Whole Woman’s Health v. Hellerstedt (2016)

The U.S. Supreme Court case Whole Woman’s Health v. Hellerstedt, 579 U.S. 582 (2016), held that two requirements of Texas’s H.B. 2: (1) that abortion-performing physicians must hold hospital admitting privileges within 30 miles and, (2) that abortion clinics meet the standards for ambulatory surgical centers, placed a “substantial obstacle” in the path of individuals seeking legal pre-viability abortions and thus imposed an undue burden under the Fourteenth Amendment. The Court found that the State’s evidence did not demonstrate that the laws meaningfully advanced health outcomes compared to prior regulations. Record evidence showed that many clinics closed and abortion access became more difficult, especially for rural individuals and those living in poverty. The undue burden test established by Planned Parenthood v. Casey (1992), 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.