other assorted topics, and then abruptly announces with no doctrinal analysis that this privacy right is broad enough to encompass' abortion. . . . But as the Court itself admits a few pages later [in the opinion], the existence of the living fetus makes the case at hand ‘inherently different’ . . . from every single one of these earlier-invoked cases. And as a precedent-setter, the Court creates an elaborate trimester framework that has struck many critics as visibly (indeed, nakedly) . . . more legislative than - 14 -

judicial." (footnotes omitted)); see also Laurence H. Tribe, Foreword: Toward a Model of Roles in the Due Process of Life and Law, 87 Harv. L. Rev. 1, 4 (1973) (noting that "[o]ne reads the Court's explanation [of the viability line] several times before becoming convinced that nothing has inadvertently been omitted”). Indeed, just three years after T.W. (and well before Dobbs), the U.S. Supreme Court abandoned Roe's position that the right to abortion was grounded in any sort of privacy right. See Casey, 505 U.S. at 846 (joint opinion) (“Constitutional protection of the woman's decision to terminate her pregnancy derives from the Due Process Clause of the Fourteenth Amendment."); cf. Dobbs, 597 U.S. at 279 ("The Court [in Casey] abandoned any reliance on a privacy right and instead grounded the abortion right entirely on the Fourteenth Amendment's Due Process Clause."). This demonstrates the tenuous connection between “privacy” and abortion an issue that, unlike other privacy matters, directly implicates the interests of both developing human life and the pregnant woman. In light of T. W.'s analytical deficiencies and subsequent U.S. Supreme Court decisions rejecting the Roe framework on which - 15 -

T.W.'s reasoning depended, our assessment of the challenged statute requires us to examine the Privacy Clause and, for the first time in the abortion context, consider the original public meaning of the text as it was understood by Florida voters in 1980.10 III A We begin by recognizing the standard that governs our review. Because this case requires us to review both “the constitutionality of a statute and the interpretation of a provision of the Florida Constitution," our review is de novo. Lewis v. Leon Cnty., 73 So. 3d 151, 153 (Fla. 2011) (citing Crist v. Fla. Ass’n of Crim. Def. Laws., Inc., 978 So. 2d 134, 139 (Fla. 2008)); see also Florigrown, LLC, 317 So. 3d at 1110. We have long recognized that “statutes come clothed with a presumption of constitutionality and must be construed whenever possible to effect a constitutional outcome." Lewis, 73 So. 3d at 10. We decided two other significant cases involving abortion after T. W., but in those cases, we did not provide additional doctrinal justifications for T.W.'s adoption of Roe's privacy framework. - 16

153 (citing Fla. Dep't of Revenue v. City of Gainesville, 918 So. 2d 250, 256 (Fla. 2005)). Indeed, nearly a century ago, we said: (1) On its face every act of the Legislature is presumed to be constitutional; (2) every doubt as to its constitutionality must be resolved in its favor; [and] (3) if the act admits of two interpretations, one of which would lead to its constitutionality and the other to its unconstitutionality, the former rather than the latter must be adopted . . . Gray v. Cent. Fla. Lumber Co., 140 So. 320, 323 (Fla. 1932); see also Savage v. Bd. of Pub. Instruction for Hillsborough Cnty., 133 So. 341, 344 (Fla. 1931); Chatlos v. Overstreet, 124 So. 2d 1, 2 (Fla. 1960); In re Caldwell's Estate, 247 So. 2d 1, 3 (Fla. 1971); Franklin v. State, 887 So. 2d 1063, 1073 (Fla. 2004); Florigrown, LLC, 317 So. 3d at 1111; Statler v. State, 349 So. 3d 873, 884 (Fla. 2022). And to overcome the presumption of constitutionality, “the invalidity must appear beyond reasonable doubt." Franklin, 887 So. 2d at 1073 (quoting State ex rel. Flink v. Canova, 94 So. 2d 181, 184 (Fla. 1957)); see also Waybright v. Duval Cnty., 196 So. 430, 432 (Fla. 1940) ("[W]e will . . . determine if, beyond a reasonable doubt, violence was done [to] any provisions of the organic law in the passage of the challenged act, and in doing so will not deal with the - 17 -

merits of the measure, that being the exclusive concern of the Legislature."). B Our approach to interpreting the constitution reflects a commitment to the supremacy-of-text principle, “recognizing that '[t]he words of a governing text are of paramount concern, and what they convey, in their context, is what the text means. Coates v. R.J. Reynolds Tobacco Co., 365 So. 3d 353, 354 (Fla. 2023) (alteration in original) (quoting Levy v. Levy, 326 So. 3d 678, 681 (Fla. 2021)) (interpreting statutory text); see also Advisory Op. to Governor re Implementation of Amend. 4, The Voting Restoration Amend. (Amendment 4), 288 So. 3d 1070, 1081 (Fla. 2020) (interpreting constitutional text). The goal of this approach is to ascertain the original, public meaning of a constitutional provision-in other words, the meaning as understood by its ratifiers at the time of its adoption. See City of Tallahassee v. Fla. Police Benevolent Ass'n, Inc., 375 So. 3d 178, 183 (Fla. 2023) ("[W]e give the words of the constitution their plain, usual, ordinary, and commonly accepted meanings at the time they were written.”). In construing the meaning of a constitutional provision, we do not - 18 - 999

seek the original intent of the voters or the framers. Instead, we ask how the public would have understood the meaning of the text in its full context when the voters ratified it. See Amendment 4, 288 So. 3d at 1081-82. To answer this question of public meaning, we consider the text, see Alachua Cnty. v. Watson, 333 So. 3d 162, 169-70 (Fla. 2022), contextual clues, see id., dictionaries, see Somers v. United States, 355 So. 3d 887, 891 (Fla. 2022), canons of construction, see Conage v. United States, 346 So. 3d 594, 598-99 (Fla. 2022), and historical sources, including evidence related to public discussion, see Tomlinson v. State, 369 So. 3d 1142, 1147-51 (Fla. 2023); Dist. of Columbia v. Heller, 554 U.S. 570, 614 (2008). IV With these background principles fixed, we now focus our attention on the Privacy Clause itself. Article I, section 23 is entitled: "Right of privacy." Our constitution, though, tells us that in construing the meaning of constitutional text, we are not to use titles and subtitles. See art. X, § 12(h), Fla. Const. Accordingly, we look at the operative text, which guarantees the right “to be let - 19 -

alone and free from governmental intrusion into the person's private life." Art. I, § 23. As is apparent at first glance, the provision does not explicitly reference abortion at all. Thus, if Planned Parenthood is to prevail, we must find that the public would have understood the principle embodied in the operative text to encompass abortion, even though the clause itself says nothing about it. To this end, the parties have marshaled era-appropriate dictionary definitions of key terms in the Privacy Clause. Based on the dictionaries we consulted, we know that in 1980 the right to be "let alone" could be defined as the right to be left "in solitude," free from outside "interfer[ence]” or “attention." See Let Alone, Oxford English Dictionary 213 (1st ed. 1933) (reprinted in 1978). And the latter phrase "free from governmental intrusion” into “private life”—can convey a similar meaning. “Intrusion” meant “[i]llegal entry upon or appropriation." Intrusion, American Heritage Dictionary of the English Language 688 (1st ed. 1969); see also Intrusion, American Heritage Dictionary 674 (2d Coll. ed. 1982) (same); Intrude, American Heritage Dictionary of the English Language 687 (1st ed. 1969) ("To interpose (oneself or something) - 20 -

without invitation, fitness, or leave."); Intrude, American Heritage Dictionary 674 (2d Coll. ed. 1982) (similar). And the word "private" carried the idea of being "[s]ecluded from the sight, presence, or intrusion of others," the chief example being “a private bathroom." Private, American Heritage Dictionary of the English Language 1042 (1st ed. 1969); Private, American Heritage Dictionary 986 (2d Coll. ed. 1982) (same). These accepted definitions do not seem to us to be natural ways of describing the abortion procedures of 1980. The decision to have an abortion may have been made in solitude, but the procedure itself included medical intervention and required both the presence and intrusion of others. See, e.g., Roe, 410 U.S. at 172 (Rehnquist, J., dissenting) (“A transaction resulting in an operation such as [abortion] is not 'private' in the ordinary usage of that word."); Thornburgh v. Am. Coll. of Obstetricians & Gynecologists, 476 U.S. 747, 792 (1986) (White, J., dissenting) (noting that even the Roe majority recognized a "pregnant woman cannot be isolated in her privacy” because “the termination of a - 21

pregnancy typically involves the destruction of another entity: the fetus" (quoting Roe, 410 U.S. at 159)).11 Next, we see if contextual clues could offer guidance. Looking at the complete text of the provision allows us to consider the physical and logical relation of its parts, as they might have been viewed by a voter. See Lab'y Corp. of Am. v. Davis, 339 So. 3d 318, 324 (Fla. 2022). 11. The dissent cites Griswold v. Connecticut, 381 U.S. 479 (1965) (invalidating on privacy grounds a state law criminalizing the use of contraception in the marital context), to support the assertion that the involvement of others does not prevent an activity or procedure from being a private matter. Dissenting op. at 67-68 (stressing that the law at issue in Griswold “operate[d] directly on an intimate relation of husband and wife and their physician's role in one aspect of that relation" (quoting Griswold, 381 U.S. at 482)). But the Court in Griswold "only invalidated the section of the state law which prohibited the use of contraception, rather than outlawing the manufacture, distribution, or sale of contraceptives." Alyson M. Cox & O. Carter Snead, “Grievously and Egregiously Wrong": American Abortion Jurisprudence, 26 Tex. Rev. L. & Pol. 1, 16-17 (2022). Indeed, as we noted above, Roe itself acknowledged that abortion was "inherently different" from the situations involved in cases like Griswold. Roe, 410 U.S. at 159. Thus, we do not share the dissent's concern "that parties will rely on the majority's reasoning that the involvement of 'others' in an abortion procedure defeats privacy—in attempts to undermine the broad privacy protections that are extended in the medical context.” Dissenting op. at 68. - 22

The first sentence sets forth the protected right, i.e., "to be let alone and free from governmental intrusion into . . . private life." The second sentence then provides that “[t]his section shall not be construed to limit the public's right of access to public records and meetings as provided by law." Art. I, § 23. By its terms, this latter sentence covers “public records and meetings.” That phrase which relates only to accessing public informationdoes not implicate or apply to the subject of abortion. We do not give great weight to this observation, but we note it here to emphasize that contextual clues do not lend support to a claim that voters clearly understood abortion to be part and parcel of the rights recognized in the Privacy Clause. V Dictionary definitions and immediate context, although informative, do not provide a full picture of the text's meaning. We also consider the historical background of the phrases contained within the operative text. See Tomlinson, 369 So. 3d at 1146 ("[W]hen (as often happens) a word had more than one accepted meaning at that time, we decide which one is the law by looking to the context in which it appears, and what history tells us about - 23 -

how it got there."); Antonin Scalia & Bryan Garner, Reading Law: The Interpretation of Legal Texts 33 (2012) ("[C]ontext embraces not just textual purpose but also . . . a word's historical associations acquired from recurrent patterns of past usage . ."); see also Heller, 554 U.S. at 605 (noting the critical importance in constitutional interpretation of examining “a variety of legal and other sources to determine the public understanding of a legal text in the period after its enactment or ratification"); TransUnion LLC v. Ramirez, 594 U.S. 413, 424 (2021) (relying on historical sources in determining constitutional text's meaning); N.Y. State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1, 26-27 (2022) (historical sources integral to Court's holding). A Before examining the Privacy Clause's specific history and public debate, we explore the settled use of the "right to be let alone" in the context of Florida law, cognizant that technical meanings might bear upon the public understanding of the constitutional text. 12 12. In construing constitutional provisions that have an acquired meaning, “[w]e cannot understand these provisions unless - 24

