Whole Woman's Health v. Hellerstedt

In 2013, Texas enacted House Bill 2, requiring physicians performing abortions to have admitting privileges at a nearby hospital and mandating that clinics meet the standards of ambulatory surgical centers. Whole Woman’s Health and other abortion providers sued John Hellerstedt, the state health commissioner, arguing that these provisions served no medical purpose and imposed an undue burden on women’s access to abortion. The Supreme Court heard the case and on June 27, 2016, issued a 5–3 decision striking down both provisions. Applying the undue burden standard from Planned Parenthood v. Casey, the majority found that the restrictions offered no significant health benefits while placing a substantial obstacle in the path of women seeking abortions, thereby violating the Fourteenth Amendment. The ruling required courts to independently weigh the benefits of abortion regulations against the burdens they create.

The Supreme Court reversed the Fifth Circuit, holding that both provisions of Texas H.B. 2 constitute an undue burden on abortion access and are therefore facially unconstitutional. The law was struck down in its entirety.

Whether the Texas admitting-privileges and surgical-center requirements imposed an unconstitutional undue burden on a woman's right to obtain an abortion, in violation of the Fourteenth Amendment as interpreted in Planned Parenthood v. Casey.

The decision was celebrated as a major victory for reproductive rights, immediately blocking similar clinic restrictions in other states. It reaffirmed the undue burden standard and led courts to scrutinize the medical justifications for abortion regulations. However, it intensified the political and legal battle over abortion, galvanizing conservative efforts that ultimately culminated in the Supreme Court overruling Roe v. Wade in Dobbs v. Jackson Women’s Health Organization (2022). The case remains a pivotal moment in the history of U.S. abortion jurisprudence.