The following case brief for Planned Parenthood of Southeastern Pennsylvania v. Casey (1992) provides a concise and structured summary of the court case that serves as a valuable reference tool for law students and legal professionals. It allows them to review and analyze legal principles, identify key issues and holdings, and gain insight into the court’s reasoning.
By presenting cases in a structured manner, case briefs facilitate effective studying, research, and the application of legal principles to new legal scenarios. Whether used for exam preparation, legal research, or enhancing understanding of judicial decisions, case briefs are invaluable resources that contribute to a deeper comprehension of the law.
Case: Planned Parenthood of Southeastern Pennsylvania v. Casey
| Court: | Supreme Court of the United States |
| Citation: | 505 U.S. 833 (1992) |
| Petitioner: | Planned Parenthood of Southeastern Pennsylvania et al. |
| Respondent: | Robert P. Casey, Governor of Pennsylvania, et al. |
Procedural History: Planned Parenthood v. Casey (1992)
- The case originated in the United States District Court for the Eastern District of Pennsylvania.
- Planned Parenthood of Southeastern Pennsylvania and several other organizations and physicians challenged the constitutionality of certain provisions of the Pennsylvania Abortion Control Act.
- The District Court invalidated several provisions but upheld others.
- Both parties appealed the decision to the United States Court of Appeals for the Third Circuit.
- The Court of Appeals affirmed the District Court’s decision in part and reversed in part.
- The case was then appealed to the United States Supreme Court.
Facts: Planned Parenthood v. Casey
Pennsylvania enacted the Abortion Control Act, which imposed several restrictions on abortions, including a mandatory waiting period, informed consent requirements, and spousal notification. Planned Parenthood, along with other abortion providers and individual women, challenged the constitutionality of these provisions. The primary issue before the court was whether the restrictions imposed by the Abortion Control Act violated the constitutional right to privacy established in Roe v. Wade.
Issue: Planned Parenthood v. Casey (1992)
The primary issue before the court was whether the restrictions imposed by the Pennsylvania Abortion Control Act violated the constitutional right to privacy as recognized in Roe v. Wade.
Rule of Law: Planned Parenthood v. Casey
The court considered the constitutionality of the restrictions on abortions under the Fourteenth Amendment’s Due Process Clause and the standard set by Roe v. Wade.
Holding and Reasoning: Planned Parenthood v. Casey (1992)
The Supreme Court held that certain provisions of the Pennsylvania Abortion Control Act were unconstitutional, while upholding others.
Holding: The Court, by a 5-4 decision, held the following:
- Undue Burden Standard: The Court modified the “strict scrutiny” standard set by Roe v. Wade and established a new standard called the “undue burden” standard. Under this standard, a state regulation of abortion is unconstitutional if it places a substantial obstacle in the path of a woman seeking an abortion before the fetus reaches viability.
- Informed Consent and Spousal Notification: The Court upheld the requirement for informed consent, which included providing specific information to the woman seeking an abortion. However, it struck down the spousal notification requirement, stating that it imposed an undue burden on a woman’s right to choose.
- Viability: The Court reaffirmed the principle that states have a legitimate interest in protecting fetal life after viability, which occurs when the fetus is capable of surviving outside the womb. States may enact restrictions on post-viability abortions as long as they include exceptions to protect the life or health of the mother.
- Pre-viability Ban: The Court invalidated the provision that imposed a blanket ban on abortions before viability. It held that such a ban, without exceptions, violated a woman’s right to choose and constituted an undue burden.
Concurrence and Dissent: Planned Parenthood v. Casey
- Justice Sandra Day O’Connor, Justice Anthony Kennedy, and Justice David Souter jointly authored the opinion for the Court, with Justice O’Connor providing the controlling opinion.
- Justice Harry Blackmun filed a concurring opinion, reaffirming his belief in the continued validity of Roe v. Wade.
- Justice Antonin Scalia filed a dissenting opinion, joined by Chief Justice William H. Rehnquist and Justice Clarence Thomas, arguing that the Court’s decision undermined the principles of Roe v. Wade and exceeded the Court’s authority.
Significance: Planned Parenthood v. Casey (1992)
Planned Parenthood v. Casey is a significant case in the area of abortion rights. While it modified the standard set by Roe v. Wade, it ultimately reaffirmed a woman’s constitutional right to choose to have an abortion before fetal viability.
The decision allowed states to regulate abortion but established the “undue burden” standard, which clarified the limitations on such regulations. This case shifted the legal landscape surrounding abortion rights and continues to shape the ongoing debate on the constitutionality of abortion restrictions.