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Planned Parenthood Assn. of Kansas City, Mo., Inc. v. Ashcroft

Citations: 76 L. Ed. 2d 733; 103 S. Ct. 2517; 462 U.S. 476; 1983 U.S. LEXIS 64; 51 U.S.L.W. 4783Docket: 81-1255

Court: Supreme Court of the United States; June 15, 1983; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

In this case, the Supreme Court evaluated the constitutionality of various Missouri statutes regulating abortion procedures. The primary legal issues involved the state's requirements for hospitalization after 12 weeks of pregnancy, the presence of a second physician during post-viability abortions, the necessity of pathology reports for each abortion, and parental or judicial consent for minors seeking an abortion. Planned Parenthood, along with other plaintiffs, challenged these statutes on the grounds that they infringed upon constitutional rights. The District Court initially invalidated all provisions except the pathology-report requirement. However, the Eighth Circuit Court reversed parts of this decision, leading to further proceedings. The Supreme Court ultimately found the hospitalization requirement unconstitutional, affirming that it imposed an undue burden on a woman's right to an abortion. Conversely, the second-physician and pathology-report requirements were upheld, as they were consistent with medical standards and the state's interest in protecting fetal life. The parental consent statute was also deemed constitutional, offering necessary protections for minors with a provision for judicial consent. The Court's decision reflects a balance between individual rights and state interests, leading to a partial affirmation and reversal of the lower courts' rulings, with the case remanded for further proceedings on attorney's fees.

Legal Issues Addressed

Abortion Rights and Constitutional Limitations

Application: The Supreme Court determined that Missouri statute § 188.025, requiring hospitalization for abortions after 12 weeks, unreasonably infringes on a woman's constitutional right to an abortion and is therefore unconstitutional.

Reasoning: The Supreme Court held that § 188.025 is unconstitutional as it unreasonably infringes on a woman’s constitutional right to an abortion.

Medical Standards in Abortion Procedures

Application: The pathology-report requirement under § 188.047 was deemed constitutional as it conforms to medical standards and does not significantly burden a woman's decision to have an abortion.

Reasoning: The pathology-report requirement in § 188.047 aligns with accepted medical standards and does not significantly burden a woman's decision to have an abortion.

Parental and Judicial Consent for Minors

Application: Missouri's statute § 188.028 requiring parental or judicial consent for minors seeking an abortion was found constitutional as it provides necessary protections and offers a judicial alternative for consent.

Reasoning: Lastly, § 188.028 is deemed constitutional, as it provides necessary protections for minors while allowing a judicial alternative for consent.

State Interest in Protecting Viable Fetuses

Application: The requirement of a second physician during post-viability abortions under § 188.030.3 was upheld as constitutional, as it aligns with the state's interest in protecting viable fetal life.

Reasoning: The second-physician requirement in § 188.030.3 is constitutional as it serves the state’s interest in protecting viable fetuses.