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Whole Women's Health v. Hellerstedt

136 S. Ct. 2292 (2016)

tl;dr: Introduces balancing test of burden of law vs. benefit to women in upholding abortion laws.

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The Supreme Court of the United States ruled on a case involving Whole Woman's Health and John Hellerstedt, the Commissioner of the Texas Department of State Health Services. The case considered whether two provisions of Texas' House Bill 2 violated the Federal Constitution as interpreted in Planned Parenthood of Southeastern Pa. v. Casey. The Court found that both provisions placed a substantial obstacle in the path of women seeking an abortion and constituted an undue burden on abortion access, violating the Federal Constitution. The District Court granted an injunction, but the Fifth Circuit vacated it three days later, allowing the provision to take effect. The Fifth Circuit upheld the admitting-privileges requirement in House Bill 2, citing evidence that it would reduce delays in treatment and decrease health risks for patients with complications. A group of abortion providers filed a lawsuit seeking an injunction to prevent the enforcement of the admitting-privileges provision and the surgical-center provision anywhere in Texas, claiming that these provisions violated the Constitution's Fourteenth Amendment, as interpreted in Casey. The District Court concluded that approximately 5.4 million women of reproductive age live within a large geographical area in Texas. The number of licensed abortion facilities in Texas dropped by almost half after the enforcement of the admitting-privileges requirement, and the surgical-center provision would further reduce the number of facilities. However, the Fifth Circuit vacated the injunction, allowing the provisions to take effect.

The case dealt with the constitutionality of two provisions in Texas' House Bill 2 that made it difficult for certain women to access abortions. The District Court found the provisions unconstitutional, but the Court of Appeals wrongly applied the principle of res judicata to bar challenges to the admitting-privileges requirement. The Court of Appeals erred in concluding that the award of facial relief was precluded by principles of res judicata. The Supreme Court agrees with the District Court's decision that the admitting-privileges requirement creates a significant obstacle for women seeking abortions, leading to the closure of clinics and difficulty for providers in obtaining privileges. The new surgical-center requirement in Texas' law for abortion facilities is being challenged and found to be unnecessary and not benefiting patients. Justice Thomas disagrees with the Court's decision to strike down two state laws limiting abortion services. The Court's opinion changes the "undue burden" standard for assessing the constitutionality of abortion restrictions, making it more like strict scrutiny.

Justice Alito, along with Chief Justice and Justice Thomas, dissents from the Court's decision in the abortion case, arguing that the Court's use of tiers of scrutiny in constitutional law is problematic and losing its meaning. The case concerns the application of res judicata, rather than the constitutionality of abortion laws. The Court's failure to apply the principle of claim preclusion raises issues of the Court's fairness and impartiality. The challenges to the admitting privileges requirement and the ASC requirement should be considered together, with petitioners bearing the burden of demonstrating that the requirements are prohibitively burdensome on women. The admitting privileges requirement should be upheld where it is not an undue burden, such as in most of eastern Texas. The lower court made an error in declaring all surgical center requirements unconstitutional, and severability should have been applied to separate the constitutional provisions from the unconstitutional ones. The case needs to be returned to the lower courts for a more specific remedy.

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IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:State of Texas passed 2 provisions in the House Bill...

Holding:The rule from Casey requires that courts consider the burdens...

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Whole Women's Health v. Hellerstedt

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