Narrative Opinion Summary
In Reproductive Health Services of Planned Parenthood of the St. Louis Region, Inc. v. Jeremiah W. Nixon, the Eighth Circuit Court reviewed the constitutionality of Missouri's 1999 'Infant's Protection Act,' which criminalizes partial birth abortion without a health exception. The district court deemed the statute unconstitutional, referencing the Supreme Court's decision in Stenberg v. Carhart that invalidated similar legislation due to the lack of a health exception. Planned Parenthood's motion for summary judgment was supported by expert testimony indicating the lower risk associated with intact dilation and evacuation procedures, while the state countered with its experts asserting such procedures were unnecessary. The court found no genuine dispute of material fact existed regarding the health exception. The state's reliance on congressional records and expert testimony failed to present new evidence altering the medical consensus established in Stenberg. Consequently, the Eighth Circuit affirmed the district court's judgment, upholding the summary judgment that the Missouri statute violated constitutional protections by not including a health exception for the mother.
Legal Issues Addressed
Constitutionality of Abortion Regulations under Stenberg v. Carhartsubscribe to see similar legal issues
Application: The court assessed Missouri's 'Infant's Protection Act' against the constitutional standards established in Stenberg v. Carhart, particularly emphasizing the requirement for a health exception.
Reasoning: The district court found the statute unconstitutional, referencing the Supreme Court's ruling in Stenberg v. Carhart, which highlighted the absence of a health exception for the mother as a significant flaw.
Judicial Review of Legislative Recordssubscribe to see similar legal issues
Application: The court assessed the relevance of the congressional record from the federal Partial-Birth Abortion Ban Act of 2003, finding it insufficient to demonstrate any change in medical evidence since Stenberg.
Reasoning: However, the court found that the congressional record did not indicate any change in medical evidence since Stenberg.
Medical Necessity in Abortion Proceduressubscribe to see similar legal issues
Application: The court considered expert opinions on the medical necessity of intact D.E. procedures, ultimately determining that the state's evidence did not present a genuine issue of material fact.
Reasoning: Planned Parenthood sought summary judgment based on the Supreme Court precedent, supported by expert opinions stating that intact D.E. procedures carry lower risks.
Summary Judgment Standardssubscribe to see similar legal issues
Application: The court evaluated the appropriateness of summary judgment based on the absence of a genuine dispute regarding material facts, particularly the lack of a health exception, affirming its alignment with legal standards.
Reasoning: Summary judgment is reviewed de novo, meaning the appellate court examines the case without deference to the lower court's findings.