Editing Sandra Day O'Connor (section)

====Abortion====
The [[Christian right]] element in the Reagan coalition strongly supported him in 1980, in the belief that he would appoint Supreme Court justices to overturn ''[[Roe v. Wade]]''. They were astonished and dismayed when his first appointment was O'Connor, who they feared would tolerate abortion. They worked hard to defeat her confirmation but failed.<ref>{{cite journal|first=Prudence|last=Flowers|title='A Prolife Disaster': The Reagan Administration and the Nomination of Sandra Day O'Connor|journal=[[Journal of Contemporary History]]|publisher=[[SAGE Journals]]|location=Thousand Oaks, California|volume=53|issue=2|date=January 2019|pages=391–414|doi=10.1177/0022009417699865 |s2cid=159917418 }}</ref> In her confirmation hearings and early days on the Court, O'Connor was carefully ambiguous on the issue of abortion, as some conservatives questioned her [[anti-abortion]] credentials based on some of her votes in the Arizona legislature.<ref name="greenburg 222"/> O'Connor generally dissented from 1980s opinions which took an expansive view of ''Roe v. Wade''; she criticized that decision's "trimester approach" sharply in her dissent in ''[[City of Akron v. Akron Center for Reproductive Health]]'' (1983). She criticized ''Roe'' in ''[[Thornburgh v. American College of Obstetricians and Gynecologists]]'' (1986): "I dispute not only the wisdom but also the legitimacy of the Court's attempt to discredit and pre-empt state abortion regulation regardless of the interests it serves and the impact it has."<ref name="Greenhouse, Becoming Justice Blackmun"/> In 1989, O'Connor stated during the deliberations over the ''Webster'' case that she would not overrule ''Roe''.<ref>{{harvp|Greenburg|2007|p=80}}</ref> While on the Court, O'Connor did not vote to strike down any restrictions on abortion until ''[[Hodgson v. Minnesota]]'' in 1990.<ref name="Greenhouse, Becoming Justice Blackmun">{{cite book | first = Linda | last = Greenhouse | author-link = Linda Greenhouse | title = Becoming Justice Blackmun | publisher = [[Times Books]] | location=New York City |year = 2006 | isbn = 0805080570 | pages = 196–197}}</ref>

O'Connor allowed certain limits to be placed on access to abortion, but supported the right to abortion established by ''Roe''. In the landmark ruling ''[[Planned Parenthood v. Casey]]'' (1992), O'Connor used a test she had originally developed in ''City of Akron v. Akron Center for Reproductive Health'' to limit the holding of ''Roe v. Wade'', opening up a legislative portal where a State could enact measures so long as they did not place an "[[undue burden]]" on a woman's right to an abortion. ''Casey'' revised downward the standard of scrutiny federal courts would apply to state abortion restrictions, a major departure from ''Roe''. However, it preserved ''Roe''<nowiki/>'s core constitutional precept: that the [[Fourteenth Amendment to the United States Constitution|Fourteenth Amendment]] implies and protects a woman's fundamental right to control the outcomes of her reproductive actions. Writing the plurality opinion for the Court, O'Connor, along with Kennedy and Souter, famously declared: "At the heart of liberty is the right to define one's own concept of existence, of meaning, of the universe, and of the mystery of human life. Beliefs about these matters could not define the attributes of personhood were they formed under compulsion of the State."<ref>''Planned Parenthood of Southeastern Pennsylvania v. Casey,'' 505 U.S. 833, 851 (1992).</ref>