"One of the explicit concerns of the Casey joint opinion was that "decisions after Roe [had] cast doubt upon the meaning and reach of its holding," and therefore, lower courts "must have guidance as they seek to address this subject." As one of the first courts to review abortion regulations under the new Casey undue burden standard found, however, "[d]espite the recent efforts of a three-justice plurality of the Supreme Court, passing on the constitutionality of state statutes regulating abortion after Casey has become neither less difficult nor more closely anchored to the Constitution." The explicit intention to provide clarity is particularly ironic given the amount of scholarly comment detailing inherent defects in the undue burden standard and predicting its troublesome application."