Adapting to a World Without Third-Party Standing: How Reproductive Rights Advocacy Organizations Can Challenge Anti-Abortion Statutes Through Associational Standing
President Trump and other conservative legislators have often made grand statements about overturning Roe v. Wade and returning abortion law to the states. Many commentators, however, expect the Court and other conservative actors to continue their more subtle approach of slowly chipping away at the rights granted in Roe without explicitly overturning the case. Recently, one such effort to chip away at Roe has taken the form of a procedural attack on standing. Under a traditional standing analysis, a plaintiff may only attempt to vindicate her own constitutional rights and not the rights of some individual who is not a party to the case. If applied strictly, this rule would prohibit an abortion clinic from arguing that a law imposes an undue burden on its patients. Since 1976, however, the Court has permitted abortion clinics to sue on behalf of their patients under the doctrine of third-party standing. Third-party standing permits a plaintiff (e.g., an abortion clinic) to assert standing on behalf of some third party (e.g., a patient) when a close relationship exists and when the third party faces a hindrance making it difficult for her to challenge the law herself.
Multiple Supreme Court justices and some commentators have recently argued that clinics should not qualify for third-party standing. If a majority of the Court adopts this position, lawsuits challenging abortion restrictions will need to include an individual plaintiff with standing to challenge the law (clinics may still join the suit as additional parties). This attack on standing chips away at Roe by making it harder to challenge state statutes restricting abortion access. First, women may not want to bring lawsuits challenging abortion restrictions because the suits may negatively impact their personal and professional lives. After all, 46% of Americans identify as pro-life, 47% view abortion as morally wrong, and 20% want abortion illegal in all circumstances. What if a work supervisor or family member in that 20% of the population heard about the lawsuit? An individual could lose her job or relationship. Worse yet, abortion providers in 2019 reported 22,366 incidents of online harassment, 1,507 cases of trespassing, and 8 bomb threats. Professional clinics are better positioned to handle these tense situations than individual plaintiffs. Although suing under a pseudonym alleviates some of these concerns, it would still be difficult to hide involvement in a high-profile suit from friends, family members, and employers, any one of whom could leak information to the general public.
In addition to the heightened risks that an individual may face when challenging abortion restrictions, the Court has also recognized an incentive problem that exists in this type of lawsuit. Since litigation is costly, time-intensive, and controversial, individuals have little reason to challenge laws that do not directly affect them. Women seeking abortions are directly burdened by spousal consent requirements or waiting periods and therefore have some incentive to challenge them in court. However, individuals do not immediately feel the burden of other regulations like strict credentialing standards and hospital admit privilege requirements. Although these regulations may eventually burden individual women by forcing clinics to close, they are much less visible until their negative effects are difficult to reverse. Therefore, without third-party standing, nobody is in a good position to challenge back-end process regulations until they have already imposed a substantial, irreversible burden on patients.
This Article makes the novel argument that reproductive rights advocacy organizations can directly challenge restrictive anti-abortion statutes through associational standing. The doctrine of associational standing allows organizations to sue on behalf of their members. It has many of the same benefits as third-party standing: (most of) the anonymity that third-party standing provides, the ability to leverage the time and resources of a larger organization, and a high incentive to challenge all types of statutes restricting abortions. Although abortion clinics may not qualify for associational standing, many reproductive rights organizations likely have standing to challenge abortion restrictions on behalf of their members. This Article will first summarize the rise and fall of third-party standing for abortion clinics and will then argue that advocacy organizations have associational standing to directly challenge abortion restrictions.
The Rise and Fall of Third-Party Standing for Abortion Providers
The traditional rules of standing prevent plaintiffs from appearing in federal court unless they meet several “Case” and “Controversy” requirements rooted in Article III of the Constitution as well as some additional rules imposed by the Court. One such rule requires the plaintiff to argue that the defendant violated that plaintiff’s rights, not the rights of some uninvolved third party. According to this rule, an abortion clinic could argue that an anti-abortion statute impaired its own ability to operate as a business; it could not, however, argue that the statute violated the fundamental reproductive rights of women. This distinction matters because courts review claims of economic harm with a very deferential “rational basis” standard, but they review restrictions on fundamental reproductive rights with the more critical “undue burden” standard. Thus, under traditional standing doctrine, abortion clinics have a low probability of successfully challenging anti-abortion laws.
