The case of Thomas Dalton, Director, Arkansas Department of Human Services et al. v. Little Rock Family Planning Services et al., 1995 revolved around the constitutionality of an Arkansas statute that required all abortions to be performed in hospitals or licensed abortion facilities and prohibited public funding for nontherapeutic abortions. The Supreme Court ruled that the law was unconstitutional as it placed an undue burden on women seeking abortions by limiting their access to safe and legal procedures. Furthermore, they found no compelling state interest justifying such restrictions which violated a woman's right to privacy under the Fourteenth Amendment's Due Process Clause as established in Roe v Wade (1973). This decision reaffirmed the court’s commitment towards protecting women’s reproductive rights against unnecessary state interference.

In the dissenting opinion for Thomas Dalton, Director, Arkansas Department of Human Services et al. v. Little Rock Family Planning Services et al., Justice Stevens argued that the majority's decision to uphold an Arkansas statute requiring women under 18 seeking abortions to notify their parents was a departure from previous Supreme Court rulings on abortion rights. He contended that this law placed an undue burden on young women by potentially subjecting them to physical or emotional abuse if they were forced to tell their parents about their decision. Furthermore, he pointed out that many minors might not be able to navigate the judicial bypass option provided in the law due to lack of resources or knowledge. Therefore, he believed that this legislation violated these individuals' constitutional right to privacy and access safe medical procedures without unnecessary obstacles.