It doesn't take a genius to figure out that conservative states tend to have more restrictive laws governing abortion while liberal states tend to have more permissive laws, right? Well, <a href="http://slate.msn.com//?id=2074736">not exactly</a>. The Arizona Supreme Court, not exactly a bastion of liberal thinking, recently ruled that the state Medicaid program must fund medically necessary abortions for women who don't have the means to pay for them. And Arizona is hardly an isolated case. This win for pro-choice advocates was the latest in a concerted state-by-state drive to undermine federal abortion decisions. Since 1980, when the U.S. Supreme Court ruled 5-4, in Harris v. McRae, that the federal Constitution doesn't require Medicaid to pay for medically necessary abortions, pro-choice groups have been asking state courts to upend their funding restrictions by rooting the right to choose in their own constitutions. "Ignore McRae," goes the argument. "Our state constitution requires something more." The strategy seems to be working so well primarily because pro-life groups in the United States tend to focus their efforts on the national political and legal scene, with an emphasis on overturning, or at least limiting, Roe v. Wade. Meanwhile, pro-choice groups have been quietly going about their business at the state level with striking success, having already won 15 of the 21 suits they have brought in state courts around the country.