In the 1978 case Bellotti v. Baird, the U.S. Supreme Court ruled on a Massachusetts law requiring minors to obtain parental consent for an abortion unless there was court approval for bypassing this requirement. The court held that while states have a significant interest in encouraging minors to seek parental guidance when considering an abortion, they cannot give parents absolute veto power over their child's decision. Instead, states must provide an alternative procedure where a minor can demonstrate either: she is mature enough to make her own decision or that performing an abortion would be in her best interests despite not having parental consent or being immature. In such cases, the state must permit a physician to perform the operation without notifying parents.

In the dissenting opinion for Bellotti v. Baird, Justice White argued that Massachusetts had a compelling interest in protecting minors and preserving family integrity which justified its requirement of parental consent or judicial approval before an abortion could be performed on a minor. He believed that the majority's decision undermined these interests by allowing minors to bypass their parents or courts entirely if they can convince a doctor that they are mature enough to make this decision independently. Furthermore, he disagreed with the majority's assertion that requiring parental involvement would necessarily lead to delay and medical risk for pregnant adolescents. Instead, he suggested it might encourage them to seek advice and support from their families during this difficult time.