Planned Parenthood of the Heartlands, et al. v. Reynolds, et al.

Overview

(Supreme Court of Iowa, July 28, 2024) The Supreme Court of Iowa reversed the district court and overturned a temporary injunction against a fetal heartbeat law, declaring that abortion is not a fundamental right in Iowa and that abortion restrictions need only be rationally related to legitimate state interests. The district court had upheld the injunction, applying the “undue burden” test, but its analysis reflected the “unsettled terrain regarding the level of scrutiny to apply in this case.” The district court relied heavily on precedent from before Dobbs, especially an Iowa Supreme Court case that had established that abortion was not a fundamental right in Iowa but had failed to form a majority regarding how abortion regulations should be scrutinized. Reevaluating this question after Dobbs,the Supreme Court of Iowa decided 4-3 that abortion regulations in Iowa should instead be evaluated under the rational basis test, a low burden for restrictions to meet. Applying this reduced scrutiny, the Court held that the fetal heartbeat law is rationally related to the legitimate state interest of protecting unborn life and reversed the temporary injunction to enable the fetal heartbeat law to take effect. Read the full opinion here. 

View all cases in the Judicial Trends in Public Health – August 15, 2024.

View all cases under “Reproductive Liberties and Care Access.”