"In June 1992, the United States Supreme Court in Planned Parenthood v. Casey struck down the trimester framework of Roe v. Wade and replaced it with an undue burden standard to test the constitutionality of state abortion regulations. After Casey, commentators predicted the standard would be unworkable in practice, engender confusion in the lower courts, increase abortion litigation, allow judges broad discretion, and create inconsistent outcomes from state to state. After a survey of the thirteen cases which have so far implemented the undue burden standard, there is little evidence of the accuracy of these predictions, with the exception that the courts have been confused widely about the requirements of this new standard."