"In 1992, after a three-year hiatus in which no major abortion decision was announced, the Court issues its ruling in Planned Parenthood of Southeastern Pennsylvania v. Casey (1992). The case addressed the 1982 Pennsylvania Abortion Control Act, amended in 1988 and 1989. Under the heading of informed consent, the law required a physician to inform a woman of the risks of abortion and wait at least 24 hours before performing the procedure. It also required married women, under most circumstances, to present signed statements that they had notified their husbands about their intention to have an abortion. The Court issues a lengthy and complex ruling on June 29, 1992. The opinion indicated that a new consensus had formed with Justices O’Connor and Kennedy and Justice David Souter jointly authoring a plurality opinion that retained “the essential holding” of the Court’s landmark 1973 opinion, Roe v. Wade. The joint opinion outlined three elements it considered essential to Roe v. Wade. First, the woman had a right to have an abortion before the fetus is viable without “undue interference” from the state. Second, the state could restrict abortions after the fetus was viable as long as it allowed an exception for the woman’s life or health. Third, the state’s interest in the life of the woman and the fetus began at the start of the pregnancy, not merely at the point in which the fetus was viable. The authors of the joint opinion stressed that the Court’s commitment to individual liberty, in conjunction with the constraints of its earlier decisions and the rule of law, convinced them to reaffirm Roe v. Wade. In light of these considerations, and in an attempt to balance the woman’s constitutional right to abortion with a state’s interest in prenatal life throughout the pregnancy, the Court drew a line at viability. Abandoning the trimester framework, which it did not consider “essential” to its ruling in Roe v. Wade, the Court replaced the three trimesters with two stages of pregnancy: pre- and postviability. Before viability, a state could enact laws to ensure that the abortion decision was “thoughtful and informed,” but it was not permitted to prohibit abortions outright or even to restrict them unduly. The opinion explained that because of its legitimate interest in protecting potential life, the state did not have to remove itself from the abortion decision throughout the pregnancy; it was only forbidden to enact abortion regulations during the previability stage that imposed an “undue burden” on the woman’s choice. It specified that a woman with a previable fetus would be unduly burdened if the state placed “a substantial obstacle” in her path. Thus, states were no longer required to have compelling reasons to restrict a woman’s access to abortion as long as they did not impose an undue burden on her choice. Once the fetus was viable, states were permitted to regulate or proscribe abortions entirely as long as reasonable health exception were in place, that is, as long as the laws exempted women whose life or health was at risk."