While the Court refused to use the Pennsylvania case to overturn Roe, it did uphold Pennsylvania's informed consent requirements. This implicitly opened the door to further regulations designed to protect the health of women. Abortion remains a "liberty," but it may be regulated as long as the regulations do not impose an "undue burden" on the woman seeking an abortion.

Pro-life lobbyists are now working in every state to enact tighter regulations on clinics for informed consent, waiting periods, and greater liability for abortion related injuries. At the request of other pro-life organizations, I have spent considerable time reviewing informed consent legislation and providing recommendations to improve it. As these bills enter legislative hearings, we will be prepared to provide documentation and testimony to support the importance of these regulations.