The phrase "to be let alone" carries with it a rich legal tradition. In Cason v. Baskin, we discussed the common-law right to privacy and explained that in substance it was "the right to be let alone, the right to live in a community without being held up to the public gaze if you don't want to be held up to the public gaze." 20 So. 2d 243, 248 (Fla. 1944) (quoting Laurence H. Eldredge, Modern Tort Problems 77 (1941)).¹3 This right “to be let alone,” which was we understand their history; and when we find them expressed in technical words, and words of art, we must suppose these words to be employed in their technical sense." Thomas M. Cooley, A Treatise on the Constitutional Limitations which Rest upon the Legislative Power of the States of the American Union 93-94 (7th ed. 1903). Indeed, “[t]he technical sense in these cases is the sense popularly understood, because that is the sense fixed upon the words in legal and constitutional history where they have been employed for the protection of popular rights." Id. at 94 (emphasis added). 13. We recognize that this phrase “the right to be let alone” is likely sourced from the seminal 1890 law-review article, The Right to Privacy. Samuel D. Warren & Louis D. Brandeis, The Right to Privacy, 4 Harv. L. Rev. 193 (1890); cf. Stall v. State, 570 So. 2d 257, 265 (Fla. 1990) (Kogan, J., dissenting) (recognizing significance of this article). The authors of that article elaborated on the "right to be let alone" and free from “intrusion upon the domestic circle." Warren & Brandeis, supra, at 195-96 (borrowing label for this right from a tort treatise by Judge Thomas Cooley). The right, however, “had little to do with the autonomy of an individual to make decisions . . . free from government control." Jeffrey M. Shaman, The Right of Privacy in State Constitutional Law, 37 Rutgers L.J. 971, 990 (2006). It described a "different sort of privacy"-one - 25 -

often used interchangeably with the "right to privacy," was a prominent feature in Florida tort law. See, e.g., Battaglia v. Adams, 164 So. 2d 195, 197 (Fla. 1964) (“An unauthorized use of a person's name in this respect is recognized as a violation of his right of privacy."); Jacova v. S. Radio & Television Co., 83 So. 2d 34, 36 (Fla. 1955) (reiterating that Florida recognized a common-law claim for invasion of privacy and noting that "[when] one, whether willingly or not, becomes an actor in an occurrence of public or general interest,” “he emerges from his seclusion, and it is not an invasion of his right of privacy' to publish his photograph with an account of such occurrence" (quoting Metter v. L.A. Exam'r, 95 P.2d 491, 494 (Cal. Ct. App. 1939))); Harms v. Mia. Daily News, Inc., 127 So. 2d 715, 717 (Fla. 3d DCA 1961) (noting in the tort context that "[t]he "directed to keeping personal information from being exposed to the public, rather than to keeping decision-making within the control of an individual." Id. To Warren and Brandeis, the “right to be let alone" and free from “intrusion" safe-guarded against the publication of private facts. Warren & Brandeis, supra, at 195-96, 207-12. - 26

right of privacy is defined as the right of an individual to be let alone and to live a life free from unwarranted publicity"). 14 Significantly, throughout the decades in which the "right to be let alone" was developed and applied in Florida, two distinct propositions were true in the law and harmonious: first, the right "to be let alone” existed and had a discernable and enforceable meaning; and second, the Legislature had the authority to comprehensively regulate abortion before and after viability. Indeed, from at least 1868 to 1972, abortion was for the most part prohibited in our state. 15 And although litigants, prior to the 14. Florida law in this respect appears consistent with that of other jurisdictions. See W.E. Shipley, Annotation, Right of Privacy, 14 A.L.R.2d 750 (1950) (noting acts of intrusion into one's private affairs may also constitute violations of the right of privacy, such as eavesdropping, examination of private records or papers, or publications of personal material identified with the complainant as would using the complainant's name or likeness in almost any form of distributive publication). 15. See ch. 1637, subc. 3, § 11, subc. 8, § 9, Laws of Fla. (1868) (outlawing most abortions); Rev. St. 1892, §§ 2387, 2618 (same); §§ 782.10, 797.01, Fla. Stat. (1941) (repealed 1972) (same); §§ 782.10, 797.01, Fla. Stat. (1971) (repealed 1972) (same). In 1972, this Court determined that the abortion statute in effect at that time was unconstitutionally vague. State v. Barquet, 262 So. 2d 431, 438 (Fla. 1972). Immediately following that decision, the Legislature passed a more specific law, still banning abortion at all times during pregnancy except in certain limited circumstances. - 27 -

adoption of the Privacy Clause, sought to curtail government action by arguing they had the "right to be let alone," we are not aware of litigants invoking that particular right to challenge abortion restrictions in Florida. We also stress that this “right to be let alone” was modified by a limiting principle: the right did not permit an individual to inflict harm on herself or others. See State v. Eitel, 227 So. 2d 489, 491 (Fla. 1969) (rejecting a challenge to helmet laws based on a right "to be let alone," stressing that "no person is an entirely isolated being" and that “it is impossible for a person to do anything seriously or permanently hurtful to himself, without mischief reaching at least to his near connections, and often far beyond them") (cleaned up). Indeed, our Privacy Clause jurisprudence outside the abortion context recognizes that the right does not authorize harm to third parties. See, e.g., Beagle v. Beagle, 678 So. 2d 1271, 1276 (Fla. 1996) (parents' privacy right to raise their children yields to need to protect children from harm). Because the "right to be let alone" was limited in this way, it is not surprising that when litigants Ch. 72-196, § 2, Laws of Fla. (codified at section 458.22 of the Florida Statutes (Supp. 1972)) (repealed 1976). - 28

challenged the 1972 abortion statute in this Court, they did not do so based on the "right to be let alone." Instead, they argued a right to privacy grounded in substantive due process under the Fourteenth Amendment to the United States Constitution. See Barquet, 262 So. 2d at 434. B We also acknowledge that the public understanding of the term "privacy" was, to some extent, informed by the U.S. Supreme Court's 1973 decision in Roe v. Wade. Following that decision, the phrase “right to privacy” gained new connotations that, for the first time, included the choice to have an abortion. See Roe, 410 U.S. at 154 ("We, therefore, conclude that the right of personal privacy includes the abortion decision .”). In Planned Parenthood's view, this aspect of federal privacy jurisprudence should control our analysis here. Specifically, Planned Parenthood argues that Florida voters would have internalized Roe's definition of privacy when they voted for the privacy amendment. Indeed, Planned Parenthood has repeatedly asserted that the public understanding of this privacy definition was so engrained by 1980 that even without a specific mention of the term abortion, the Privacy Clause unequivocally - 29 -

included such a right by implication. Agreeing with this argument, the dissent cites case law, newspaper articles, a news clip, and more to support the contention that Americans, and Floridians in particular, would have naturally understood privacy to encompass abortion. 16 Though this argument has some force, we cannot agree with Planned Parenthood or the dissent that the backdrop of Roe conclusively establishes how a voter would have understood the provision. In Roe, the Supreme Court did not consider language comparable to the operative text of Florida's Privacy Clause-that is, the “right to be let alone.” That phrase is found only once in Roe, and that single mention is in Justice Stewart's concurrence quoting Katz v. United States, 389 U.S. 347 (1967), in support of the proposition that there is no federal right to privacy. Roe, 410 U.S. 16. This evidence consists primarily of media coverage surrounding the Roe decision and subsequent evidence that discussed the abortion debate and associated a right of privacy with abortion. We accept that Roe had some bearing on the public's understanding of privacy rights in 1980. But, unlike the dissent, we do not find that it is dispositive. We are unwilling to disregard other probative evidence of public meaning, much of which is focused specifically on the amendment itself. The dissent, in our view, gives little attention to such evidence. - 30

at 167 n.2 (Stewart, J., concurring). So, while the Roe majority may have deemed abortion to be part of a “right to privacy," it would require an analytical leap to say that the public would have instinctively associated “the right to be let alone and free from governmental interference into one's private life" with abortion. E.g., Louis Henkin, Privacy and Autonomy, 74 Colum. L. Rev. 1410, 1424 (1974) (decisional autonomy “is not at all what most people mean by privacy,” which instead concerns “my freedom from official intrusion into my home, my person, my papers, my telephone”). This point is reinforced by the fact that the specific phrase used in the Privacy Clause had a consistent meaning in Florida law and had never once been interpreted to cover abortion rights. And as a final point here, we reiterate that Roe did not settle the scope of privacy rights as Planned Parenthood insists. As we discussed earlier, Roe's privacy-based reasoning was questioned soon after the opinion issued and was eventually rejected in a decision that completely detached abortion rights from the concept of privacy. See Casey, 505 U.S. at 846 (joint opinion). Thus, even if it is possible that voters would have understood the Privacy Clause to protect certain individual autonomy interests, it is by no means - 31

clear that those interests would have included the controversial subject of abortion, which uniquely involves the interests of prenatal life. Consequently, while Roe is relevant to our analysis of public meaning, it is not dispositive. Having considered dictionary definitions, context, and technical meanings that could have informed the original public meaning, we now turn to a critical piece of our historical analysis where we answer the following relevant questions: How did this provision make its way to the ballot, what was the focus of the debate surrounding its adoption, and how were the issues framed for the voters? C The origin of our Privacy Clause traces back to the work of a constitution revision commission in the late 1970s. As part of its work, the commission held public meetings throughout Florida and listened to the public's views and concerns. See Daniel R. Gordon, Upside Down Intentions: Weakening the State Constitutional Right to Privacy, a Florida Story of Intrigue and a Lack of Historical Integrity, 71 Temp. L. Rev. 579, 588 (1998); Transcript of Fla. C.R.C. proceedings at D:003272-73 (Jan. 9, 1978) (discussion of - 32 -

committee's work regarding privacy proposal). Eventually, the commission agreed upon the following language: Every natural person has the right to be let alone and free from governmental intrusion into his private life except as otherwise provided herein. Patricia A. Dore, Of Rights Lost and Gained, 6 Fla. St. U. L. Rev. 609, 650 n.248 (1978) (quoting Fla. C.R.C., Rev. Fla. Const. art. I, § 23 (May 11, 1978)). That proposed amendment, along with roughly 80 others, was submitted to the public as a package deal in the 1978 election. Gordon, supra, at 588. This package, in addition to containing the privacy proposal, also included amendments ensuring access to (1) public records, (2) meetings of non-judicial public bodies, (3) judicial hearings and records, and (4) proceedings and records of the judicial nominating commissions. Gerald B. Cope, Jr., To Be Let Alone: Florida's Proposed Right of Privacy, 6 Fla. St. U. L. Rev. 671, 675-77 (1978). Of note, proposals specifically addressing state abortion rights were rejected by the commissioners and never made it to the ballot. See Fla. Const. Revision Comm'n, Summary of Proposed Revisions to the Florida Constitution 1-2 (Sept. 27, 1977) (available in the Florida State University College of Law Research - 33 -

Center); cf. Mary Ann Lindley, A New Constitution Takes Shape, Palm Beach Post-Times, Apr. 9, 1978, at D1. For our purposes, though, we focus on statements made by commissioners in describing the reason or need for the proposal.17 On this subject, Justice Overton said: [W]ho, ten years ago, really understood that personal and financial data on a substantial part of our population could be collected by government or business and held for easy distribution by computer operated information systems? There is a public concern about how personal information concerning an individual citizen is used, whether it be collected by government or by business. The subject of individual privacy and privacy law is in a developing stage. . . . It is a new problem that should probably be addressed. Transcript of Fla. C.R.C. proceedings D:000020-21 (July 6, 1977). 17. See McDonald v. City of Chicago, 561 U.S. 742, 828-29 (2010) (Thomas, J., concurring in part and concurring in the judgment) (“When interpreting constitutional text, the goal is to discern the most likely public understanding of a particular provision at the time it was adopted. Statements by legislators can assist in this process to the extent they demonstrate the manner in which the public used or understood a particular word or phrase. They can further assist to the extent there is evidence that these statements were disseminated to the public. In other words, this evidence is useful not because it demonstrates what the draftsmen of the text may have been thinking, but only insofar as it illuminates what the public understood the words chosen by the draftsmen to mean.”). - 34 -

Justice Overton was not alone in this respect. Commissioner Jon Moyle (sponsor of the privacy proposal) spoke of government surveillance, technological advances, and society's dependence on such technology—characterizing them as threats to an individual's privacy. Transcript of Fla. C.R.C. proceedings at D:003273, 327678 (Jan. 9, 1978). He also noted that records about private life were becoming more common. Id. at D:003277-81. According to him, states were “very much involved in the business of keeping records about their residents.” Id. at D:003276. But the states, in his view, had not done “their part” in protecting such records. Id. at D:003277. In line with Commissioner Moyle's sentiments, Commissioners Lew Brantley and Dexter Douglass both noted specific government-surveillance efforts as sources of privacy concerns. Id. at D:003325 (remarks of Lew Brantley); id. at D:003336 (remarks of Dexter Douglass). This historical survey is illustrative of the commission's focus in terms of privacy. Various commissioners publicly expressed concern for informational privacy. However, as best as we can tell from their statements, that pressing concern did not extend to abortion. - 35

