In June Medical Services v. Russo, 591 U.S. 299 (2020), the U.S. Supreme Court held that Louisiana’s Act 620, which required any doctor performing abortions to have “active admitting privileges” at a nearby hospital within 30 miles, imposed an unconstitutional undue burden under the Fourteenth Amendment because the state’s evidence showed the regulation would drastically reduce the number and geographic distribution of abortion providers with minimal health benefit, thus placing substantial obstacles in the path of those seeking legal abortions.
The undue burden test established by Planned Parenthood v. Casey (1992) and also applied in Whole Woman’s Health v. Hellerstedt, was overruled by the U.S. Supreme Court in Dobbs v. Jackson Women’s Health Organization, in 2022 citing ambiguity and its difficulty to apply to cases in a consistent manner.