As explained in the Background, third-party standing is an exception to general standing doctrine that sometimes permits a plaintiff to assert the rights of others in a lawsuit. In addition to satisfying the Article III requirements, a plaintiff seeking to establish third-party standing must (1) maintain a close relationship with the third party and (2) show that the third party faced some hindrance in asserting her own rights. Shortly after creating the doctrine, the Supreme Court in 1976 granted abortion providers third-party standing to sue on behalf of their patients.
Since gaining third-party standing rights in Singleton, abortion providers have been essential to challenging unconstitutional restrictions on reproductive rights. For example, the Court recently cited eight separate Supreme Court cases brought by abortion clinics with third-party standing. Many of these cases treated the issue as so clear that they did not even discuss standing at all. Another study found that in the three years between Roe and Singleton, approximately 32% of the challenges to abortion laws in federal courts were filed by clinics; since the Singleton decision in 1976, clinics account for 76% of the challenges to abortion laws in federal courts. This data confirms the important role of clinics in challenging anti-abortion laws and demonstrates the widespread acceptance of their standing to do so.
Recently, however, the legitimacy of third-party standing for abortion providers has been called into question by both scholars and members of the Court. These arguments against third-party standing are best summarized in Justice Alito’s dissenting opinion in June Medical Services. First, Alito argued that the interests of an abortion provider do not align with those of the patient when the provider challenges regulations intended to advance the safety of the patient. In June Medical Services, the stated purpose of the regulation was to protect the patient’s health and the effect was to increase the regulatory burden on the clinics. Alito saw a conflict of interest here: it is in the clinic’s self-interest to challenge the burdensome regulation, but it is not in the patient’s best interests because the regulation was passed to protect the patient. The natural response to this argument is that the regulation was not passed to protect the patient; that is the whole point of the litigation. However, according to Alito’s rationale, that is an argument on the merits of the law, which cannot be addressed until the plaintiff establishes standing. Under this logic, there is an inherent conflict of interest that could prevent clinics from establishing third-party standing.
Justice Alito then proceeded to argue that abortion clinics do not meet the two requirements for third-party standing. He first questioned the “closeness” of the relationship between a doctor performing an abortion and her patient and even quoted a statement that there is “no doctor/ patient relationship” between a doctor performing an abortion and her patient. Alito also argued that women face no hindrance to challenging restrictive statutes themselves. He focused on the two hindrances discussed in Singleton: privacy concerns for the plaintiff and the likelihood of a pregnancy ending before the lawsuit, thereby mooting the case. Regarding the privacy issue, Alito suggested that women could sue under a pseudonym and follow the other procedures established to protect anonymity in the courtroom. Regarding the concern about mootness, Alito stated that the capable-of-repetition-yet-evading-review exception to mootness solves the problem of a pregnancy ending prior to a lawsuit’s conclusion.
Justice Alito’s arguments were convincing enough to gain the support of Justices Thomas and Gorsuch. Although Justice Kavanaugh did not join this section of Alito’s dissent, his opinion on third-party standing remains unknown, as does that of Justice Barrett. Since Alito’s dissent could potentially become the Court’s majority view in the next few years, advocates of reproductive rights need to consider alternative ways to challenge burdensome anti-abortion laws. Associational standing may provide one such avenue.
Associational Standing for Reproductive Rights Organizations
As support for third-party standing dwindles, reproductive rights advocacy organizations should consider challenging anti-abortion laws through associational standing. Associational standing allows an organization to assert standing on behalf of its members in certain situations where the remedy will benefit the members who have been injured. This doctrine expands access to the courts by allowing members to benefit from an organization’s “pre-existing reservoir of expertise and capital.” Furthermore, since individuals often join an organization “to create an effective vehicle for vindicating interests that they share with others,” the organization is generally well-positioned to represent its members.
After establishing associational standing, an organization can assert the rights of its members in the same way that a clinic with third-party standing can assert the rights of its patients. An organization seeking associational standing must show that: “(a) its members would otherwise have standing to sue in their own right; (b) the interests it seeks to protect are germane to the organization's purpose; and (c) neither the claim asserted nor the relief requested requires the participation of individual members in the lawsuit.”The following sections will first explore who might qualify as an “organization” and will then assess how such an organization could satisfy the three required elements.
