{"schema":"abhortion.org/case.v1/v1","id":"whole-womans-health-v-hellerstedt-2016","type":"case","case_name_short":"Whole Woman's Health v. Hellerstedt","case_name_full":"Whole Woman's Health v. Hellerstedt, Commissioner, Texas Department of State Health Services","citation":"579 U.S. 582 (2016)","docket_number":"15-274","status":"Superseded by Dobbs","court":"U.S. Supreme Court","date_argued":"2016-03-02","date_decided":"2016-06-27","vote":"5-3 (Justice Scalia had died February 13, 2016)","question_presented":"Whether Texas House Bill 2 provisions — requiring (1) abortion providers to hold admitting privileges at a hospital within 30 miles and (2) abortion facilities to meet ambulatory surgical center (ASC) standards — impose an undue burden on the right to abortion.","holding":"Both provisions are unconstitutional because they place a 'substantial obstacle' in the path of women seeking abortion without providing significant health benefits.","reasoning_summary":"Justice Breyer refined Casey's undue burden test to require courts to independently balance the burdens imposed by a law against the medical benefits claimed. The Court found that H.B. 2 had caused approximately half of Texas's abortion clinics to close (from about 40 to 20) with no measurable improvement in patient safety.","practical_effect":"TRAP (Targeted Regulation of Abortion Providers) laws in numerous states were invalidated or vulnerable to challenge. The benefits-and-burdens balancing test was later narrowed by Roberts's concurrence in June Medical Services (2020) and abandoned by Dobbs (2022).","opinions":[{"role":"majority","author":"Breyer, J.","joined_by":"Kennedy, Ginsburg, Sotomayor, Kagan, JJ.","summary":"Both provisions are unconstitutional because they place a 'substantial obstacle' in the path of women seeking abortion without providing significant health benefits."},{"role":"concurrence","author":"Ginsburg, J.","summary":"Emphasized that abortion is a safe procedure and that TRAP laws serve no medical purpose."},{"role":"dissent","author":"Thomas, J.","summary":"Would reject the entire Casey framework."},{"role":"dissent","author":"Alito, J.","joined_by":"Roberts, C.J.; Thomas, J.","summary":"Argued the majority misapplied the undue burden test and improperly weighed evidence."}],"key_quotes":[{"quote":"We conclude that neither of these provisions confers medical benefits sufficient to justify the burdens upon access that each imposes. Each places a substantial obstacle in the path of women seeking a previability abortion, each constitutes an undue burden on abortion access, and each violates the Federal Constitution.","speaker":"Breyer, J. (majority)","location":"slip op. at 1-2"},{"quote":"The record evidence indicates that the admitting-privileges requirement placed a substantial obstacle in the path of a woman's choice, vastly increased the obstacles confronting women seeking abortions in Texas without providing any benefit to women's health.","speaker":"Breyer, J. (majority)","location":"slip op. at 25"}],"perspectives":{"abolitionist":"Abolitionists criticize Hellerstedt as an example of judicial interference with democratic pro-life legislation. Since Dobbs, the case has diminished relevance.","mainstream_prolife":"Mainstream pro-life groups were sharply critical, arguing the Court had substituted its medical judgment for the legislature's. The 'benefits-burdens' test was seen as unworkable and hostile to any pro-life regulation.","prochoice":"Celebrated as a major victory that restored teeth to Casey's undue burden test and pushed back against TRAP laws."},"significance":{"overall":5,"legal_precedential_weight":6,"practical_impact_on_access":7,"movement_relevance_abolitionist":3,"enduring_relevance_2026":2,"rationale":"Major pre-Dobbs precedent superseded by Dobbs. Some analytical framework remains relevant for challenges to state constitutional provisions."},"sources":{"primary":[{"name":"supreme.justia.com/cases/federal/us/579/15-274","href":"https://supreme.justia.com/cases/federal/us/579/15-274/"}],"secondary":[{"name":"theusconstitution.org/litigation/whole-wo…","href":"https://www.theusconstitution.org/litigation/whole-womans-health-v-hellerstedt-u-s-sup-ct/"}]},"related_cases":{"cites_earlier":["Planned Parenthood v. Casey (1992)"],"cited_by_later":["June Medical Services v. Russo (2020)","Dobbs v. Jackson Women's Health Organization (2022)"]},"notes":"The absence of a ninth Justice (post-Scalia death, pre-Gorsuch confirmation) shaped the outcome.","links":{"html":"https://www.abhortion.org/cases/whole-womans-health-v-hellerstedt-2016.html","markdown":"https://www.abhortion.org/cases/whole-womans-health-v-hellerstedt-2016.md","json":"https://www.abhortion.org/cases/whole-womans-health-v-hellerstedt-2016.json"}}