The proposals failed, and less than two years later, we held that there was no state constitutional right of privacy that would prevent public disclosure of confidential papers prepared by a consultant for an electric authority. Shevin v. Byron, Harless, Schaffer, Reid & Assocs., Inc., 379 So. 2d 633, 639 (Fla. 1980); cf. Laird v. State, 342 So. 2d 962, 963 (Fla. 1977) (no constitutional right of privacy to smoke marijuana in confines of home). Months after Shevin was decided, the Legislature revived the idea of a privacy clause and ultimately agreed on a proposal that said: Every natural person has the right to be let alone and free from governmental intrusion into [the person's] private life except as otherwise provided herein. This section shall not be construed to limit the public's right of access to public records and meetings as provided by law. Editorial, Guaranteeing Our Privacy, Boca Raton News, Oct. 29, 1980, at 6A (setting forth language to appear on 1980 ballot); Patrick McMahon, State Constitutional Amendments, St. Petersburg Times, Oct. 30, 1980, at 22 (noting ballot title). In overwhelming numbers, legislators from both political parties voted to approve it for placement on the ballot. Out of the - 36

138 legislators who voted on it, only 6 did not support the proposal. See Lorraine Cichowski, House Votes to Propose Guaranteeing Right to Privacy, Fort Myers News-Press, May 7, 1980, at 8B; Jim Walker, Senators Clash over Privacy Amendment, Tampa Tribune, May 15, 1980, at 6-A. Of additional note, during the floor debate, there was virtually no discussion of abortion. And when abortion was brought up, the Senate sponsor assured other senators that the proposal would have no effect on that subject. Audio Tape: Proceedings of the Fla. S., Tape 2 at 17:40 (May 14, 1980) (available at Fla. Dep't of State, Fla. State Archives, Tallahassee, Fla., Series S1238, Box 57). As best as we can tell, no commissioner or legislator ever claimed (at least publicly between 1977-80) that abortion was part of the rights guaranteed by the Privacy Clause.¹8 See, e.g., Gordon, 18. To the extent that Planned Parenthood relies on Representative Jon Mills's later statement in the 1990s that he subjectively hoped that the privacy proposal would cover abortion, such reliance is misplaced. See Heller, 554 U.S. at 577 (proper approach to interpretation does not consider hidden or secret meaning "that would not have been known to ordinary citizens in the founding generation”). Similarly, Planned Parenthood and one amicus misplace reliance on how voters handled two later proposed amendments—one in 2004 and the other in 2012. The understanding of voters over 20 years after the privacy amendment offers little value in determining what the voters in 1980 would have understood the privacy proposal to mean. Indeed, at oral - 37 -

supra, at 590 n.148 ("Nowhere did revision commissioners in 1978 refer to abortion . ."). Indeed, Planned Parenthood does not claim otherwise. D Like the history of the privacy proposal, the public debate surrounding the amendment also did not focus on abortion. Once the privacy proposal was approved for placement on the ballot in 1980, the public engaged in significant and robust debate over whether that proposal should be approved. Advocates for homosexual rights, proponents of legalized marijuana use, and various editorial boards advocated in favor of the amendment. Mary Hladky, Commissioners Table Vote on State Privacy Amendment, Fort Lauderdale News, Oct. 1, 1980, at 8B; Mary Lavers, Privacy Amendment Advocated by Kunst, Tampa Times, Oct. 23, 1980, at 10-A; Associated Press, Privacy Amendment Caught in Swirl of Controversy, Sentinel Star (Orlando), Oct. 24, 1980, at 2-C; Editorial, Amendment 2-Vote Yes, argument, Planned Parenthood conceded as much. See Oral Arg. at 22:59-23:02 (“2012 isn't evidence of what [the privacy amendment] meant in 1980.”). - 38 -

Bradenton Herald, Nov. 1, 1980, at A-4; Craig Matsuda, State Questions Are a Mix of Roads, Water, Privacy, Miami Herald, Nov. 2, 1980, at 8E; Amendments, St. Petersburg Times, Nov. 1, 1980, at 12B. These groups presented sweeping views of what the amendment would accomplish. Some, for instance, claimed that the amendment would decriminalize marijuana as well as certain intimate sexual conduct occurring inside the confines of a home. Julius Karash, Psychologist Stumps for Amendment, News-Press Local, Oct. 3, 1980, at B1; Steve Piacente, Gay Rights Activist Speaks for Privacy Act, Tampa Tribune, Oct. 24, 1980, at 2-B. Opponents of the measure included some political conservatives, various law enforcement officers, an association of prosecutors, and the then-serving governor. Prosecutors Condemn Privacy Amendment, Florida Today, Oct. 28, 1980, at 4B; Attorneys' Group Fights Privacy Amendment, Palm Beach Post, Oct. 28, 1980, at B26; Amendments under Attack as Vote Nears, Bradenton Herald, Oct. 29, 1980, at B-5; Graham Hit on Privacy, Florida Today, Oct. 29, 1980, at 6B; Amendment Opposition by Graham Criticized, Palm Beach Post, Oct. 29, 1980, at A11; Lawyer Raps Constitution Revision Plan, Fort Lauderdale News, Oct. 29, 1980, at 17A; Michael - 39 -

Harrell, Advertisement, Fort Lauderdale News, Oct. 29, 1980, at 16A; Amendments, St. Petersburg Times, Nov. 1, 1980, at 12B. Some opponents expressed concern that the open-ended language would permit courts to expansively interpret the amendment. Sensing that growing concern, House sponsors of the privacy proposal weighed in on the public debate. Taking to the newspapers, they reassured the public that concerns about whether the amendment would accomplish sweeping policy changes were unfounded. For instance, sponsors said that the proposed amendment arose from concerns “about technological advances that could enable the government to compile extensive computer files on citizens." Privacy Amendment Caught in Swirl of Controversy, supra, at 2-C; see also Associated Press, Privacy Measure Stirs Controversy, Pensacola News-Journal, Nov. 2, 1980, at 14C. Indeed, one sponsor said that the proposal was "necessary to ward off a growing government whose curiosity about people's private lives also is increasing." R. Michael Anderson, Amendment Guaranteeing Right to Privacy Debated, Florida Times-Union Jacksonville Journal, Oct. 26, 1980, at B-1. That same sponsor characterized the proposal as "quite conservative," predicting that - 40 -

"Florida judges wouldn't use it to overturn many existing laws." Privacy Amendment Caught in Swirl of Controversy, supra, at 2-C. And the other sponsor called expansive views of the proposed amendment “garbage.” See id. Of note, in looking at the extensive discussion surrounding the privacy amendment, little to nothing was said about abortion in print or in public comment. The debate-as framed to the publicoverwhelmingly associated the Privacy Clause's terms with concerns related to government surveillance and disclosure of private information to the public. Consistent with this observation, prolife and prochoice groups did not join in the fray. These groups are not politically bashfulnot now, and not in 1980. If the public understanding of the privacy proposal was that it included a silent-but almost unfettered-right to abortion, we would expect such groups to have engaged in the robust public debate. But based on all sources brought to our attention, we simply see no evidence of that. See James W. Fox, Jr., A Historical and Originalist Defense of Abortion in Florida, 75 Rutgers U. L. Rev. 393, 443-44 (2023) (acknowledging that these groups were silent on this topic; but - 41 -

discounting significance of such fact); cf. Oral Arg. at 13:02-13:39 (counsel for Planned Parenthood acknowledging that silence in the historical record). The dissent downplays the significance of this scope-of-debate evidence. Dissenting op. at 86. Accepting the logic of a law review article, the dissent claims that “[a]bortion would only have been debated if its coverage within the right to privacy were in dispute or were not yet established in law." Dissenting op. at 86 (quoting Fox, supra, at 442-43). We, however, cannot agree with this speculation. A person's understanding of the amendment's purpose would certainly inform whether he or she supported the adoption of the amendment. And, critically, it would inform how that person would persuade others to adopt their position. The debate over the privacy amendment was vigorous, yet there is virtually no evidence that anyone publicly connected the privacy amendment proposal with abortion rights. And as referenced by the dissent, newspapers during this same period were still discussing the controversy surrounding abortion, so it was far from a settled issue. Dissenting op. at 81-82 (noting that "Florida newspapers" in 1980 "covered statements by pro-choice activists and by pro-life activists" - 42 -

involving the abortion debate). We are unwilling to presume, as the dissent does, that abortion was so intertwined with the term "privacy" and so unquestionably accepted by society that its complete absence from the public debate surrounding this amendment should be expected. In sum, the scope of the privacy-proposal debate, both in terms of topics and participants, underscores that the public would not have understood, or assumed, the language of the Privacy Clause to encompass abortion. E Finally, we consider two additional sources of historical evidence, both of which show a contemporaneous understanding that the Privacy Clause did not enshrine abortion rights in our constitution. The first is concurrent legislative action. There were several Florida statutes passed between 1978 and 1980 regulating or restricting access to abortion in substantial ways. See ch. 78382, §§ 2, 4-10, Laws of Fla. (empowering Department of Health and Rehabilitative Services to create rules regulating abortion clinics; setting forth licensing requirement and framework; prohibiting abortion by unlicensed clinics); ch. 79-302, § 1, Laws of - 43 -

Fla. (requiring parental consent for unmarried minors); ch. 80-208, § 1, Laws of Fla. (fetal remains to be disposed of in "sanitary and appropriate manner"; establishing crime for violations of this standard); ch. 80-413, § 1, Laws of Fla. (additional regulations on abortion clinics; imposing standard governing disposal of fetal remains); cf. Amicus Brief of Former State Representative John Grant at 25-28 (noting concurrent legislation on abortionparticularly the abortion law passed during the same session as the privacy proposal). Based on this significant body of abortion regulation—some of which would be struck down as violative of Roe¹⁹ it seems unlikely to us that the Legislature in 1980 would put to the people a proposal crafted to imperil that recent work. The second source of evidence is what legislators of the time expressed with respect to adding a right-to-life amendment to the U.S. Constitution. See Fla. S. Comm. on HRS SM 737 (1978) Staff Analysis 1 (Fla. May 9, 1978) (available at Fla. Dep’t of State, Fla. State Archives, Tallahassee, Fla.); Fla. H.R., H.M. 388, 11th Sess. (Fla. 1979) (available at Dep't of State, Fla. State Archives, 19. See, e.g., Fla. Women's Med. Clinic, Inc. v. Smith, 536 F. Supp. 1048, 1059 (S.D. Fla. 1982). - 44 -

Tallahassee, Fla.); Fla. S., S.M. 118, 11th Sess. (Fla. 1979) (available at Fla. Dep't of State, Fla. State Archives, Tallahassee, Fla.). Of significance here, twenty-seven legislators who voted for the privacy proposal had, within the prior two years, openly supported the adoption of a federal amendment to "protect unborn human[s]” in response to Roe v. Wade. Compare H.R. Journal, 12th Sess., at 318 (Fla. 1980), with H.R. Journal, 11th Sess., at 48 (Fla. 1979); compare S. Journal, 11th Sess., at 21 (Fla. 1979), with S. Journal, 12th Sess., at 313 (Fla. 1980). To us, it seems quite unlikely that so many legislators would have tried to remove abortion rights as a matter of federal constitutional law only to restrict legislative power on abortion just two years later by way of a state constitutional amendment. F We pause to summarize the textual, contextual, and historical evidence we have discussed so far. The Privacy Clause of the Florida Constitution does not mention abortion or include a word or phrase that clearly incorporates it. Era-appropriate dictionary definitions and contextual clues suggest that abortion does not naturally fit within the rights at issue. Reliable historical sources, - 45 -

like the technical meaning of the terms contained in the provision, the origin of the amendment, and the framing of the public debate, similarly do not support a conclusion that abortion should be read into the provision's text. Roe is also relevant to our analysis of the public meaning of the Privacy Clause. But speculation as to Roe's effect on voter understanding does not overcome the combined force of the substantial evidence we have examined above. Thus, we cannot conclude that in 1980 a voter would have assumed the text encompassed a polarizing definition of privacy that included broad protections for abortion. VI We have established the background legal principles that govern our review and analyzed the original public meaning of the Privacy Clause as it relates to the subject of abortion. Now, we must address how those considerations apply here-namely, can Planned Parenthood demonstrate conflict between the challenged statute and the constitutional protections secured by the Privacy Clause? The statute we review prohibits abortions after 15 weeks of pregnancy, subject to certain exceptions. This statute "come[s] - 46 -

clothed with a presumption of constitutionality and must be construed" if possible "to effect a constitutional outcome." Crist, 978 So. 2d at 139. To overcome this presumption, the challenger must establish invalidity (or conflict) "beyond reasonable doubt." Id. Based on our analysis finding no clear right to abortion embodied within the Privacy Clause, Planned Parenthood cannot overcome the presumption of constitutionality and is unable to demonstrate beyond a reasonable doubt that the 15-week ban is unconstitutional. 20 This conclusion brings us into tension with our precedent, primarily T. W. in which we derived a right to abortion from the Privacy Clause's text and invalidated a statute on that basis. 551 So. 2d at 1188; see also N. Fla. Women's Health, 866 So. 2d at 639 (reaffirming T.W.); Gainesville Woman Care, 210 So. 3d at 1253-56, 20. Even if we gave significantly greater weight to Roe's effect on the original public meaning of the Privacy Clause (as urged by the dissent) and gave less weight to the other meaningful sources of evidence discussed above, we would still be left without a definition of privacy and considerable ambiguity as to the breadth of the provision. In that instance, we would reach the same conclusion, because a statute is presumed constitutional unless shown to be invalid beyond a reasonable doubt. Franklin, 887 So. 2d at 1073. The dissent fails to address what effect, if any, this longstanding principle of law should have here. - 47 -

