In the case of Ohio v. Akron Center for Reproductive Health et al., 1989, the U.S. Supreme Court upheld an Ohio law requiring minors to obtain parental consent or a court order before having an abortion. The law allowed for judicial bypass if it was in the minor's best interest or if she was mature enough to make her own decision. The Akron Center for Reproductive Health and others challenged this law as unconstitutional, arguing that it violated a minor’s right to privacy and placed undue burden on their access to abortions. The Supreme Court ruled 5-4 in favor of Ohio, stating that while minors do have some constitutional rights, these can be adjusted based on their age and maturity level. It held that states have significant interests in encouraging family involvement with such decisions without placing undue burdens on minors seeking abortions. This ruling further solidified state power over regulating abortions within certain boundaries set by previous cases like Roe v Wade (1973) and Planned Parenthood v Casey (1992).

In the dissenting opinion for Ohio v. Akron Center for Reproductive Health, Justice Blackmun argued that the majority's decision to uphold an Ohio law requiring one-parent notification before a minor could obtain an abortion was inconsistent with previous Supreme Court rulings on similar issues. He contended that this law placed undue burden on minors seeking abortions and violated their constitutional rights to privacy and bodily autonomy. Furthermore, he criticized the majority's reliance on findings from lower courts about parental involvement in minors' abortion decisions, arguing these were not based on substantial evidence but rather reflected personal beliefs about family relationships and dynamics. He also expressed concern that such laws would disproportionately affect disadvantaged young women who might be unable or unwilling to involve a parent in their decision due to fear of abuse or other negative consequences.