Planned Parenthood of Se. Pennsylvania v. Casey

In light of Roe v. Wade, the plaintiffs challenged various abortion-limiting restrictions in Pennsylvania’s Abortion Control Act. The Supreme Court created a new test that asks whether a state abortion regulation has the purpose or effect of imposing an “undue burden,” which the Court defined as a “substantial obstacle in the path of a woman seeking an abortion before the fetus attains viability.” Pursuant to this test, the Court upheld nearly all of the restrictions in Pennsylvania’s state abortion law, including parental notification/consent requirements for minors and limitations on public funding of abortions. However, the Court did find that the statute’s husband notification requirement was unlawful.