In the case of Neal F. Hartigan, Attorney General of Illinois, et al. v. David Zbaraz and Allan G Charles etc., 1987, the U.S Supreme Court ruled on an Illinois law that required a minor to notify both parents before obtaining an abortion or seek judicial bypass if parental notification was not possible or safe for her well-being. The court held that this law violated constitutional rights as it placed undue burden on minors seeking abortions by potentially delaying access to medical services due to its stringent requirements for judicial bypasses in cases where notifying parents could be harmful or impossible. Furthermore, the requirement for two-parent notification was deemed unnecessary and burdensome without significantly furthering any state interest in protecting family integrity.

In the dissenting opinion for Hartigan v. Zbaraz, Justice White argued that the Illinois Abortion Law of 1975 did not violate a woman's constitutional right to privacy as established in Roe v. Wade because it only required a minor seeking an abortion to notify her parents or obtain judicial consent if she could not do so. He believed this law was designed to protect minors from making uninformed decisions and ensure their wellbeing rather than restrict access to abortions. Furthermore, he disagreed with the majority’s view that these requirements posed an undue burden on women's rights, arguing instead they were reasonable measures intended for child protection purposes.