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Planned Parenthood of Central New Jersey Herbert Holmes, M.D. David Wallace, M.D. Gerson Weiss, M.D. On Behalf of Themselves and Their Patients v. John Farmer, Jr. , Attorney General of the State of New Jersey, in His Official Capacity, and His Successors in Office New Jersey Board of Medical Examiners, and Their Successors in Office Christine Grant , Commissioner of the Department of Health and Senior Services, in Her Official Capacity, and Her Successors in Office New Jersey Legislature, by and Through Donald T. Difrancesco, in His Official Capacity as President of the New Jersey Senate, and Jack Collins, in His Official Capacity as Speaker of the New Jersey Assembly, and as the Representative of the New Jersey Assembly (Intervenors in d.c.)

Citation: 220 F.3d 127Docket: 99-5042

Court: Court of Appeals for the Third Circuit; July 26, 2000; Federal Appellate Court

Narrative Opinion Summary

The case involves an appeal by the New Jersey State Legislature against the United States District Court for the District of New Jersey's decision declaring the New Jersey Partial-Birth Abortion Ban Act of 1997 unconstitutional. Planned Parenthood of Central New Jersey and several physicians challenged the Act, arguing it was vague and imposed an undue burden on the constitutional right to abortion. The District Court granted a permanent injunction against the Act, finding it void for vagueness and lacking a health exception. The Third Circuit Court of Appeals affirmed the decision, aligning with the Supreme Court ruling in Stenberg v. Carhart. The case highlights significant legal principles, including the void for vagueness doctrine and the undue burden standard under Roe v. Wade and Planned Parenthood v. Casey. The plaintiffs had standing due to potential legal repercussions, and the case was ripe for review despite the Act not being enforced. The court rejected Pullman abstention, citing the Act's vagueness as preventing a meaningful state court interpretation, and emphasized the constitutional protection of a woman's right to choose prior to fetal viability. The judgment affirmed the unconstitutionality of the Act due to vagueness and the undue burden it imposed on abortion rights.

Legal Issues Addressed

Constitutionality of Abortion Statutes

Application: The New Jersey Partial-Birth Abortion Ban Act of 1997 was found unconstitutional under the due process clause as it imposed an undue burden on a woman's right to an abortion and was void for vagueness.

Reasoning: The District Court found the Act void for vagueness and concluded that it imposed an undue burden on a woman's constitutional right to obtain an abortion.

Pullman Abstention Doctrine

Application: The court declined to abstain from ruling on the federal constitutional issue despite the Act not being interpreted by state courts, as the Act was too vague for a definitive state court interpretation.

Reasoning: The District Court determined that abstention was unnecessary due to the Act's vagueness, which precluded any state court interpretation that could limit federal constitutional issues.

Ripeness of Constitutional Challenges

Application: The case was deemed ripe for judicial review as delaying consideration would cause hardship to the parties, and the issues were adequately developed for review.

Reasoning: The case at hand is deemed ripe because withholding review would cause hardship to the parties and the issues presented were adequately developed through a four-day hearing, providing a sufficient factual record for legal determinations.

Standing to Challenge Abortion Statutes

Application: Planned Parenthood and physician plaintiffs had standing to challenge the Act due to its impact on conventional abortion methods they perform, which exposed them to potential legal repercussions.

Reasoning: The District Court determined that plaintiffs have standing because the act also affects conventional abortion methods they perform, exposing them to potential legal repercussions.

Undue Burden Standard

Application: The Act was found to impose an undue burden on women's constitutional rights by broadly encompassing conventional abortion methods without a health exception for the mother.

Reasoning: The Act has been found to create an undue burden on a woman's constitutional right to obtain an abortion. This is based on three factors: the broad language of the Act that encompasses conventional abortion methods, the absence of a health exception for the physician, and the inadequacy of the existing exception for the woman's life.

Void for Vagueness Doctrine

Application: The Act's vague language, particularly the undefined terms like 'partial birth abortion' and 'substantial portion,' led to its invalidation as it did not provide clear guidance to physicians.

Reasoning: The Act's vagueness is heightened by the undefined term 'substantial portion,' which raises questions regarding its interpretation—whether it refers to size, volume, or functionality of the fetus.