"With the promulgation of this new standard, the Casey decision effectively abolishes the fundamental right status of a woman's right to choose, and replaces Roe's strict scrutiny .with a "more permissive" standard calling for consideration of state interests, thereby reducing the level of review to something more akin to heightened scrutiny 38 or rational basis review. Additionally, the Casey undue burden standard shifts the burden of proof from the state to the individuals challenging the regulation." Previously, under Roe's strict scrutiny standard, once facial challengers had proven a restriction impacted the abortion right to any degree, the burden shifted to the state to show that the restriction was narrowly drawn to serve a compelling state purpose. Because the abortion right is no longer fundamental under Casey, challengers of abortion laws face a weightier facial showing of unconstitutionality than was required under Roe: they must prove in the first instance that either "the legislature's purpose was to interfere substantially with a woman's abortion choice, or that a challenged regulation would impose a 'substantial obstacle' to the exercise of that choice.""