1260 (relying on T.W.). In deciding how to resolve that tension, we again emphasize that T. W. failed to acknowledge the longstanding principle that statutes are presumed to be constitutional. This error led the Court to read additional rights into the constitution based on Roe's dubious and immediately contested reasoning, rather than evaluate what the text of the provision actually said or what the people of Florida understood those words to mean. The decision to extend the protections of the Privacy Clause beyond what the text could reasonably bear was not ours to make. As a result, we removed substantial authority from the people's elected representatives to regulate abortion-a profoundly unique and complicated issue that affects society in many significant ways. Accordingly, for the reasons given above, we find T.W. to be clearly erroneous. Based on our established test for assessing stare-decisis issues, we now ask whether there is a valid reason not to recede from T.W. See State v. Poole, 297 So. 3d 487, 506-07 (Fla. 2020) (outlining a two-part framework on stare-decisis issues). We have said that reliance is a critical consideration. Id. But as noted by the State, the Supreme Court's reasoning in Dobbs shows why reliance does not justify keeping T.W. In conducting a - 48 -

stare-decisis analysis in that case, the Supreme Court stressed that "[t]raditional reliance interests arise where advance planning of great precision is most obviously a necessity.'” Dobbs, 597 U.S. at 287 (first quoting Casey, 505 U.S. at 856 (joint opinion); and then citing Payne v. Tennessee, 501 U.S. 808, 828 (1991)). The Court went on to state that “those traditional reliance interests [a]re not implicated because getting an abortion is generally ‘unplanned activity,' and ‘reproductive planning could take virtually immediate account of any sudden restoration of state authority to ban abortions."" Id. at 288 (quoting Casey, 505 U.S. at 856). Finally, the Court rejected application of a more malleable and undefined form of reliance that focused on the relative social and economic effects of abortion. Id. at 288-89. In its view, this type of reliance was irrelevant to a proper stare-decisis framework. Id. We think that this analysis from Dobbs is in keeping with Poole. Indeed, in Poole, we expressed wariness for tests that are "malleable and do not lend themselves to objective, consistent, and predictable application." 297 So. 3d at 507 (criticizing North Florida Women's Health's multi-factor stare-decisis framework). And in the years since Poole issued, we have not employed the more malleable - 49 -

form of reliance that Dobbs declined to apply—the same sort of societal reliance interests now being advanced by Planned Parenthood. Apart from arguing reliance, Planned Parenthood does not offer any other valid reasons for keeping T.W. Accordingly, because Planned Parenthood has failed to demonstrate a valid reason for retaining T. W., we recede from it. We also recede from Gainesville Woman Care and North Florida Women's Health, which both applied T.W.'s flawed reasoning and offered no additional doctrinal justification for locating a right to abortion in the Privacy Clause. VII We now return to the specific facts of this case. Below, the trial court granted a temporary injunction, finding that Planned Parenthood would likely succeed in its constitutional challenge. Our holding, however, displaces the doctrinal justification for the trial court's decision. Planned Parenthood cannot demonstrate a likelihood of success on the merits of its claim, which alleged that the newly enacted statute was facially invalid under the Privacy Clause of the Florida Constitution. And since Planned Parenthood fails on this prong, it is not entitled to a temporary injunction. - 50 -

Although we do not adopt the reasoning of the First District, we approve the result it reached below. It is so ordered. MUÑIZ, C.J., and CANADY, COURIEL, and FRANCIS, JJ., concur. SASSO, J., concurs with an opinion. LABARGA, J., dissents with an opinion. NOT FINAL UNTIL TIME EXPIRES TO FILE REHEARING MOTION AND, IF FILED, DETERMINED. SASSO, J., concurring. I join the majority opinion because it correctly holds that the Florida Constitution does not contain a right to elective abortion. I write separately to explain why I believe it is appropriate to reach that decision considering the standing arguments raised by the State in the lower court proceedings and on appeal and as highlighted by Amici in this Court. In doing so, I will start with some observations regarding this Court's standing jurisprudence. I will then explain why I agree with the majority's decision to accept the State's waiver of any standing arguments here. Finally, I will explain why I believe, in the proper case, this Court should reconsider its standing precedent. - 51 -

I. Standing is the legal doctrine that defines when a litigant has a stake in a controversy sufficient to obtain judicial resolution of that controversy. The doctrine keeps us in our constitutional lane by ensuring we do not become “roving commissions assigned to pass judgment on the validity of the [State's] laws." See Broadrick v. Oklahoma, 413 U.S. 601, 611 (1973). At the federal level, standing requirements are derived from Article III of the United States Constitution's Case or Controversy Clause. Constitutional in origin, standing is therefore a jurisdictional prerequisite to a plaintiff's right to sue in federal court. See Indus. Servs. Grp., Inc. v. Dobson, 68 F.4th 155, 167 (4th Cir. 2023) ("It is axiomatic that standing is a threshold jurisdictional issue that must be determined before a court can consider the merits of a case." (citing Steel Co. v. Citizens for a Better Env't, 523 U.S. 83, 88 (1998))). For that reason, federal courts have the ability, and indeed the obligation, to address standing sua sponte even if a defendant has not raised the issue. See United States v. Hays, 515 U.S. 737, 742 (1995) ("[W]e are required to address [standing] even if the courts - 52 -

below have not passed on it, and even if the parties fail to raise the issue before us." (first alteration in original) (quoting FW/PBS, Inc. v. City of Dallas, 493 U.S. 215, 230-31 (1990))); Cent. States Se. & Sw. Areas Health & Welfare Fund v. Merck-Medco Managed Care, L.L.C., 433 F.3d 181, 198 (2d Cir. 2005) ("Because the standing issue goes to this Court's subject matter jurisdiction, it can be raised sua sponte."). Likewise, the question of standing is not subject to waiver. Hays, 515 U.S. at 742. At the state level, it is different. As it relates to standing, the Florida Constitution is textually distinct from the Federal Constitution because it does not contain an explicit cases and controversies clause. It should go without saying, then, that federal law does not control standing requirements in state courts. See ASARCO Inc. v. Kadish, 490 U.S. 605, 617 (1989) (noting that the constraints of Article III do not apply to state courts, and accordingly state courts are not bound by the limitations of a case or controversy). Even so, this Court has at times reflexively adopted federal standing tests without examining whether the Florida Constitution demands similar requirements. See, e.g., State v. J.P., 907 So. 2d 1101, 1113 n.4 (Fla. 2004) (adopting three-part standing - 53 -

test established by the United States Supreme Court in Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992)); Alterra Healthcare Corp. v. Est. of Shelley, 827 So. 2d 936, 941 (Fla. 2002) (adopting thirdparty standing test recognized by the United States Supreme Court). We have not done so consistently, though. At times, we have concluded that standing in Florida is less restrictive than at the federal level. For example, in Department of Revenue v. Kuhnlein, 646 So. 2d 717, 720 (Fla. 1994), we said that the doctrine of standing does not exist in Florida "in the rigid sense employed in the federal system." See also Coal. for Adequacy & Fairness in Sch. Funding, Inc. v. Chiles, 680 So. 2d 400, 403 (Fla. 1996) (noting that in Florida, unlike the federal system, the doctrine of standing has not been rigidly followed). Consistent with this observation, we have sometimes applied state-specific standing rules. See, e.g., Johnson v. State, 78 So. 3d 1305, 1314 (Fla. 2012) (holding a litigant has standing if "he or she reasonably expects to be affected by the outcome of the proceedings, either directly or indirectly” (quoting Hayes v. Guardianship of Thompson, 952 So. 2d 498, 505 (Fla. 2006))). Other times we have, either explicitly or implicitly, - 54 -

bypassed a standing analysis altogether. See, e.g., J.P., 907 So. 2d at 1113 ("Because the Second District never determined whether these juveniles have standing to assert the constitutional rights of their parents, we decline to rule on these claims." (footnote omitted)).21 Our inconsistent approach is especially evident in the context of third-party standing. Traditionally, this Court considered as well-settled the rule that one who is not himself denied some constitutional right or privilege cannot be heard to raise constitutional questions on behalf of some other person who may at some future time be affected. See, e.g., Steele v. Freel, 25 So. 2d 501, 503 (Fla. 1946). Eventually, though, we carved out exceptions. For example, in Jones v. State, 640 So. 2d 1084 (Fla. 1994), we determined that criminal defendants could raise the privacy rights 21. Despite the inconsistent application of various tests to determine whether a party has standing to pursue its claims, our standing precedent has been steady in one respect. We have always held that standing can be waived. See, e.g., Krivanek v. Take Back Tampa Pol. Comm., 625 So. 2d 840, 842 (Fla. 1993); Cowart v. City of West Palm Beach, 255 So. 2d 673, 675 (Fla. 1971). However, this is somewhat logically inconsistent, because we oftentimes have adopted federal standards ostensibly derived from the Federal Constitution without adopting the corresponding rule that standing is jurisdictional in nature and therefore not subject to waiver. - 55 -

of the female minors with whom they had sexual relations because the criminal defendants "st[oo]d to lose from the outcome of this case and yet they ha[d] no other effective avenue for preserving their rights." Id. at 1085 (referencing Stall v. State, 570 So. 2d 257 (Fla. 1990), for "vicarious standing" requirements). Later, in Alterra, we applied a federal test to determine when parties can sue on behalf of rights belonging to others. 827 So. 2d at 941-42. The test, as laid out in Alterra, goes like this: a litigant may bring an action on behalf of a third party if 1) the litigant suffered an “injury in fact,” thus giving him or her a "sufficiently concrete interest" in the outcome of the issue in dispute; 2) the litigant has a close relation to the third party; and 3) there is some hindrance to the third party's ability to protect his or her own interests. Id. (quoting Powers v. Ohio, 499 U.S. 400, 410-11 (1991)). But we applied this test in Alterra without explicitly adopting it as doctrine and without addressing our previous application of the Stall standard in Jones. Only a year after Alterra was decided, we again backed away from applying federal standing tests at all in Allstate Insurance Co. v. Kaklamanos, 843 So. 2d 885 (Fla. 2003). There, we reiterated - 56

that the doctrine of standing does not exist in Florida "in the rigid sense employed in the federal system." Id. at 895 (quoting Kuhnlein, 646 So. 2d at 720). This made room for our conclusion that an insured could maintain an action against the insurer for nonpayment of personal injury protection automotive insurance benefits even though the insured had not paid the medical bills in question and the medical provider had not instituted legal action against the insured for nonpayment. Id. at 897. And later, we appeared to cabin Alterra to the employment context in Weaver v. Myers, 229 So. 3d 1118, 1129 (Fla. 2017). In that same case, we also cited favorably the “vicarious standing" test from Jones, a case that preceded Alterra.2² Id. 22. Our doctrinal inconsistency in third-party standing cases is not the only aspect of our standing jurisprudence that has been unclear. For example, as noted above we adopted the three-part standing test established by the United States Supreme Court in Lujan v. Defenders of Wildlife, 504 U.S. 555, in J.P. But a few years later in Johnson, we stated broadly that “standing ‘requires a would-be litigant to demonstrate that he or she reasonably expects to be affected by the outcome of the proceedings, either directly or indirectly.'" 78 So. 3d at 1314 (quoting Hayes, 952 So. 2d at 505). We did so without any reference to our previous adoption of the Lujan test and over the dissenting justices' observation that the moving party would have met that standing requirement. And although we have, with more consistency, adhered to the Rickman v. Whitehurst, 74 So. 205 (Fla. 1917), rule when litigants have - 57 -

