(b) After the first trimester, the State, in promoting its interest in the health of the mother, may, if it chooses, regulate the abortion procedure in ways that are reasonably related to maternal health. (c) For the stage subsequent to viability, the State, in promoting its interest in the potentiality of human life may, if it chooses, regulate and even proscribe abortion, except where it is necessary, in appropriate medical judgment, for the preservation of the life or health of the mother.”

Resistance and Controversy
Opponents of the 1973 Supreme Court ruling, arguing that a fetus is entitled as a “person” to constitutional protection, attacked the decision on a variety of fronts. State legislative bodies were lobbied for statutes narrowing the implications of the decision and circumscribing in several ways the mother's ability to obtain an abortion. A nationwide campaign was instituted to amend the Constitution to prohibit or severely restrict abortion. “Right-to-life” groups also engaged in grass-roots political activity designed to defeat abortion proponents and elect abortion opponents. Abortion became, rather than simply a legal and constitutional issue, a major political and social controversy. Many state legislatures passed laws imposing additional procedural requirements on women who sought abortions; federal court decisions holding these new statutes unconstitutional usually followed each legislative initiative.

Recent Developments
The Reagan administration (1981-1989) and the Bush administration (1989-1992) supported the right-to-life position, as did many of their appointees to the federal judiciary. The Supreme Court, though sharply divided, generally declared unconstitutional those laws it found to place an undue burden on a woman's right to obtain an abortion. For example, in 1983 the Court reviewed three laws—from Akron, Ohio; Missouri; and Virginia—and struck down provisions requiring (1) a 24-hour waiting period; (2) that a doctor obtain a woman's “informed consent”; and (3) hospitalization for abortions after the first trimester of pregnancy. At the same time the Court upheld a Missouri provision that required a minor to obtain parental consent before an abortion but struck down an Akron ordinance with the same objective but which a majority of the justices found unduly restrictive. In a 1989 decision the Court let stand a Missouri requirement that before performing an abortion on any woman thought to be at least 20 weeks pregnant, a doctor must test whether the fetus could survive outside the womb.