{"schema":"abhortion.org/case.v1/v1","id":"ayotte-v-planned-parenthood-2006","type":"case","case_name_short":"Ayotte v. Planned Parenthood of Northern New England","case_name_full":"Ayotte, Attorney General of New Hampshire v. Planned Parenthood of Northern New England et al.","citation":"546 U.S. 320 (2006)","docket_number":"04-1144","status":"Good law on remedial question","court":"U.S. Supreme Court","date_argued":"2005-11-30","date_decided":"2006-01-18","vote":"9-0","question_presented":"If an abortion statute (New Hampshire's Parental Notification Prior to Abortion Act) is unconstitutional only in a narrow range of medical emergencies, is the appropriate remedy total invalidation or a narrower injunction?","holding":"Invalidating a statute entirely is not always necessary or justified when only some applications would be unconstitutional. Lower courts may render narrower declaratory and injunctive relief.","reasoning_summary":"Justice O'Connor's unanimous opinion sought to preserve as much of a state's abortion regulation as possible when only limited applications are unconstitutional. This was O'Connor's last opinion before retirement.","practical_effect":"State abortion laws lacking health exceptions could be enjoined only as to medical emergencies rather than struck down entirely. Preserved parental notification laws generally.","opinions":[{"role":"majority","author":"O'Connor, J.","joined_by":"Roberts, C.J.; Stevens, Scalia, Kennedy, Souter, Thomas, Ginsburg, Breyer, JJ.","summary":"Invalidating a statute entirely is not always necessary or justified when only some applications would be unconstitutional. Lower courts may render narrower declaratory and injunctive relief."}],"key_quotes":[{"quote":"We do not revisit our abortion precedents today, but rather address a question of remedy: If enforcing a statute that regulates access to abortion would be unconstitutional in medical emergencies, what is the appropriate judicial response? We hold that invalidating the statute entirely is not always necessary or justified, for lower courts may be able to render narrower declaratory and injunctive relief.","speaker":"O'Connor, J.","location":"slip op. at 1"},{"quote":"States have the right to require parental involvement when a minor considers terminating her pregnancy.","speaker":"O'Connor, J.","location":"slip op."}],"perspectives":{"abolitionist":"Abolitionists have mixed views: the remedial narrowing prevented complete invalidation of pro-life laws, but the framework preserved a health exception that abolitionists reject.","mainstream_prolife":"Mainstream pro-life groups generally supported the narrower remedy as preserving parental involvement laws.","prochoice":"Advocates viewed the ruling as procedural but noted it preserved parental notification requirements."},"significance":{"overall":3,"legal_precedential_weight":3,"practical_impact_on_access":3,"movement_relevance_abolitionist":2,"enduring_relevance_2026":2,"rationale":"A remedial decision with limited doctrinal impact on abortion itself."},"sources":{"primary":[{"name":"supreme.justia.com/cases/federal/us/546/320","href":"https://supreme.justia.com/cases/federal/us/546/320/"}],"secondary":[{"name":"aclu.org/press-releases/supr…","href":"https://www.aclu.org/press-releases/supreme-court-ruling-ayotte-v-planned-parenthood-recognizes-protections-womens-health"}]},"related_cases":{"cites_earlier":["Planned Parenthood v. Casey (1992)"]},"notes":"Justice O'Connor's final opinion before retirement.","links":{"html":"https://www.abhortion.org/cases/ayotte-v-planned-parenthood-2006.html","markdown":"https://www.abhortion.org/cases/ayotte-v-planned-parenthood-2006.md","json":"https://www.abhortion.org/cases/ayotte-v-planned-parenthood-2006.json"}}