II. With that background in mind, I now return to this case. It serves as a prime example of the challenges our doctrinal inconsistencies create for litigants and lower courts. In the trial court, the State argued Planned Parenthood lacked standing to challenge HB 5 because none of the plaintiffs could assert a personal right to privacy—instead, the plaintiffs sought to assert the privacy rights of their patients and/or customers. Working off the Alterra test, the State then argued Planned Parenthood could not meet the requirements for overcoming the general bar to third-party standing. In doing so, though, the State conceded that the second prong of the Alterra test (the close relationship requirement) was satisfied. In response, Planned Parenthood accepted the State's framing of the issue, arguing it could satisfy the Alterra test. This framework carried over to the trial court's order granting the challenged government action, we continue to carve out exceptions without a textual explanation justifying a new exception. See, e.g., Dep't of Admin. v. Horne, 269 So. 2d 659 (Fla. 1972) (citing federal precedent to carve out exception for "ordinary citizens and taxpayers" to pursue constitutional claims in certain circumstances even absent a showing of special injury to themselves). - 58 -

temporary injunction, where it applied the Alterra test and concluded that Planned Parenthood has "third-party standing to bring this suit on behalf of their actual and potential patients." Planned Parenthood of Sw. & Cent. Fla. v. State, No. 2022-CA-912, 2022 WL 2436704, at *17 (Fla. 2d Cir. Ct. July 5, 2022). But, in the First District, the court concluded that it did not need to address Petitioners' standing argument. Instead, the First District decided that Petitioners had not suffered irreparable harm sufficient to support the issuance of a temporary injunction. State v. Planned Parenthood of Sw. & Cent. Fla., 342 So. 3d 863, 867-68 (Fla. 1st DCA 2022). That takes us to the parties' briefing filed in this Court. The State reasserted its argument as to Planned Parenthood's standing to pursue its claims. But as the majority opinion notes, the State essentially conceded the issue of standing at oral argument, urging this Court to reach the merits. So why do we accept that concession? First, as the majority notes, this case has been litigated under the umbrella of this Court's abortion jurisprudence. See, e.g., Gainesville Woman Care, LLC v. State, 210 So. 3d 1243, 1253-54 (Fla. 2017); N. Fla. Women's - 59 -

Health & Counseling Servs., Inc. v. State, 866 So. 2d 612, 620 (Fla. 2003); In re T. W., 551 So. 2d 1186, 1188-89 (Fla. 1989). And our abortion jurisprudence falls into the category of cases where we have, without explaining why, skipped over a standing analysis altogether. As a result, we have neither directly addressed standing nor applied the Alterra test in any of our abortion cases. Instead, to the extent standing was considered, we seem to have collapsed the analysis into the grounds for obtaining a temporary injunction without considering which standing test to apply or whether an abortion provider can meet that test. See Gainesville Woman Care, 210 So. 3d at 1247 (“Petitioners have established a substantial likelihood of success on the merits, one of the requirements of granting a temporary injunction, as well as all other grounds for the entry of a temporary injunction.” (emphasis added)). For that reason, addressing standing alone here would have only added to the inconsistencies in our cases. Second, both parties have asked us to apply the federal thirdparty standing test as applied in Alterra. But as explained above, we have applied that test once. And, for many reasons, I question the wisdom of perpetuating the standard here. For one, I do not - 60

think we should apply federal standards to textually distinct provisions of the Florida Constitution without considering whether that standard is independently justified on state law grounds. For another, reflexively adopting the federal third-party standing test is particularly troublesome because, in federal courts, it has been inconsistently applied and widely criticized. See, e.g., June Med. Servs. L. L. C. v. Russo, 140 S. Ct. 2103, 2142-46 (2020) (Thomas, J., dissenting) (noting the test's inconsistent application, criticizing the characterization of third-party standing as prudential in nature, and concluding that third-party standing is inconsistent with the case-or-controversy requirement of Article III). Finally, and critically, neither party has challenged our characterization of standing as waivable rather than jurisdictional. Similarly, no party has offered an alternative standard to apply in the absence of Alterra or an argument as to whether Planned Parenthood fails to meet any alternative standard. As a result, I believe this Court properly reaches the merits of this case. III. While the State's concession takes care of this case, in future cases we should reconsider our standing precedents. Most - 61

fundamentally, we should consider from where our standing requirements are derived (spoiler alert-it is not the Federal Constitution). For example, is standing in Florida derived only from article V's conception of "judicial power"? See, e.g., Sons of Confederate Veterans v. Henry Cnty. Bd. of Comm'rs, 880 S.E.2d 168, 185-86 (Ga. 2022) (concluding that standing requirement arises from the Georgia Constitution's judicial power provision). Or does the access to courts provision of article I, section 21 have anything to say as to standing? Once decided, we will need to clarify the scope of any standing requirements, such as whether parties may assert both legal and factual injuries or whether only a legal injury will suffice. See, e.g., F. Andrew Hessick, Standing, Injury in Fact, and Private Rights, 93 Cornell L. Rev. 275, 280-81 (2008) (noting that at common law "factual harm without a legal injury was damnum absque injuria and provided no basis for relief"). We will also need to examine whether standing requirements are truly subject to waiver, or instead whether they are jurisdictional in nature. And finally, we will need to provide a principled methodology to help litigants understand which tests to apply when. - 62 -

To decide these and other issues related to standing, we will need the benefit of the adversarial process and thorough briefing. For that reason, and in the proper case, I encourage parties to critically assess these and other standing issues and present argument to this Court should the opportunity arise. LABARGA, J., dissenting. When the United States Supreme Court's decision in Dobbs23 “returned to the people and their elected representatives” “the authority to regulate abortion,” the decision did not force the state of Florida into uncharted territory. Instead, as history reveals and the majority acknowledges, the right to an abortion as a matter of Florida law was decided decades ago following two significant postRoe24 developments: (1) Florida voters' 1980 approval of an amendment to the Florida Constitution expressly providing a right of privacy, and (2) this Court's 1989 decision in In re T. W., 551 So. 2d 1186 (Fla. 1989), holding that Florida's express right of privacy 23. Dobbs v. Jackson Women's Health Org., 597 U.S. 215, 292 (2022). 24. Roe v. Wade, 410 U.S. 113 (1973). - 63

encompasses the right to an abortion. Nonetheless, today's majority decision recedes from decades of this Court's precedent and holds that "there is no basis under [Florida's express right of privacy] to invalidate” “a recently amended statute that shortens the window of time in which a physician may perform an abortion." Majority op. at 2. I strongly dissent. The Right of Privacy Adopted by Florida voters in 1980, article I, section 23 of the Florida Constitution provides: “Every natural person has the right to be let alone and free from governmental intrusion into the person's private life except as otherwise provided herein. This section shall not be construed to limit the public's right of access to public records and meetings as provided by law." Contrary to the majority, I am convinced that in 1980, a Florida voter would have understood that the proposed privacy amendment “included broad protections for abortion." Id. at 46. The right of privacy is no novel concept. More than 100 years ago, former Michigan Supreme Court Justice and noted legal scholar Thomas Cooley described “[t]he right to one's person" as the right "to be let alone." Thomas M. Cooley, A Treatise on the Law of - 64 -

Torts or the Wrongs Which Arise Independent of Contract 29 (2d ed. 1888). When the right "to be let alone" was discussed by Samuel D. Warren and Louis D. Brandeis in their Harvard Law Review article The Right to Privacy, the article primarily discussed the tort of invasion of privacy. See Samuel D. Warren & Louis D. Brandeis, The Right to Privacy, 4 Harv. L. Rev. 193 (1890). However, the authors also made the following salient observation: THAT the individual shall have full protection in person and in property is a principle as old as the common law; but it has been found necessary from time to time to define anew the exact nature and extent of such protection. Political, social, and economic changes entail the recognition of new rights, and the common law, in its eternal youth, grows to meet the demands of society. Id. at 193. Thus, even in early considerations of the right of privacy, scholars recognized that the right would be one that would evolve over time and it did. During the twentieth century, political, social, and economic changes led to a host of changes in the legal landscape, resulting in an expansion of the right of privacy far beyond a right to be free from unwanted public exposure. Without question, one of the most significant legal developments was the United States Supreme Court's recognition in Roe of an implicit right of privacy - 65 -

guaranteeing the right to an abortion as a matter of federal law. However, the right of privacy in the context of decisional autonomy took hold several years earlier in Griswold v. Connecticut, 381 U.S. 479 (1965) (holding that a state statute prohibiting the use of contraceptives violated the right to marital privacy). It is relevant to the analysis of the public understanding of the right of privacy that Griswold's expansion of privacy to reach decisional autonomy occurred more than seven years before Roe and fifteen years before Florida voters' adoption of the right of privacy as a matter of state constitutional law. The State's argument, that the sole context for Florida's right of privacy is informational privacy, seems to have been a step too far even for the majority. Nonetheless, the majority concludes that the language of "shall not be construed to limit the public's right of access to public records and meetings as provided by law" provides context that "do[es] not lend support to a claim that voters clearly understood abortion to be part and parcel of the rights recognized" under the right of privacy. Majority op. at 23. What is more, it reaches this conclusion despite substantial evidence that - 66 -

overwhelmingly supports the conclusion that the public understood the right of privacy to encompass the right to an abortion. Abortion as a Private Matter Before turning to the public understanding of the right of privacy, I write to address the majority's suggestion that abortion is ultimately not a private matter because “the procedure itself include[s] medical intervention and require[s] both the presence and intrusion of others.” Id. at 21 (citing Roe, 410 U.S. at 172 (Rehnquist, J., dissenting)). The majority acknowledges that an abortion "include[s] medical intervention,” see id., but beyond merely “includ[ing] medical intervention,” Florida’s statutes regulating abortion—then and now-require that the procedure be performed by a physician. See § 390.0111(2), Fla. Stat. (2023) (requiring that a termination of pregnancy be performed by a physician); Wright v. State, 351 So. 2d 708 (Fla. 1977) (pre-1980 decision from this Court upholding the conviction of a registered nurse who performed an abortion in violation of statute requiring that the procedure be performed by a physician). The “others” required to be present and involved in the procedure are physicians and medical personnel. In the interest of - 67 -

patient privacy, medical matters, including countless forms of medical procedures, are broadly afforded confidentiality protections with narrowly tailored exceptions. And notably, the involvement of a physician was not fatal to the privacy issue in Griswold, where the United States Supreme Court said: "This law [prohibiting the use of contraceptives], however, operates directly on an intimate relation of husband and wife and their physician's role in one aspect of that relation.” 381 U.S. at 482 (emphasis added). As a matter of necessity, physicians and medical personnel are routinely involved in a wide range of medical procedures, decisions, and other medical matters. The majority attempts to limit today's decision to the issue of abortion. See majority op. at 10 note 7 ("[T]oday we do not revisit our precedents outside the abortion context."). However, I fear that parties will rely on the majority's reasoning that the involvement of "others" in an abortion procedure defeats privacy-in attempts to undermine the broad privacy protections that are extended in the medical context. - 68

The Public Understanding of Roe v. Wade and the Right of Privacy The majority "acknowledge[s] that the public understanding of the term 'privacy' was, to some extent, informed by the United States Supreme Court's 1973 decision in Roe v. Wade," observing that "[following that decision, the phrase ‘right to privacy' gained new connotations that, for the first time, included the choice to have an abortion." Majority op. at 29 (emphasis added). The majority continues: In Planned Parenthood's view, this aspect of federal privacy jurisprudence should control our analysis here. Specifically, Planned Parenthood argues that Florida voters would have internalized Roe's definition of privacy when they voted for the privacy amendment. Indeed, Planned Parenthood has repeatedly asserted that the public understanding of this privacy definition was so engrained by 1980 that even without a specific mention of the term abortion, the Privacy Clause unequivocally included such a right by implication. Though this argument has some force, we cannot agree with Planned Parenthood that the backdrop of Roe conclusively establishes how a voter would have understood the provision. Id. at 29-30 (emphasis added). The majority concludes that "[c]onsequently, while Roe is relevant to our analysis of public meaning, it is not dispositive.” Id. at 32. I could not disagree more. - 69 -

