The U.S. Supreme Court case Planned Parenthood Association of Kansas City, Missouri, Inc., et al. v. Ashcroft, Attorney General of Missouri, et al., 1982 dealt with the constitutionality of a Missouri statute that imposed restrictions on abortions. The court upheld several provisions in the law including: requiring physicians to perform viability tests on fetuses at or beyond 20 weeks gestation; mandating parental consent for minors seeking an abortion (with a judicial bypass option); and necessitating written consent from women seeking abortions after being provided detailed information about fetal development and risks associated with abortion procedures. However, it struck down one provision which required all second-trimester abortions to be performed in hospitals rather than clinics due to its undue burden on women's access to safe and legal abortions.

In the dissenting opinion for Planned Parenthood Association of Kansas City, Missouri, Inc., v. Ashcroft, Attorney General of Missouri et al., 1982 case, Justice Stevens argued that the state's requirement for a second physician to be present during an abortion procedure was unnecessary and burdensome. He also disagreed with the majority's decision regarding parental consent for minors seeking abortions. According to him, this ruling could potentially infringe upon a minor’s constitutional right to privacy by requiring them to obtain parental or judicial approval before undergoing an abortion procedure. Moreover, he expressed concern over how these restrictions might disproportionately affect low-income women who may not have access to multiple physicians or legal resources necessary in obtaining judicial bypasses around parental consent laws.