In the case of H. L. v. Matheson, Governor of Utah, et al., 1980, a minor girl identified as "H.L." challenged a Utah law that required doctors to notify parents or guardians before performing an abortion on a minor unless there was a medical emergency or the parents could not be found after reasonable effort. The Supreme Court upheld this law in a 6-3 decision arguing that it did not violate any constitutional rights and served legitimate state interests such as protecting minors against their own immaturity and fostering family unity by encouraging parental consultation about significant decisions like abortions. The court also noted that while minors have some constitutional rights independent of their parents', these are more limited than those held by adults due to their unique vulnerability and potential for harm.

In the dissenting opinion for H. L. v. Matheson, Justice Marshall argued that the Utah law requiring physicians to notify parents before performing an abortion on a minor was unconstitutional because it violated a minor's right to privacy and could potentially deter them from seeking safe medical care out of fear of parental retaliation or abuse. He emphasized that while parents generally have authority over their children, this does not extend to overriding constitutional rights such as privacy in personal decisions like whether or not to terminate a pregnancy. Furthermore, he pointed out inconsistencies in how minors are treated under different laws - they can consent independently for other medical procedures but not abortions - which he saw as evidence of discrimination against pregnant minors specifically rather than genuine concern for their welfare.