The majority correctly recognizes the significant impact of Roe but stops short of the reality that Roe, having fundamentally changed the landscape of abortion rights on a national scale by redefining the scope of the right of privacy, was key to the public understanding of the right of privacy. During the seven-year interval between Roe and Florida voters' adoption of the right of privacy, I find it inconceivable that Americans and more specifically, Floridians were not aware that the right of privacy encompassed the right to an abortion. I agree with the petitioners that "the public understanding of [Roe's] privacy definition was so engrained by 1980 that even without a specific mention of the term abortion, the Privacy Clause unequivocally included such a right by implication." Id. at 29-30. In fact, the majority notes the controversial impact of Roe's reasoning, which reinforces that the public would have understood the right of privacy encompassed the right to an abortion. See id. at 14 (stating that Roe "left even progressive legal scholars baffled at how such a right could be gleaned from the constitution's text," and quoting Dobbs, 597 U.S. at 268 (“Roe's constitutional analysis was far outside the bounds of any reasonable interpretation of the - 70 -

various constitutional provisions to which it vaguely pointed.")). Contrary to the majority's position, evidence of the discussion surrounding Roe's reasoning is probative that the public understood the right of privacy to encompass the right to an abortion, and to so conclude does not require the "analytical leap" that the majority suggests it does. See id. at 31. Roe's opponents strenuously disapproved of basing the right to an abortion on the right of privacy; just as strenuously, Roe's supporters agreed with the Supreme Court's analysis. The common denominator is the understanding that the right to an abortion was tied to the right of privacy. The Nationwide Understanding of Roe and the Right of Privacy A decision that triggered pervasive national coverage, Roe was publicly discussed and debated in a way that most judicial decisions-even those decided by the United States Supreme Court are not. Media outlets across the nation reported on the landmark decision. On the day that Roe was decided, Associated Press articles announcing the seminal decision were published on the front pages of newspapers nationwide, many explaining that the decision "was - 71 -

based predominantly on what [Justice] Blackmun called a right of privacy."25 The nightly news programs on the major television networks also reported on Roe to an audience of tens of millions of viewers. The CBS Evening News with Walter Cronkite-a news program with, at that time, a consistent audience of twenty million or more viewers-covered the decision in a segment lasting more than three minutes, noting that “[t]he nine justices made abortion 25. See, e.g., Associated Press, Abortion Law Out, Mexico Ledger, Jan. 22, 1973, at 1; Associated Press, Barry Schweid, Abortion Law Struck by Court, The Courier News (Blytheville), Jan. 22, 1973, at 1; Associated Press, Abortions Allowed During 1st 6 Months, The Daily Chronicle (Centralia), Jan. 22, 1973, at 1; Associated Press, Barry Schweid, Blackmun Cites 'Right of Privacy' Court Bars Restricting Three-Month Abortions, The Index-Journal (Greenwood), Jan. 22, 1973, at 1; Associated Press, Court Strikes Down Abortion Law, The Neosho Daily News, Jan. 22, 1973, at 1; Associated Press, Court Strikes Down Abortion Law, Aiken Standard, Jan. 22, 1973, at 1; Associated Press, Court Strikes Down Texas Abortion Law, The Daily Times-News (Burlington), Jan. 22, 1973, at 1; Associated Press, Barry Schweid, Decision Will Affect 44 States, Del Rio News-Herald, Jan. 22, 1973, at 1; Associated Press, High Court Upholds Medical Abortions, Waukesha Daily Freeman, Jan. 22, 1973, at 1; Associated Press, Key Abortion Ruling by Supreme Court, Santa Cruz Sentinel, Jan. 22, 1973, at 1; Associated Press, Rule on Abortions, The Sedalia Democrat, Jan. 22, 1973, at 1; Associated Press, States Can't Block Early Abortions, The Bismarck Tribune, Jan. 22, 1973, at 1; Associated Press, Supreme Court Upholds Women's Abortion Rights, Fairbanks Daily News-Miner, Jan. 22, 1973, at 1; Associated Press, Texas Law Struck Down, 7-2, The Vernon Daily Record, Jan. 22, 1973, at 1-2. - 72 -

largely a private matter." CBS Evening News with Walter Cronkite, featuring George Herman in Washington (CBS television broadcast Jan. 22, 1973), https://www.youtube.com/watch?v=dccagy905yk (available on the CBS News YouTube channel). Throughout the nation, local journalists also published articles announcing and explaining Roe, as did opinion writers in making their arguments.26 In some articles, even the titles emphasized that the right to an abortion was based on the right of privacy. See, e.g., Supreme Court: Right of Privacy Includes Abortion, The Georgia Bulletin, Feb. 22, 1973, at 2 (calling Roe "one of the biggest news stories of the year"); Chicago Daily News Services, 'Privacy' is Reason for Abortion Ruling, Omaha World-Herald, 26. See, e.g., Bonni McKeown, Abortion's Status in West Virginia: Legal Question Affects Availability, Beckley Post-Herald, June 21, 1976, at 5 (explaining that Roe invalidated most states' abortion laws based on the balancing of the state's interests versus a woman's right of privacy); Washington Post, Editorial, Abortion: 19th Century, The Evening Times (Sayre), Feb. 3, 1973, at 4 (same); Joseph Kraft, Opinion, The High Court Speaks Up for Privacy, The Greensboro Record, Jan. 29, 1973, at 20 (same); Joseph Kraft, Opinion, Ruling Revealed Conservative Court, The Montana Standard, Jan. 28, 1973, at 6 (same); Joseph Kraft, Opinion, The Abortion Ruling, The Roanoke Times, Jan. 27, 1973, at 6 (same); Mary Smith, Abortion Ruling Draws Varied Reactions Here, The Lawton Constitution, Jan. 23, 1973, at 4 (same). - 73 -

Jan. 23, 1973, at 18; Associated Press, 'Right of Privacy' Cited in Action Against States, Reno Gazette-Journal, Jan. 22, 1973, at 1. Roe and its extensive coverage informed legislators and their constituents that the right of privacy under the U.S. Constitution protected the right to an abortion. Far from an issue that faded after one or two news cycles, abortion remained a prevalent issue during the seven years between Roe and the 1980 adoption of Florida's privacy amendment. The three-trimester framework laid out in Roe balanced the state's interests against the mother's right of privacy, and based on that balancing test, abortion laws in multiple states, including Florida, were struck down on federal privacy grounds. See Fla. Women's Med. Clinic, Inc. v. Smith, 478 F. Supp. 233 (S.D. Fla. 1979) (holding unconstitutional, on federal privacy grounds, administrative rules implementing Florida abortion statute); Jones v. Smith, 474 F. Supp. 1160 (S.D. Fla. 1979) (granting, on federal privacy grounds, a preliminary injunction against the enforcement of Florida abortion statute); Coe v. Gerstein, 376 F. Supp. 695 (S.D. Fla. 1973) (holding Florida abortion statute unconstitutional on federal privacy grounds). - 74 -

As courts, legislatures, and the public continued to confront the topic of abortion, the media continued to cover Roe, noting the historical and legal context: “In the famous 1973 Roe vs. Wade case, the U.S. Supreme Court ruled that choosing abortion was part of a woman's right to privacy";27 "The Supreme Court legalized abortions in 1973, basing its landmark ruling on a woman's right to privacy."28 In 1980, only two months before Florida's privacy amendment vote, a United States district court judge struck down North Dakota's new abortion law regulating first trimester abortions, applying Roe and stating that "[t]he decision to obtain an abortion free from governmental interference is a fundamental right founded 27. Kevin M. Russell, Letter to the Editor, Does The Bill Regulating Abortions Deny Women Their Rights?, The Record (Hackensack), June 17, 1979, at 105. 28. Associated Press, Top Court to Decide Abortion Law Rule, Gettysburg Times, Nov. 28, 1979, at 6; Associated Press, Abortion Issue Back Before Supreme Court, The Index-Journal (Greenwood), Nov. 27, 1979, at 8; Associated Press, Abortion Issue Goes Back to High Court, News-Journal (Mansfield), Nov. 27, 1979, at 7; Associated Press, Abortion Issue is Back Before the Supreme Court, Poughkeepsie Journal, Nov. 27, 1979, at 6; Associated Press, High Court to Rule on Abortion Issue, Daily Sitka Sentinel, Nov. 27, 1979, at 2. - 75 -

in the right of privacy implicit in the Constitution." Leigh v. Olson, 497 F. Supp. 1340, 1343 (D.N.D. 1980); Associated Press, Most of Abortion Law Tossed Out, The Bismarck Tribune, Sept. 30, 1980, at 1 (front-page newspaper article in North Dakota quoting the court's decision). Following Roe, pro-choice advocates praised the decision for recognizing a woman's right of privacy, while Catholic bishops and other pro-life advocates spoke out against Roe, asserting that the decision let the right of privacy outweigh the right to life: “In effect, the Court is saying that the right of privacy takes precedence over the right to life." U.S. Bishops Issue Message on Abortion, Panama City News-Herald, Mar. 4, 1973, at 40; Bishops Reject High Court's Abortion Ruling, Issue Pastoral Applications for Catholics, The True Voice (Omaha), Feb. 16, 1973, at 1.29 at 29. See also Katherine Lunine, Letter to the Editor, Preserve Constitutional Rights, The Journal News (Hamilton), Feb. 1, 1977, 4 (showing that pro-choice actors argue that government interference with abortion is limited by a woman's right of privacy); Associated Press, Abortion Ban Voted by House, The Corbin TimesTribune, Sept. 17, 1976, at 12 (same); Associated Press, Betty Anne Williams, Anti-Abortionists Stage Ban Rally in Washington, The Robesonian (Lumberton), Jan. 22, 1976, at 2 (same); Associated Press, 'March for Life' Again Seeks Amendment to Ban Abortion, The Index-Journal (Greenwood), Jan. 22, 1976, at 3 (same); Associated - 76

Ultimately, whether they supported the Supreme Court's decision in Roe or not, Americans in 1980 would have understood that the right of privacy encompassed the right to an abortion. The Public Understanding of Florida Voters in 1980 More specifically, and especially relevant to the present case, Florida media coverage after Roe illustrates that in 1980 Florida voters would have understood the privacy amendment to encompass the right to an abortion. The wealth of primary sources from Florida strongly indicates what voters would have known. Newspapers across Florida began reporting on Roe the day it was decided: January 22, 1973. In explaining the decision, these articles discussed the federal right of privacy as the basis for the right to an abortion. Adam Richardson, The Originalist Case for Why the Florida Constitution's Right of Privacy Protects the Right to an Abortion, 53 Stetson L. Rev. 101, 125 (2023). Like newspapers throughout the nation, Florida newspapers published an Associated Press, Washington Rally Marks Abortion Anniversary, The Times Record (Troy), Jan. 22, 1976, at 3 (same); United Press International, High Court 7-2 Ruling on Abortion Praised, Condemned, Traverse City Record-Eagle, Jan. 23, 1973, at 24 (same). - 77 -

