"The apparent confusion and lack of clarity in the abortions-for-minors cases goes beyond efforts to define the relevant right and to establish rules about which preconditions to abortions for minors are acceptable. In Roe v. Wade the Court quite plainly held that the abortion right (whatever it may be) is fundamental. That holding led to the conclusion that state infringements on the right are unconstitutional unless they are necessary to a compelling state interest. In the cases about minors however, the Court moved away from the necessary to a compelling state interest standard. It applied a variety of different standards to restrictions on the abortion right including whether the restriction was reasonably calculated to achieve the state’s end. That is the lowest level of scrutiny the Court applies to invasions of rights and is inconsistent with the idea that the abortion right is fundamental. Additionally, the court deviated from “Roe” by expanding the number of state interests that may be considered in deciding whether a particular intrusion into the abortion right is acceptable. The Court recognized as worthy of consideration the interest in family integrity, the interest in protecting adolescents, the interest in providing essential medical information (even in the first trimester), the interest in protecting potential life (even before viability), and the interest in full-term pregnancies. Obviously, some of these interests exist regardless of the age of the woman seeking an abortion. Obviously, too, the interests in providing information, protecting potential life, and full-term pregnancies permit massive inroads into women’s opportunities to obtain abortions. A 1979 abortion for minors case makes clear the reason for the Court’s backing away from “Roe” and for the Court’s confused and inconsistent approach."