States’ and women’s rights regarding reproductive decision have been further shaped and defined by a number of landmark rulings.

■■ In 1992, in Planned Parenthood v. Casey, the Supreme Court nearly overturned Roe v. Wade. It rejected the trimester approach in favor of the Court evaluating the permissibility of state abortion rules based on whether they unduly burden a woman’s ability to obtain an abortion. A rule is considered an undue burden if its purpose or effect is to place a substantial obstacle in the path of a woman seeking an abortion before the fetus is viable.

■■ A partial-birth abortion is a late-term abortion that involves partial delivery of the fetus prior to its being aborted. An Arkansas statute failed to prohibit this manner of abortion largely as a result of its broad coverage. The act was determined to be unconstitutional because it was unconstitutionally vague, imposed an undue burden on women seeking abortions, and did not adequately protect the health and lives of pregnant women.

■■ In Utah Women’s Clinic, Inc. v. Leavitt, the court determined that imposition of a 24-hour waiting period—except in the event of a medical emergency—does not impose an undue burden on the right to an abortion.

■■ In Doe v. Zimmerman, the court declared unconstitutional the provisions of the Pennsylvania Abortion Control Act, which required that the written consent of the husband of a married woman be secured before the performance of an abortion.