Press article quoting Roe's pronouncement that the right of privacy "is broad enough to encompass a woman's decision whether or not to terminate her pregnancy." See, e.g., Associated Press, Court Strikes Down Abortion Laws, The Pensacola News, Jan. 22, 1973, at 1; Associated Press, High Court KOs Ban on Abortion, Tallahassee Democrat, Jan. 22, 1973, at 1. Coverage of Roe and of this broad privacy right also made the front pages of newspapers in Orlando and Fort Myers. See Washington Post Dispatch, High Court Nullifies Abortion Laws, Sentinel Star (Orlando), Jan. 23, 1973, at 1; Associated Press, Six-Month Abortions Upheld, Fort Myers NewsPress, Jan. 23, 1973, at 1. In 1980, the right of privacy and its inextricable connection to the right to an abortion continued to permeate Florida news. When Justice Douglas died in January 1980, Florida newspapers reported his legacy with mention of his majority opinion in Griswold as a precursor to Roe. Richardson, supra, at 131; James W. Fox Jr., A Historical and Originalist Defense of Abortion in Florida, 75 Rutgers U. L. Rev. 393, 427-28 (2023). For example, a Miami Herald article noted that after Griswold, "the [United States Supreme] court moved to rule, in 1973, that a woman in early pregnancy has a - 78 -

constitutional right of privacy to choose abortion without government interference." Aaron Epstein, William O. Douglas: Champion of Underdogs, Unpopular Ideas, The Miami Herald, Jan. 27, 1980, at 5-E. Florida news coverage of the United States Supreme Court continued with reports of abortion cases―and their right of privacy issues. In discussing the Supreme Court's 1980 oral arguments in H. L. v. Matheson, 450 U.S. 398 (1981), which involved parental notification of abortion, the Miami Herald reported that “[o]ut of this conflict between a minor's right to privacy and her parents' obligation to care for her has emerged a constitutional issue that was accepted Monday for review by the U.S. Supreme Court." Aaron Epstein, Court Will Examine Parents' Notification for Minor's Abortion, The Miami Herald, Feb. 26, 1980, at 10-A. And explaining the Court's decision in Harris v. McRae, 448 U.S. 297 (1980), which upheld the Hyde Amendment's restrictions on the use of federal funds to pay for an abortion, the Pensacola News reported that the decision "had nothing to do with the legality of abortion itself" because “[t]he Supreme Court legalized abortion in its landmark 1973 decision” in which "the court said a woman's right to privacy - 79 -

makes her decision to have an abortion a matter only for her and her doctor during the first three months of her pregnancy." Associated Press, High Court Rules on Abortions, The Pensacola News, June 30, 1980, at 1. Florida newspapers covered major party platforms, including their stances on abortion. These articles linked the abortion issue with the right of privacy. The Fort Lauderdale News and other Florida newspapers published a syndicated column indicating that although the Republican platform did not yet have a consensus on abortion, the Supreme Court had made its determination in 1973 by, in the author's view, “forging from a ‘privacy right' a scythe to mow down state laws that expressed various community judgments about abortion." See George Will, Opinion, Bridges to Cross; Bridges to Burn, Fort Lauderdale News, July 17, 1980, at 18A; Richardson, supra, at 132 n. 177 (observing that the column ran in Florida Today, Fort Myers News-Press, Palm Beach Post, Pensacola News, Sentinel Star (Orlando), St. Lucie News Tribune, St. Petersburg Times, Stuart News, and Tallahassee Democrat). Covering the Democratic platform, the St. Petersburg Times reported that delegates had voted for a platform statement opposing "government - 80 -

interference in the reproductive decisions of Americans" and "restrictions on funding for health services for the poor that deny poor women especially the right to exercise a constitutionallyguaranteed right to privacy." Charles Stafford, Kennedy Stirs Democrats with Rousing Call to Arms, St. Petersburg Times, Aug. 13, 1980, at 1-A (quoting the statement under the label “ABORTION”). Florida newspapers also covered statements by pro-choice activists and by pro-life activists that demonstrate both groups' understanding of abortion as part of the right of privacy. See Associated Press, Planned Parenthood Waving the Flag, The Tampa Tribune, Oct. 4, 1980, at 7-D (“In recent years we have faced an increasingly vocal and at times violent minority which seeks to deny all of us our fundamental rights of privacy and individual decisionmaking."); Carol Jeffares, Her Love of Life Makes Her Stand, Fight for It, The Tampa Tribune, Sept. 20, 1980, at 5-Pasco ("The abortion law is based on the woman's right to privacy. It says ‘a woman's right to privacy supersedes the fetus's life." "); Richardson, supra, at 132. With inflammatory language, both pro-choice and pro-life letters to the editor in Florida newspapers further demonstrate this understanding. See Joyce Tarnow, Letter to the Editor, Vote Out - 81

Anti-Abortionists, Fort Lauderdale News, Jan. 29, 1980, at 26-A ("The U.S. Constitution guarantees each of us the right of privacy, the right of religious freedom and the right to pursue happiness however we define it. Compulsory pregnancy is a denial of each of these rights."); Hugh Pope, Letter to the Editor, The Tampa TribuneTimes, Nov. 2, 1980, at 2-C (“There cannot be a more compelling reason for intelligent and patriotic Americans to vote Republican than to save lives! Stripped of all its sugarcoated slogans-freedom of choice[,]' [] 'woman's right to privacy[,]' [] etc., etc., abortion is legalized murder.”). The foregoing primary sources from Florida and from across the United States are examples of many. These sources should not be overlooked, and their impact should not be undervalued. In a quest to uncover the original public meaning of the Florida Constitution's Privacy Clause, they reveal that Roe was widely known for its holding and for its reasoning. Thus, in 1980, Florida voters would have understood the right of privacy as encompassing the right to an abortion. I hasten to add that the coverage discussed above, specifically connecting Roe and the right to an abortion to the right of privacy, - 82 -

occurred at a time when Americans relied heavily on print media and national news broadcasts. Florida Courts Acknowledge Right of Privacy Under Roe By the time Florida voters adopted the privacy amendment in 1980, Florida court decisions had repeatedly acknowledged the right of privacy expanded under federal law by Roe. While these decisions did not conclude that a right of privacy existed on state law grounds, they do provide further support that the public would have understood the link between the right to an abortion and the right of privacy. In 1977, this Court stated that “Justice Blackmun's articulation in Roe v. Wade of the limited scope of the right to privacy remains the current state of the law." Laird v. State, 342 So. 2d 962, 965 (Fla. 1977) (emphasis added) (rejecting argument that a right of privacy protected the possession of marijuana in the home). Even the dissenting opinion in Laird observed: "A constitutional right to privacy has been clearly established by the United States Supreme Court in . . . Roe . . . .” Id. at 966 (Adkins, J., dissenting) (emphasis added). - 83 -

In Jones v. Smith, 278 So. 2d 339 (Fla. 4th DCA 1973), cert. denied, Jones v. Smith, 415 U.S. 958 (1974), a case involving the abortion context, the Fourth District Court of Appeal rejected the claim of a putative father that he was entitled to prevent the mother from obtaining an abortion. The district court rejected that argument, saying: The recent decisions of the United States Supreme Court in Roe v. Wade . . . and Doe v. Bolton [410 U.S. 179 (1973)], while dealing with the constitutionality of statutes, set forth what we perceive to be the essential and underlying factor in the determination of this appeal. That factor is the "right of privacy” of the mother. Id. at 341 (emphasis added). Additionally, in discussing the right of privacy, the district court noted an observation made by the United States Supreme Court in Union Pacific Railway Co. v. Botsford, 141 U.S. 250, 251 (1891): “As well said by Judge Cooley, The right to one's person may be said to be a right of complete immunity to be let alone."" 278 So. 2d at 342 (quoting Babbitz v. McCann, 310 F. Supp. 293, 299 (E.D. Wisc. 1970)). Moreover, in Wright, the statute at issue required that an abortion be performed by a physician and at an approved facility. The petitioner, a registered nurse, challenged the approved facility - 84 -

requirement on the basis that under Roe and other federal decisions, the requirement violated the right of privacy. 351 So. 2d at 710. This Court ultimately upheld the petitioner's conviction on the ground that the statute constitutionally prohibited nonphysicians from performing an abortion. Despite concluding that the approved facility requirement was unconstitutional, this Court rejected the petitioner's privacy argument, stating: “The right to privacy in the abortion decision, recognized in Roe . . . as belonging to the pregnant woman in consultation with her physician, gives way to state power to regulate as the embryo or fetus develops." Id. at 710.30 30. Other decisions not involving abortion-related issues also recognized the right of privacy established in Roe. See, e.g., Rodriguez v. State, 378 So. 2d 7, 8 n.2 (Fla. 2d DCA 1979) (“In Roe, the court balanced the fundamental right to privacy of a woman's decision whether or not to terminate pregnancy against state interest to limit that right to safeguard health and potential life.”); Franklin v. White Egret Condo., Inc., 358 So. 2d 1084, 1089 (Fla. 4th DCA 1977) (observing on motion for rehearing that “[t]he right to be free of unwarranted interference with the decision to have children has been identified on numerous occasions by the United States Supreme Court as one of the matters protected by the right of privacy"); Day v. Nationwide Mut. Ins. Co., 328 So. 2d 560, 562 (Fla. 2d DCA 1976) (“The decision to have an abortion during the first trimester has been held to be private and personal to the individual woman. The primary interest, at least in the early stages of pregnancy, is that of the woman and her right to privacy." (citations - 85

Roe and the Privacy Amendment Debate According to the majority, the relative absence of the topic of abortion from the debate over Florida's proposed privacy amendment is evidence that the public did not understand that the right to an abortion was included in the scope of the proposed right of privacy. See majority op. at 41-42 (citing Fox, supra, at 443-44). However, Professor Fox explains why the topic of abortion was not a part of the amendment debate: Abortion would only have been debated if its coverage within the right to privacy were in dispute or were not yet established in law. But as of 1980 the protection of abortion through the right to privacy was the established law. It would hardly make sense for debates about section 23 to invest time and effort re-arguing the reasoning of Roe, let alone arguing that the terms “right to privacy," "right to be let alone," and "free from governmental intrusion" would plainly mean what they already meant in federal law. Fox, supra, at 442-43 (emphasis omitted). Indeed, Roe's extension of the right of privacy to the abortion context so dominated the abortion discussion that it would have been well understood that omitted)). Again, these cases are relevant to demonstrate that after Roe, and before voters adopted Florida's privacy amendment, the right to an abortion as a matter of a right of privacy would have been well understood. - 86 -

the right of privacy adopted by Florida voters included the right to an abortion. In re T.W. [S]tate courts cannot rest when they have afforded their citizens the full protections of the federal Constitution. State constitutions, too, are a font of individual liberties, their protections often extending beyond those required by the Supreme Court's interpretation of federal law. The legal revolution which has brought federal law to the fore must not be allowed to inhibit the independent protective force of state law-for without it, the full realization of our liberties cannot be guaranteed. William J. Brennan, Jr., State Constitutions and the Protection of Individual Rights, 90 Harv. L. Rev. 489, 491 (1977). Indeed, "[t]he citizens of Florida opted for more protection from governmental intrusion when they approved article I, section 23 of the Florida Constitution. This amendment is an independent, freestanding constitutional provision which declares the fundamental right to privacy." Winfield v. Div. of Pari-Mutuel Wagering, 477 So. 2d 544, 548 (Fla. 1985). The amendment "was intentionally phrased in strong terms . in order to make the privacy right as strong as possible." Id. It was in the context of Florida's broad right of privacy that almost thirty-five years ago, this Court held as a matter of state - 87 -

constitutional law that "Florida's privacy provision is clearly implicated in a woman's decision of whether or not to continue her pregnancy." T. W., 551 So. 2d at 1192. T.W. explained: “[W]e have said that the [privacy] amendment provides ‘an explicit textual foundation for those privacy interests inherent in the concept of liberty which may not otherwise be protected by specific constitutional provisions."" Id. (quoting Rasmussen v. S. Fla. Blood Serv., 500 So. 2d 533, 536 (Fla. 1987)). Unfortunately, the majority's decision to recede from T. W. and its progeny constitutes the rejection of a “decades-long line of cases hold[ing] that the Privacy Clause ‘embraces more privacy interests, and extends more protection to the individual in those interests, than [does] the federal Constitution."" Petitioners' Opening Brief at 41 (emphases omitted) (quoting T.W., 551 So. 2d at 1192). The decision is an affront to this state's tradition of embracing a broad scope of the right of privacy.31 31. In 2012, Florida reaffirmed this tradition when voters rejected a state constitutional amendment that would have narrowed protections for abortion rights in Florida by requiring that the protections be no greater than those provided under federal law. Additionally, the amendment would have overruled T. W. and other decisions concluding that Florida protections for abortion rights - 88 -

