West Alabama Women's Center v. Williamson (11th Cir. 2018)

In West Alabama Women’s Center v. Williamson, 900 F.3d 1310 (11th Cir. 2018), the Eleventh Circuit examined the constitutionality of Alabama’s Unborn Child Protection from Dismemberment Abortion Act. The law sought to ban dilation and evacuation (D&E) procedures, a standard method utilized in most second-trimester abortions and miscarriages. Represented by the ACLU, the clinic contended that this restriction violated the Due Process Clause by imposing an undue burden on women’s ability to access lawful abortion care. After reviewing extensive medical and factual findings, the district court struck down the statute, emphasizing that the ban would leave no viable alternative for most patients. The appellate court affirmed that decision, agreeing that the Act’s constraints were incompatible with constitutional protections then recognized under Planned Parenthood v. Casey, 505 U.S. 833 (1992). The Court concluded that no adequate medical alternative existed and that the state’s asserted interests did not outweigh the burden imposed. The decision invalidated Alabama’s D&E ban and maintained the constitutional limits on state regulation of abortion as they stood prior to Casey and Roe’s overturning in Dobbs v. Jackson Women’s Health Organization, 597 U.S. 215 (2022).