- Qualifying as an Organization
Prior to asserting associational standing, a litigant must first qualify as an organization. The Court has never clearly defined the term “organization,” but it has described the necessary traits in various cases. First, in easy cases involving clear organizations like unions and trade associations, the Court has begun its associational standing analysis without even discussing the preliminary organization question. This suggests that courts will not apply a technical definition of organization when the answer is clear. Second, even in hazier circumstances involving larger organizations with broader interests like national environmental groups or the NAACP, the Court has not spent much time on the definition of an organization. These cases are less clear than those involving unions because groups like Sierra Club and the NAACP are national organizations whose members have diverse interests and reasons for joining the association. Nevertheless, the Court has easily classified both of these groups as organizations.
In the seminal case Hunt v Washington State Apple Advertising Commission, the Court confirmed its functionalist approach to defining an organization. There, a state agency sought to assert associational standing on behalf of the apple growers and dealers it regulated. On its face, an agency is clearly not an association. It does not have members, participation is not voluntary, and it is an arm of the government. Nonetheless, the Court held that the agency served similar functions to those of an organization and that it therefore had standing. These functions included (1) a “purpose of protecting and enhancing” apple sales, (2) the election of the agency’s Commissioners by the apple companies, (3) the financing of the agency through taxes solely on the apple companies, and (4) the agency’s own interests in the outcome of the litigation. This opinion shows the Court’s willingness to extend associational standing to any group that functionally serves as an “organization” representing the interests of its “members.”
Based on these broad definitions of an organization, there are several types of groups that could challenge laws restricting abortion access on behalf of their members. The strongest option would be a reproductive rights organization like NARAL or the National Network of Abortion Funds (hereinafter “NNAF”). Like Sierra Club and the NAACP, both of these groups have pages soliciting membership and encouraging donations as part of the membership process. Sierra Club’s membership options appear to be at a state-level, which may help satisfy the requirement that members have standing to sue in their own right. However, since the NAACP offers membership at a national level and courts have granted it associational standing, this distinction is likely not critical. In addition to its resemblance to Sierra Club and the NAACP, the NNAF permits some members to participate in leadership bodies, which aligns with one of the functionalist organization traits from Hunt.
As a second option, a hybrid group like Planned Parenthood that provides some medical services and engages in some advocacy may qualify as an organization under these criteria. Like the NAACP and Sierra Club, one can become a member of the Planned Parenthood Action Fund (hereinafter “PPAF”). Like the agency with a clear purpose to benefit its “members” in Hunt, the PPAF has a clearly stated purpose of increasing access to birth control, abortion, and health care equity. This aligns with the interests of its members who presumably join to advance that goal. Additionally, PPAF seeks donations from members to support its organization and is therefore at least partially funded by something similar to a membership fee. Finally, like the agency in Hunt, Planned Parenthood has personal stakes in the outcome of the litigation. Even though Planned Parenthood could be viewed as both a provider of medical services and an advocacy organization, there is nothing in the case law preventing this type of hybrid organization from asserting associational standing.
A third and least likely option would be for an abortion clinic to assert associational standing. This argument is unlikely to succeed but may be possible under the functionalist Hunt approach. After all, the purpose of a clinic is to offer reproductive health services, which aligns closely with the interests of its “members” seeking to exercise their reproductive rights. Like the agency in Hunt that was funded solely by taxes on the apple companies (its pseudo-members), a private clinic is funded primarily by its patients (its pseudo-members). With that being said, it seems unlikely that this Court would stretch the definition of an organization that far. Unlike the agency in Hunt, most women visiting a clinic do not have the same kind of on-going relationship that would make them a member of the clinic. The fees they pay would likely also be viewed more like a payment for services than a membership fee. In conclusion, there are three types of advocacy organizations that could potentially qualify for standing: pure reproductive rights organizations like NARAL (most likely), hybrid groups like Planned Parenthood (fairly likely), and pure medical groups that perform abortions but do not engage in advocacy (least likely).
- Members with Standing to Sue in Their Own Right
A litigant that qualifies as an organization must then satisfy the three criteria for associational standing. The first of these criteria requires that a group’s “members would otherwise have standing to sue in their own right.” This element simply requires an organization to show that some of its members would have standing to sue on their own. Although the Court does not often state this with clarity, it has explained at least once that “[t]he association must allege that its members, or any one of them, are suffering immediate or threatened injury.” The organization may submit affidavits from its member(s) or submit other evidence to show that its members are indeed suffering an injury.
