in Roe was controversial, with 46 states needing to change their abortion laws as a result of it.5 Arguably the next most famous Supreme Court case involving abortion rights is Planned Parenthood of Southeastern Pennsylvania v. Casey (1992). This case began when several abortion clinics and physicians challenged the Pennsylvania legislature’s amended abortion control law. The case question was: “Can a state require women who want an abortion to obtain informed consent, wait 24 hours, if married, notify their husbands, and, if minors, obtain parental consent without violating their right to abortion as guaranteed by Roe v. Wade?6” In a 5-4 decision for Planned Parenthood of Southeastern Pennsylvania, the Court kept three of the main findings from Roe: women have the right to pre-viability abortions without undue interference from the state, the state may restrict post-viability abortions, and the state has a legitimate interest in protecting the life of the fetus and woman’s health.7 Since these two monumental cases in abortion rights, many other cases involving the issue of abortion have passed through the Supreme Court. In 2007, Gonzales v. Carhart upheld a federal statute that banned partial-birth abortions.8 In 2016, the Supreme Court struck down a Texas law requiring abortion providers to maintain admitting privileges and ambulatory surgical centers in Whole Woman’s Health v. Hellerstedt.9 III.
CURRENT STATE OF ABORTION RIGHTS IN THE UNITED STATES
Since Roe and Planned Parenthood of Southeastern Pennsylvania, attempts to restrict abortion rights at various levels have ensued, highlighting the continued salience and controversy of the issue. From the passing of Roe in 1973 to the end of 2021, 1,338 abortion restrictions have been enacted by 5
Roe v. Wade (1973), Cornell Law School Legal Information Institute, https://www.law.cornell.edu/wex/roe_v_wade_(1973) (last visited April 4, 2022). 6 Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 US 833 (June 29, 1992). 7 Id. 8 Id. 9 Jessica Arons, The Last Clinics Standing, American Civil Liberties Union, https://www.aclu.org/issues/reproductive-freedom/abortion/last-clinics-standing (last visited April 6, 2022).
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