"[T]he inherently factual nature of the standard will engage the lower courts in a more complex analysis than previously required under Roe's brightline trimester framework. As one commentator aptly described it, the undue burden standard is "'a principle' as much as a test," and will undergo refinement every time it is applied.'"
Roe v. Wade

January 1, 1970

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https://en.wikiquote.org/wiki/Roe_v._Wade