June Med. Servs. L. L. C. v. Russo

Louisiana’s admitting-privileges law for abortion doctors represents a substantial obstacle to a woman pursuing an abortion and is therefore unconstitutional.

Petitioners, a group of abortion clinics and doctors, filed suit over the State of Louisiana’s law requiring abortion doctors to have admitting privileges at area hospitals.  The District Court found that this law placed an undue burden on women pursuing an abortion and was therefore unconstitutional.  The Court of Appeals disagreed with some of the District Court’s factual findings and reversed.  The Supreme Court of the United States reversed, holding that the Court of Appeals applied the wrong standard for reversing a trial court’s findings and reached the conclusion that the Louisiana law was unconstitutional.  In order to reverse the factual findings of a trial court, a reviewing court must find the factual findings are “clearly erroneous.”  Anderson v. Bessemer City, 470 U. S. 564, 573 (1985).  The Supreme Court held that the District Court’s factual findings were not clearly erroneous. Further, the Louisiana law was almost identical to the Texas admitting-privileges law that was recently struck down; the Court applied the same balancing test for the law’s benefits against the barriers to abortion access imposed.  Whole Woman’s Health v. Hellerstedt, 579 U. S. ___ (2016).  The Supreme Court held that the evidence presented at trial showed that the law would reduce access to abortions in Louisiana while providing no medical benefits.  Therefore, the law was an undue burden and unconstitutional.  REVERSED.