ABSTRACT

In 1973, the Supreme Court declared in Roe v. Wade that the constitutional right to privacy, found in the Fourteenth Amendment's guarantee of liberty, was "broad enough to encompass a woman's right to terminate her pregnancy." 1 Nineteen years later, in 1992, a very different Supreme Court held in Planned Parenthood of Southeastern Pennsylvania v. Casey that "the essential holding of Roe v. Wade should be retained and once again reaffirmed." 2 In between these two landmark decisions, however, lay two decades of intense political battle.