The case of Michael O. Leavitt, Governor of Utah, et al., v. Jane L., et al., in 1995 revolved around the issue of abortion rights for minors and parental notification laws in the state of Utah. The plaintiffs were a group of anonymous pregnant minors who challenged a law requiring them to notify their parents before obtaining an abortion or seek judicial bypass if they could not safely do so. They argued that this law violated their constitutional right to privacy and was unduly burdensome on those seeking abortions. The Supreme Court ruled against the plaintiffs, upholding the constitutionality of Utah's parental notification requirement for minor girls seeking an abortion with certain exceptions allowed through judicial bypass procedures.

In the dissenting opinion for Michael O. Leavitt, Governor of Utah, et al., v. Jane L., et al., 1995, the justice argued that the majority's decision to uphold a lower court ruling allowing minors to obtain an abortion without parental consent or notification was flawed. The dissenting justice contended that this ruling undermined parents' rights and responsibilities in caring for their minor children and making important decisions on their behalf. They also expressed concern about potential harm to minors who might make such a significant decision without adult guidance or support. Furthermore, they disagreed with the majority's interpretation of constitutional privacy rights as encompassing a minor’s right to have an abortion without parental involvement under any circumstance.