In deciding to reexamine T. W. and ultimately to recede from T.W. and its progeny, the majority states: "Since Roe featured prominently in T.W., we think it fair to also point out that the T. W. majority did not examine or offer a reasoned response to the existing criticism of that decision or consider whether it was doctrinally coherent. This was a significant misstep because Roe did not provide a settled definition of privacy rights." Majority op. at 13-14. I disagree. T. W. did acknowledge that "the workability of the trimester system and the soundness of Roe itself have been seriously questioned in Webster v. Reproductive Health Services, 492 U.S. 490 (1989).” T.W., 551 So. 2d at 1190. However, this Court correctly exceed those provided under federal law. In a decisive vote, more than fifty-five percent of Florida voters rejected the amendment. See Initiative Information: Prohibition on Public Funding of Abortions; Construction of Abortion Rights, Fla. Dep't of State, Division of Elections, https://dos.elections.myflorida.com/initiatives/initdetail.asp?accou nt=10&seqnum=82 (last visited Mar. 19, 2024). While the petitioners conceded during the oral argument in this case that Florida voters' rejection of the abortion amendment in 2012 was not relevant to the public understanding of the right of privacy adopted in 1980, the 2012 amendment rejection is still relevant to an understanding of Florida's tradition with respect to the right of privacy. - 89 -

observed that “[Roe] for now remains the federal law." See id. As such, this Court was not obligated in T.W. to “examine or offer a reasoned response to the existing criticism of [Roe] or consider whether it was doctrinally coherent." Majority op. at 13-14. It was "three years after T. W." and almost twelve years after Florida voters' 1980 adoption of the right of privacy that “the U.S. Supreme Court abandoned Roe's position that the right to abortion was grounded in any sort of [federal] privacy right." See id. at 15 (emphasis added) (citing Planned Parenthood of Se. Penn. v. Casey, 505 U.S. 833, 846 (1992)). Even then, the United States Supreme Court did not abandon Roe's “essential holding." Casey, 505 U.S. at 846. I reemphasize that T. W. was decided on state law grounds and with a clear understanding of the breadth of Florida's right of privacy as discussed in Winfield. To be certain, Roe was fundamental to the public understanding of the right of privacy as encompassing the right to an abortion. However, T. W. did not rely on Roe or the federal constitution to determine that Florida's right of privacy included the right to an abortion. See T.W., 551 So. 2d at 1196 ("We expressly decide this case on state law grounds and cite federal precedent only to the extent that it illuminates Florida - 90 -

law."). Because this Court based its decision squarely on Florida law, there is no basis for upending decades of precedent that give effect to Florida's broad right of privacy. Beyond Today's Decision The impact of today's decision extends far beyond the fifteenweek ban at issue in this case. By operation of state statute, the majority's decision will result in even more stringent abortion restrictions in this state. While not before this Court in the present case, it is an irrefutable effect of today's decision that chapter 202321, Laws of Florida, also known as the Heartbeat Protection Act, will take effect in short order. Chapter 2023-21 amends section 390.0111, Florida Statutes (among other statutes), and with limited exceptions, it bans abortions beyond the gestational age of six weeks. The Act provides that the ban will take effect thirty days after any of the following events: (1) a decision by this Court holding that Florida's constitutional right to privacy does not include a right to abortion; (2) a decision by this Court in the present case allowing the fifteen-week ban to remain in effect; (3) an amendment to the Florida Constitution clarifying that Florida's constitutional right of privacy - 91 -

does not include the right to an abortion; or (4) a decision from this Court after March 7, 2023, that recedes in whole or part from any of the following: T.W., North Florida Women's Health v. State, 866 So. 2d 612 (Fla. 2003), and Gainesville Woman Care, LLC v. State, 210 So. 3d 1243 (Fla. 2017). See ch. 2023-21, § 9, Laws of Fla. Today's decision implicates three of these four events, meaning that the Act's six-week ban will take effect in thirty days. “The document that the [majority] releases [today] is in the form of a judicial opinion interpreting a [provision of the Florida Constitution]. Bostock v. Clayton Co., 590 U.S. 644, 683 (2020) (Alito, J., dissenting). However, I lament that what the majority has done today supplants Florida voters' understandingthen and now that the right of privacy includes the right to an abortion. Conclusion "" The majority concludes that the public understanding of the right of privacy did not encompass the right to an abortion. However, the dominance of Roe in the public discourse makes it inconceivable that in 1980, Florida voters did not associate abortion with the right of privacy. - 92 -

Because of this, and with deep dismay at the action the majority takes today, I dissent. Application for Review of the Decision of the District Court of Appeal Direct Conflict of Decisions First District - Case No. 1D22-2034 (Leon County) Whitney Leigh White, Jennifer Dalven, and Johanna Zacarias of American Civil Liberties Union Foundation, New York, New York, for Petitioners Gainesville Woman Care, LLC, Indian Rocks Woman's Center, Inc., St. Petersburg Woman's Health Center, Inc., and Tampa Woman's Health Center, Inc., Autumn Katz and Caroline Sacerdote of Center for Reproductive Rights, New York, New York, for Petitioner A Woman's Choice of Jacksonville, Inc. Jennifer Sandman of Planned Parenthood Federation of America, New York, New York, for Petitioners Planned Parenthood of Southwest and Central Florida, Planned Parenthood of South, East, and North Florida, and Shelly Hsiao-Ying Tien, M.D., M.P.H. April A. Otterberg and Shoba Pillay of Jenner & Block LLP, Chicago, Illinois; and Daniel Tilley of American Civil Liberties Union Foundation of Florida, Miami, Florida; Benjamin James Stevenson, American Civil Liberties Union Foundation of Florida, Pensacola, Florida, and Nicholas L.V. Warren of American Civil Liberties Union Foundation of Florida, Inc., Tallahassee, Florida, for Petitioners - 93 -

Ashley Moody, Attorney General, Henry C. Whitaker, Solicitor General, Jeffrey Paul DeSousa, Chief Deputy Solicitor General, Daniel William Bell, Chief Deputy Solicitor General, Nathan A. Forrester, Senior Deputy Solicitor General, David M. Costello, Deputy Solicitor General, Darrick W. Monson, Assistant Solicitor General, Zachary Grouev, Solicitor General Fellow, John M. Guard, Chief Deputy Attorney General, James H. Percival, Chief of Staff, and Natalie P. Christmas, Assistant Attorney General, Office of the Attorney General Tallahassee, Florida, for Respondent Brad F. Barrios of Turkel Cuva Barrios, P.A., Tampa, Florida, for Amici Curiae Law Professors Jonathan B. Miller and Hilary Burke Chan of Public Rights Project, Oakland, California; and Matthew A. Goldberger of Matthew A. Goldberger, P.A., West Palm Beach, Florida, for Amici Curiae Current and Former Elected Representatives for Reproductive Justice Kimberly A. Parker, Lesley F. McColl, and Aleksandr Sverdlik of Wilmer Cutler Pickering Hale and Dorr LLP, Washington, District of Columbia, and Meghan G. Wingert of Wilmer Cutler Pickering Hale and Dorr LLP, New York, New York; and Sean Shaw of Swope Rodante, Tampa, Florida, for Amici Curiae American College of Obstetricians and Gynecologists, American Medical Association, and Society for Maternal-Fetal Medicine Miranda Schiller, Sarah M. Sternlieb, Robert Niles-Weed, and Elizabeth McLean of Weil, Gotshal & Manges LLP, New York, New York, Charlotte McFaddin and Caroline Elvig of Weil, Gotshal & Manges LLP, Washington, District of Columbia, and Edward Soto of Weil, Gotshal & Manges LLP, Miami, Florida, - 94 -

for Amicus Curiae Floridians for Reproductive Freedom Angela C. Vigil, Robert H. Moore, and Paul Chander of Baker & McKenzie LLP, Miami, Florida; and Francisca D. Fajana of LatinoJustice PRLDEF, New York, New York, and Emily M. Galindo of LatinoJustice PRLDEF, Orlando, Florida, for Amici Curiae LatinoJustice PRLDEF, Florida Access Network, National Latina Institute for Reproductive Justice, Esperanza United, and A.L. Brian J. Stack and Robert Harris of Stack Fernandez & Harris, P.A., Miami, Florida; and Sarah B. Gutman, Lilianna Rembar, and Caroline Soussloff of Cleary Gottlieb Steen & Hamilton, New York, New York, and Jennifer Kennedy Park of Cleary Gottlieb Steen & Hamilton, San Francisco, California, for Amici Curiae Sanctuary for Families, Legal Momentum, The National Organization for Women Foundation, The Rapid Benefits Group Fund, Women for Abortion and Reproductive Rights, Margaret A. Baldwin, JD, Professor Cyra Choudhury, Professor Donna K. Coker, Professor Zanita E. Fenton, Doctor Kathryn M. Nowotny, PhD, and Jodi Russell Eugene M. Gelernter and Caitlin A. Ross of Patterson Belknap Webb & Tyler LLP, New York, New York; and Courtney Brewer of The Mills Firm, P.A., Tallahassee, Florida, for Amici Curiae National Council of Jewish Women, Religious Coalition for Reproductive Choice, Catholics for Choice, Metropolitan Community Churches, National Council of Jewish Women - Greater Miami Section, National Council of Jewish Women - Palm Beach Section, National Council of Jewish Women - Sarasota Manatee Section, National Council of Jewish Women - Kendall Section, National Council of Jewish Women - Valencia Shores Section, Reconstructionist Rabbinical Association, Women's Rabbinic Network, Moving Traditions, Avodah, Bend the Arc: A Jewish Partnership for Justice, Jewish Council for Public Affairs, Jewish Orthodox - 95 -

Feminist Alliance, Union for Reform Judaism, Central Conference of American Rabbis, Men of Reform Judaism, Women of Reform Judaism, Rabbinical Assembly, Society for Humanistic Judaism, Muslim Women's Organization, Hindus for Human Rights, Sadhana: Coalition of Progressive Hindus, Women's Alliance for Theology, Ethics, and Ritual (WATER), SACRED (Spiritual Alliance of Communities for Reproductive Dignity), Faith in Public Life, and Florida Interfaith Coalition for Reproductive Health and Justice Jordan E. Pratt and Christine K. Pratt of First Liberty Institute, Washington, District of Columbia, for Amicus Curiae National Institute of Family and Life Advocates Alan Lawson, Paul C. Huck, Jr., Jason Gonzalez, Amber Stoner Nunnally, and Caroline May Poor of Lawson Huck Gonzalez, PLLC, Tallahassee, Florida, for Amicus Curiae Former State Representative John Grant Christopher Green, University, Mississippi; and Antony B. Kolenc, Naples, Florida, for Amici Curiae Scholars on original meaning in State Constitutional Law Lynn Fitch, Attorney General, Scott G. Stewart, Solicitor General, and Justin L. Matheny, Deputy Solicitor General, Mississippi Attorney General's Office, Jackson, Mississippi; and Samuel J. Salario, Jr. of Lawson Huck Gonzalez, PLLC, Tampa, Florida, for Amici Curiae Mississippi, Alabama, Arkansas, Georgia, Idaho, Indiana, Iowa, Kentucky, Louisiana, Missouri, Montana, Nebraska, North Dakota, Ohio, South Carolina, South Dakota, Texas, Utah, and West Virginia Stephen C. Emmanuel of Ausley McMullen, Tallahassee, Florida, - 96

for Amici Curiae Florida Conference of Catholic Bishops and the Florida Baptist Convention Jay Alan Sekulow, Jordan Sekulow, and Olivia F. Summers of American Center for Law & Justice, Washington, District of Columbia; and Edward L. White III of American Center for Law & Justice, Ann Arbor, Michigan, for Amicus Curiae Charlotte Lozier Institute Christopher E. Mills of Spero Law LLC, Charleston, South Carolina; and Chad Mizelle, Tampa, Florida, for Amicus Curiae American College of Pediatricians Edward M. Wenger of Holtzman Vogel Baran Torchinsky & Josefiak, PLLC, Washington, District of Columbia, for Amicus Curiae American Cornerstone Institute Carlos A. Rey, General Counsel, Kyle E. Gray, Deputy General Counsel, The Florida Senate, David Axelman, General Counsel, and J. Michael Maida, Deputy General Counsel, The Florida House of Representatives, Tallahassee, Florida, for Amicus Curiae The Florida Legislature Kenneth L. Connor of Connor & Connor, LLC, Aiken, South Carolina, for Amicus Curiae Liberty Counsel Action S. Dresden Brunner of S. Dresden Brunner, P.A., Naples, Florida, for Amicus Curiae The Prolife Center at the University of St. Thomas (MN) Patrick Leduc of Law Offices of Patrick Leduc, P.A., Tampa, Florida, - 97 -

for Amicus Curiae American Association of Pro-Life Obstetricians and Gynecologists Mathew D. Staver, Anita L. Staver, Horatio G. Mihet, and Hugh C. Phillips of Liberty Counsel, Orlando, Florida, for Amici Curiae Frederick Douglass Foundation, The National Hispanic Christian Leadership Conference, Fiona Jackson Center for Pregnancy, and Issues4life Foundation D. Kent Safriet of Holtzman Vogel Baran Torchinsky & Josefiak, PLLC, Tallahassee, Florida, for Amicus Curiae Susan B. Anthony Pro-Life America Denise M. Harle of Alliance Defending Freedom, Lawrenceville, Georgia, and Joshua L. Rogers of Alliance Defending Freedom, Scottsdale, Arizona, for Amicus Curiae Concerned Women for America - 98 -