Because "Roe v. Wade" left ill-defined or derivative just who could be a medical caregiver for pregnant women, courts struggled in the post-Roe medico-legal environment to decide just who could be a medical advisor in this newly recognized zone of privacy. The courts also were challenged to balance individual privacy rights, state interest in health and potential life, and medical authority when dealing with alternative caregivers. This article examines five court cases involving traditional midwives in the 1970s in California and in the 1990s in New York. The cases afford the opportunity to examine emerging legal definitions of medical caregivers and the success or failure of certain forms of resistance to these definitions. (Contains 59 notes.)