Editing Planned Parenthood v. Casey (section)

====Key judgment ====

Chief Justice [[John Roberts]]'s concurrence in the 2020 ''[[June Medical Services, LLC v. Russo]]'' case noted the key outcomes in ''Casey'': "The several restrictions that did not impose a substantial obstacle were constitutional, while the restriction that did impose a substantial obstacle was unconstitutional."<ref>{{cite web |author=[[John Roberts]]|title=June Medical Services, L.L.C. et al v. Russo, Interim Secretary, Louisiana Department of Health and Hospitals (slip opinion) |url=https://www.supremecourt.gov/opinions/19pdf/18-1323_c07d.pdf |archive-url=https://web.archive.org/web/20200630004848/https://www.supremecourt.gov/opinions/19pdf/18-1323_c07d.pdf |archive-date=June 30, 2020 |page=55}}</ref> Before an abortion regulation can be struck down as unconstitutional there must be a determination that this regulation imposes a substantial obstacle in light of [[#Undue burden standard|the undue burden standard explained in the section above]].<ref>{{cite web |author=[[John Roberts]]|title=June Medical Services, L.L.C. et al v. Russo, Interim Secretary, Louisiana Department of Health and Hospitals (slip opinion) |url=https://www.supremecourt.gov/opinions/19pdf/18-1323_c07d.pdf |archive-url=https://web.archive.org/web/20200630004848/https://www.supremecourt.gov/opinions/19pdf/18-1323_c07d.pdf |archive-date=June 30, 2020 |pages=54, 56 and 57}}</ref> In ''Casey'' "the justices imposed a new standard to determine the validity of laws restricting abortions. The new standard asks whether a state abortion regulation has the purpose or effect of imposing an "undue burden", which is defined as a "substantial obstacle in the path of a woman seeking an abortion before the fetus attains viability."<ref>{{cite web |title=Planned Parenthood of Southeastern Pennsylvania v. Casey |url=https://www.oyez.org/cases/1991/91-744 |publisher=[[Oyez Project|Oyez.org]] |access-date=July 3, 2020 |archive-url=https://web.archive.org/web/20200716131316/https://www.oyez.org/cases/1991/91-744 |archive-date=July 16, 2020 |url-status=bot: unknown }}</ref><ref>{{cite web |title=Planned Parenthood of Southeastern Pa. v. Casey, 505 U.S. 833 (1992) (Syllabus) |url=https://supreme.justia.com/cases/federal/us/505/833/ |publisher=Justia US Supreme Court Center |access-date=July 3, 2020 |archive-url=https://web.archive.org/web/20200628040642/https://supreme.justia.com/cases/federal/us/505/833/ |archive-date=June 28, 2020 |quote=A person retains the right to have an abortion, established by ''Roe v. Wade'', but the state’s compelling interest in protecting the life of an unborn child means that it can ban an abortion of a viable fetus under any circumstances except when the health of the mother is at risk. Also, laws restricting abortion should be evaluated under an undue burden standard rather than a strict scrutiny analysis. ... Its other notable revision of Roe was its replacement of strict scrutiny with an undue burden standard that was more lenient to the state. O'Connor built on her dissenting opinion from the Court's 1983 decision in ''Akron v. Akron Center for Reproductive Health'' in holding that restrictions on abortion before the fetus was viable were constitutional unless they posed a substantial obstacle to the woman seeking an abortion.}}</ref> The key judgment of ''Casey'' can be summed up as follows: "Under ''Casey'', abortion regulations are valid so long as they do not pose a substantial obstacle and meet the threshold requirement of being "reasonably related" to a "legitimate purpose." ''Id.'', at 878; ''id.'', at 882 (joint opinion)."<ref>{{cite web |author=[[John Roberts]]|title=June Medical Services, L.L.C. et al v. Russo, Interim Secretary, Louisiana Department of Health and Hospitals (slip opinion) |url=https://www.supremecourt.gov/opinions/19pdf/18-1323_c07d.pdf |archive-url=https://web.archive.org/web/20200630004848/https://www.supremecourt.gov/opinions/19pdf/18-1323_c07d.pdf |archive-date=June 30, 2020 |page=55 }}</ref>