This element should be relatively straightforward for a reproductive rights organization to satisfy. The organization would need to find at least one member (and preferably more) in a given state who is suffering some immediate or threatened injury from a statute restricting access to reproductive services. For a law restricting abortion access, this would likely be a woman who is in the early stages of her pregnancy, is considering an abortion, and is facing some burden due to the law. A drawback of this approach is that, like in an individual suit, this member’s privacy could be threatened. Unlike a suit filed by a clinic with third-party standing, the member’s name could appear on the court records or other public documents. Still, if the only options are for a woman to sue individually or for a woman to submit one affidavit so an organization may sue on her behalf, the latter seems to protect her privacy much more effectively. The court could keep the member’s name private and the chances of that information leaking out are probably lower than in a pseudonymous suit. Furthermore, submitting an affidavit is less onerous and time consuming than bringing a pseudonymous lawsuit. Thus, even though this option is less attractive than third-party standing, it is still much more appealing than requiring a woman to sue under a pseudonym.
- Interests That Are Germane to the Organization’s Purpose
Organizations will most likely be able to show that the interests at stake in the litigation are germane to their purpose. The “germaneness” element requires a close relationship between the interests at stake and the purpose of the organization. In Hunt, for example, the agency’s “purpose [was] protecting and enhancing the market for Washington apples” and the challenged law would obliterate the market by making it nearly impossible to label Washington apples differently than apples from other states. Since the agency’s purposes were clearly germane to the interests at stake in the lawsuit, it easily satisfied this second element. Similarly, an organization like NARAL or Planned Parenthood should have no problem with the germaneness requirement. For example, NARAL’s mission, which includes efforts to “organize and mobilize to protect . . . freedom by fighting for access to abortion care [and] birth control,” is certainly germane to a suit challenging a law allegedly restricting access to abortion and birth control. Thus, this second element should be easy for reproductive rights organizations to satisfy.
- Requiring the Participation of Individual Members in the Lawsuit
Reproductive rights advocacy organizations are also likely able to meet the final criteria from Hunt. This element mandates that neither the cause of action nor the proposed relief require individual members to participate in the suit. The first half of this element effectively bars organizations from bringing claims requiring an individualized analysis of the injury. For example, claims relating to the Free Exercise Clause may require a plaintiff “to show the coercive effect of the enactment as it operates against him in the practice of his religion.” When a church argued that an abortion restriction violated the Free Exercise rights of its members, the Court declined to grant it associational standing because its analysis of the law’s injury to each member would be too individualized. Given the diversity of opinion about abortion within the church and the individualized ways in which the law may impact free exercise rights, the Court felt that individual members were better positioned to bring this claim.
The second half of the element functions in a similar way but applies to situations where the proposed relief – as opposed to the claim – is too individualized to grant to an organization. Remedies like injunctions, declaratory judgments, and other forms of prospective relief are broad and apply uniformly to all parties; their benefits will therefore flow evenly to the members of an organizations. Meanwhile, damages for things like lost profits or reliance expenditures are too fact-specific and particularized to award to an organization on behalf of members. Individual members are better positioned to sue for these types of damages than an organization.
Reproductive rights groups will probably satisfy this third element. Regarding the first half of this element, courts have never treated claims under Roe and its progeny as requiring an individualized analysis of the injury. Instead, these cases tend to include pages of facts, statistics, and evidence about the broad, general benefits of a law and the burdens that the law imposes on fundamental reproductive rights. The fact that clinics bring these cases on behalf of broad groups of patients strengthens the fact that this fundamental right does not require particularized, specific evidence of injury in the same way that the Free Exercise Clause requires. Indeed, since these claims have regularly been brought by representatives via third-party standing, they are particularly likely to satisfy this requirement. Regarding the second half of this element, the remedy sought in cases challenging abortion restrictions will almost always qualify for associational standing. Plaintiffs typically ask for injunctions against these laws, not to receive individualized compensatory damages. Since the benefits of these prospective remedies flow to all members of an organization and the claim does not require a showing of individualized harm, reproductive rights organizations are well-positioned to satisfy the final element.
