June Medical Services v. Russo
On June 29, 2020, the United States Supreme Court ruled on whether a Louisiana law that required doctors who provide abortions have the right to admit patients at a local hospital placed an undue burden on women was constitutional or not. The case name is June Medical Services v. Russo.
Specifically, the law required doctors to have admitting privileges to a hospital within thirty miles of where the abortion was to be performed. Initially, the District Court found that the law was unconstitutional. On appeal, the 5th Circuit Court of Appeals reversed the District Court, noting that the court determined that no clinics will “likely be forced to close” due to the law. As a result, the law was allowed to stand. The Supreme Court of the United States agreed with the District Court. In a 5-4 ruling, the Supreme Court held that the law was unconstitutional.
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The State of Louisiana’s Argument
The State of Louisiana argued that its intention was to protect the health of women. If something were to go wrong during the procedure, and the woman needed specialized attention, the law would ensure that there was a hospital close enough to provide medical treatment. The State noted that Louisiana law imposes this requirement on all outpatient/same day surgery centers. The State further argued that it has a legitimate interest in overseeing and regulating medical treatment to ensure it is safe.
The Plaintiffs’ Argument
The Plaintiffs argued that Act 620 imposed an undue burden on women and their access to abortions. There is no hard and fast rule to define “undue burden.” Put simply, it is one that has “the purpose or effect of placing a substantial obstacle in the path of a woman seeking an abortion of a nonviable fetus.” Planned Parenthood v. Casey, 505 U.S. 833, 877 (1992). Undue burden can occur even when there is an attempt to further a legitimate and valid state. This occurs when the law has the “effect of placing a substantial obstacle in the path of a woman’s choice cannot be considered a permissible means of serving its legitimate ends.” Whole Woman’s Health v. Hellerstedt, 136 S. Ct. 2292 (2016). The Plaintiffs argued that this unnecessary health regulation placed a legitimate and substantial obstacle with the intent on curbing abortion in the state. The Plaintiffs also argued that the law was nearly identical to the admitting privileges Texas law in the Whole Woman’s court case, which was previously held unconstitutional.
Summary of the Court’s Holding
Paying attention to current events and want to understand more about the United States Supreme Court’s ruling on a Louisiana law that required doctors who provide abortions have admitting privileges at a local hospital placed an undue burden on women was constitutional or not? Here’s a summary of the ruling:
- It was determined that there was not sufficient evidence for the Court of Appeals to overturn the District Court
- In a 5-4 ruling, Act 620 was found to be unconstitutional and placed an undue burden on women
Reiterating its reasoning in the Whole Woman’s Health case, which had a nearly identical law at issue, the Court reasoned that the lower courts must consider substantial obstacles along with the benefits those laws give. The Supreme Court was also critical of the Court of Appeal’s disregard of the District Court’s findings of fact. Justice Breyer noted that these findings of fact may be based on oral or written evidence and should not be “set aside unless clearly erroneous, and the reviewing court must give due regard to the trial court’s opportunity to judge the witnesses’ credibility.” June Medical Services v. Russo, quoting Fed. Rule Civ. Proc. 52(a)(6). Essentially, it is not the Court of Appeals’ job to review the facts with a fresh mind, which is what the 5th Circuit did in this matter. Justice Breyer and the joining Justices did not find there was sufficient evidence for the Court of Appeals to overturn the District Court. As a result, the District Court’s findings should be given deference that Act 620 provided a substantial burden to women who wish to seek an abortion. The Court reversed the Fifth Circuit Court of Appeals and held that Act 620 was unconstitutional. The link to the full opinion can be found here.
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