82 PART oNE • THE AMERiCAN sYsTEM
Court twice struck down laws that required a woman who wished to have an abortion to
undergo counseling designed to discourage abortions. In the late 1980s and early 1990s,
however, the Court took a more conservative approach. For example, in 1989, the Court
upheld a Missouri statute that, among other things, banned the use of public hospitals or
other taxpayer-supported facilities for performing abortions.^37 In 1992, the Court upheld
a Pennsylvania law that required preabortion counseling, a waiting period of twenty-four
hours, and for girls under the age of eighteen, parental or judicial permission.^38 As a result,
abortions are more difficult to obtain in some states than in others.The Controversy Continues. Abortion continues to be a divisive issue. Groups opposed
to abortion continue to push for laws restricting abortion, to endorse political candidates
who support their views, and to organize protests. Because of several episodes of violence
attending protests at abortion clinics, in 1994 Congress passed the Freedom of Access to
Clinic Entrances Act. The act prohibits protesters from blocking entrances to such clinics.
In recent years, abortion opponents have concentrated—often unsuccessfully—on
state ballot proposals that could lay the groundwork for an eventual challenge to Roe. In
one 2011 example, in Mississippi voters rejected a measure that would have outlawed all
abortions and some forms of birth control. Abortion opponents have been more successful
in winning new restrictions on abortion clinics. New state laws became especially common
after the 2010 elections, when Republicans took over many state legislative chambers.This protester stands in front of the Planned Parenthood center in Aurora, Illinois. What
limits are placed on anti-abortion protesters? (AP Photo/Stacie Freudenberg)- Webster v. Reproductive Health Services, 492 U.S. 490 (1989).
- Planned Parenthood v. Casey, 505 U.S. 833 (1992).
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