Abortion providers have had third-party standing to bring claims on behalf of their patients for almost 40 years. Nonetheless, due to creative arguments by anti-choice advocates and a new Supreme Court composition, this exception to traditional standing doctrine may not be available to providers in just a few years. Changes to standing rules might not make the headlines in the same way that a Roe reversal would, but they would certainly chip away at the fundamental rights of women by making it harder to challenge restrictive anti-abortion laws. After all, forcing women to challenge these laws as individual plaintiffs puts their personal relationships and livelihood at risk; it also decreases the likelihood of back-end regulations being challenged due to the incentive problem discussed earlier.
Associational standing provides another avenue for organizations to challenge restrictive anti-abortion statutes on behalf of the affected individuals. Although clinics themselves may not qualify for associational standing, major organizations like NARAL and Planned Parenthood likely have standing under this doctrine. The doctrine offers many of the same benefits as third-party standing: similar levels of privacy, access to the resources and knowledge of a larger organization, and a solution to the incentive problem arising in individual suits. Thus, as third-party standing falls out of favor with the Court, associational standing may be the best way for organizations to protect the fundamental rights guaranteed by Roe.
 See, e.g., Aaron Blake, Trump Makes Clear Roe v. Wade Is on the Chopping Block, THE WASHINGTON POST (July 2, 2018, 11:23 AM), https://www.washingtonpost.com/news/the-fix/wp/2018/07/02/trump-makes-cl... Sahil Kapur, Republicans May Have a Real Shot at Overturning Roe v. Wade. But Political Danger Lurks., NBC NEWS (Oct. 5, 2020), https://www.nbcnews.com/politics/2020-election/republicans-may-have-real... Jessica Levinson, Trump's Promise to Overturn Roe v. Wade May Still Come True, MSNBC (Apr. 16, 2021, 3:08 PM), https://www.msnbc.com/opinion/trump-s-promise-overturn-roe-v-wade-may-st....
 See, e.g., Selina K. Hewitt, Note, Hodgson v. Minnesota: Chipping Away at Roe v. Wade in the Aftermath of Webster, 18 PEPP. L. REV. 955 (1991); Jason Swindle, Chipping Away at Roe v. Wade, THE TIMES-NEWS (Mar. 17, 2020, 5:37 PM), https://www.valleytimes-news.com/2020/03/chipping-away-at-roe-v-wade.
 Mary Ziegler, The Question No One Is Asking About the Supreme Court and Abortion, THE WASHINGTON POST (Mar. 5, 2020, 5:00 AM), https://www.washingtonpost.com/outlook/2020/03/05/question-no-one-is-ask....
 Robert Allen Sedler, Standing to Assert Constitutional Jus Tertii in the Supreme Court, 71 YALE L.J. 599, 599–600 (1962).
 Singleton v. Wulff, 428 U.S. 106, 119 (1976).
 Kowalski v. Tesmer, 543 U.S. 125, 130 (2004).
 June Med. Servs., 140 S. Ct. at 2165–71 (2020).
 Lydia Saad, Americans' Abortion Views Steady in Past Year, GALLUP (June 29, 2020), https://news.gallup.com/poll/313094/americans-abortion-views-steady-past....
 NATIONAL ABORTION FEDERATION, 2019 VIOLENCE AND DISRUPTION STATISTICS 2 (2019), https://5aa1b2xfmfh2e2mk03kk8rsx-wpengine.netdna-ssl.com/wp-content/uplo....
 Campbell v. Louisiana, 523 U.S. 392, 398 (1998). See also Brief for Former Federal Judges and Department of Justice Officials as Amici Curiae Supporting Petitioners, June Med. Servs. L.L.C. v. Gee, 140 S. Ct. 2103 (2020) (Nos. 18-1323, 18-1460), 2019 WL 6524881.
 This author did not find any federal challenges to anti-abortion statutes discussing associational standing. There are a few state court cases granting associational standing to reproductive rights organizations, but they do not discuss the issue in any depth. Since state courts are not bound by Article III standing requirements, the holding is not especially relevant to plaintiff bringing a federal claim. See, e.g., Pro-Choice Mississippi v. Fordice, 716 So. 2d 645, 664 (Miss. 1998); New Mexico Right to Choose/NARAL v. Johnson, 1999-NMSC-005, ¶ 14, 126 N.M. 788, 975 P.2d 841, 847.
