The latter complaint is what is most germane for the State Board of Healing Arts, which licenses and oversees physicians in the state.
Operation Rescue relied on medical records from Michelle Armesto, a Topeka resident, for its complaint. Armesto testified last month before a legislative panel about her experience.
Armesto, a 22-year-old, told lawmakers how she was the victim of a coerced, and apparently illegal, abortion at Tiller's center four years ago.
After pressure from her parents, Armesto went to the abortion business. She says she was denied the opportunity to view an ultrasound on her baby before an out-of-state abortion practitioner killed the child with an injection of poison.
She said that she was not able to sign consent papers until after the abortion process had started and that the only exams she received happened afterwards.
"Tiller now faces two Board of Healing Arts investigations that could cost him his license," OR president Troy Newman told LifeNews.com.
"He faces 19 criminal counts of illegal late-term abortions that could cost him huge fines, and he faces a grand jury investigation that could net literally hundreds of additional counts of illegal abortions from the past five years that could cost him his freedom," Newman added.
Armesto released her medical records to Operation Rescue for the purpose of filing the complaint, which alleges 14 suspected violations including beginning the abortion procedure without having taken a medical history or obtaining her consent
It also alleges that Tiller associate abortion practitioner Shelley Sella ignored the legal requirement that she meet with the patient prior to the abortion. Sella is also accused of violating the 24-hour waiting period and failing to provide follow-up contact or care.
Additionally, the complaint contends Sella falsified the determination of non-viability in Armesto's 24-week-old unborn baby in order to avoid having to comply with the laws restricting abortions on viable unborn children.
Tiller was included in the complaint because, as the Medical Director of Women's Health Care Services, he is responsible for all medical treatment and care conducted at his facility.
A second complaint against Tiller and abortion practitioner Ann Kristin Neuhaus is being advanced to a Peer Review Board. That complaint alleged that Tiller and Neuhaus had an illegal financial affiliation that they formed in order to do abortions past viability.
"This is a full court press against an abortion industry that has too long operated as if they are above the law. It is past time that these people were brought to justice," Newman said.