they brought as-applied challenges in mccallen and prevailed. they brought their as-applied challenge in el paso and did not prevail. and the killeen clinic did not seek as-applied relief. indeed, if there are any future concerns, asapplied challenges can be raised. for instance, the wide swath of area in west texas that does not have an abortion clinic today, there was no asapplied relief sought in this case. and if there were if it would turn out that there were going to be an issue in that area, a future asapplied challenge could address that concern. justice ginsburg: well, that's the problem. once a clinic closes you said mccallen reopened, but that was very swift. once a clinic closes, equipment are gone, the doctors are gone, you can't reinstate it tomorrow. it won't be there. there will be no remedy for that woman who succeeds in the asapplied challenge. mr. keller: mr. chief justice, my time has expired, if may address it. chief justice roberts: sure. mr. keller: except even there, the clinic was not just closed for a single day. it was

annually, and there are going to be at least eight other ascs in texas, plus the tenth facility, the mccallen facility, that obtained asapplied relief, it does not stretch credulity to believe that those remaining facilities would suffice to meet the demand for abortions. justice breyer: and you asked to put in this evidence, and then the court said no, we will not let you put in the evidence? mr. keller: we didn't put in the evidence because petitioners bore the burden justice breyer: i asked, did you ask to put in this evidence? mr. keller: no. justice breyer: no. thank you very much. okay. i'd like to go back to the the question that justice ginsburg was asking, which is about what is the benefit of this procedure. there are two laws. i am focusing on the first law. the first law says that a doctor at the abortion clinic must have admitting privileges in a hospital miles within that -- 30 miles within that -- nearby, right? mr. keller: correct. justice breyer: okay. prior to that law, the law was that the clinic had to have a working arrangement to transfer such a patient, correct? i'm jus