 There is not space here to elaborate on Article III standing requirements. For a detailed discussion of Article III standing, see Lujan v. Defs. of Wildlife, 504 U.S. 555, 560–61 (1992).
 Sedler, supra note 4.
 Kowalski v. Tesmer, 543 U.S. 125, 130 (2004).
 See generally Singleton v. Wulff, 428 U.S. 106 (1976).
 June Med. Servs. L.L.C. v. Russo, 140 S. Ct. 2103, 2118 (2020).
 Brandon L. Winchel, Note, The Double Standard for Third-Party Standing: June Medical and the Continuation of Disparate Standing Doctrine, 96 NOTRE DAME L. REV.421, 442–43 (2020) (citing Teresa Stanton Collett, Symposium: After 40+ Years It Is Clear Women Can Speak for Themselves, SCOTUSBLOG (Jan. 30, 2020, 10:10 AM), https://www.scotusblog.com/2020/01/symposium-after-40-years-it-is-clear-...). Although Collett uses the data to argue that abortion clinics are suing to protect their own interests, the data at least shows a widespread acceptance and usage of third-party standing in lawsuits challenging abortion restrictions.
 See, e.g., June Med. Servs., 140 S. Ct. at 2166 (Alito, J., dissenting); Stephen J. Wallace, Note, Why Third-Party Standing in Abortion Suits Deserves A Closer Look, 84 NOTRE DAME L. REV. 1369 (2009); Winchel, supra note 15; Collett, supra note 15.
 June Med. Servs., 140 S. Ct. at 2165–71.
 Id. at 2166–68.
 Id. at 2166.
Id. at 2167–69.
 Id. at 2168.
 Id. at 2168–69.
 Warth v. Seldin, 422 U.S. 490, 515 (1975).
 Int'l Union, United Auto., Aerospace & Agr. Implement Workers of Am. v. Brock, 477 U.S. 274, 275 (1986).
 Id. at 275–76.
 Hunt v. Washington State Apple Advert. Comm'n, 432 U.S. 333, 343 (1977).
 Brock, 477 U.S. at 281–88 (applying the three prongs from Hunt to determine whether a union has associational standing without questioning whether that union qualifies as an organization); Nat'l Motor Freight Traffic Ass'n v. United States, 372 U.S. 246, 247 (1963) (easily finding that an association of motor carriers has standing to challenge an Interstate Commerce Commission order on behalf of its members).
 See, e.g., Sierra Club v. Morton, 405 U.S. 727, 738–40 (1972) (“It is clear that an organization whose members are injured may represent those members in a proceeding for judicial review . . . . The Sierra Club is a large and long-established organization.”); Nat'l Ass'n for Advancement of Colored People v. Button, 371 U.S. 415, 431, (1963) (“The NAACP is not a conventional political party; but the litigation it assists, while serving to vindicate the legal rights of members of the American Negro community, at the same time and perhaps more importantly, makes possible the distinctive contribution of a minority group to the ideas and beliefs of our society. For such a group, association for litigation may be the most effective form of political association.”).
 Hunt, 432 U.S. at 341–46.
 Id. at 341.
 Id. at 344–45.
 Id. at 344.
 Id. at 344–45.
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 Hunt v. Washington State Apple Advert. Comm'n, 432 U.S. 333, 343 (1977).
 See, e.g., Int'l Union, United Auto., Aerospace & Agr. Implement Workers of Am. v. Brock, 477 U.S. 274, 286 (1986) (finding that the first element was satisfied because “at least some members of the UAW would have had standing to bring this suit in their own right”).
 Warth v. Seldin, 422 U.S. 490, 511 (1975) (emphasis added).
 Id. at 501–02.
 Hunt, 432 U.S. at 343.
 Id. at 344.
 Id. at 337–38.
 Who we are, NARAL, https://www.prochoiceamerica.org/about (last visited Apr. 23, 2021).
 Id. at 343.
 Harris v. McRae, 448 U.S. 297, 321 (1980) (quoting Abington School Dist. v. Schempp, 374 U.S. 203, 223 (1963)) (emphasis added).
 Warth v. Seldin, 422 U.S. 490, 515 (1975).
 Id. at 515–16.
 See, e.g., Planned Parenthood of Se. Pennsylvania v. Casey, 505 U.S. 833, 888–91 (1992).