Eubanks v. Schmidt

126 F. Supp. 2d 451, 2000 U.S. Dist. LEXIS 19021, 2000 WL 1886263
CourtDistrict Court, W.D. Kentucky
DecidedDecember 21, 2000
DocketCIV.A.3:99CV107H
StatusPublished
Cited by15 cases

This text of 126 F. Supp. 2d 451 (Eubanks v. Schmidt) is published on Counsel Stack Legal Research, covering District Court, W.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eubanks v. Schmidt, 126 F. Supp. 2d 451, 2000 U.S. Dist. LEXIS 19021, 2000 WL 1886263 (W.D. Ky. 2000).

Opinion

MEMORANDUM OPINION

HEYBURN, District Judge.

This Court now considers whether Kentucky’s Abortion Informed Consent Statute, Ky. Rev. Stat. § 311.725 (Michie Supp.2000) (the “Informed Consent Statute” or the “Statute”) is valid and enforceable under the United States Constitution. The Statute’s provisions are similar to the portions of the Pennsylvania law which the Supreme Court upheld in Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833, 112 S.Ct. 2791, 120 L.Ed.2d 674 (1992). Like the Pennsylvania law, the Statute requires that physicians inform women about certain specific medical and social information and offer them two state published pamphlets at least twenty-four hours before any abortion procedure. One pamphlet describes fetal development and the other pamphlet lists resources available to the woman. Unlike the Pennsylvania law, the Kentucky Statute requires physicians to pay for the costs of these pamphlets. 1

Women have a right to choose to have an abortion before viability and to obtain it without the state imposing any undue burden. Casey, 505 U.S. at 878, 112 S.Ct. 2791. States have legitimate interests as well. Here, the state legislature wanted women seeking abortions to make a more informed and deliberate decision, no doubt hoping that they would opt for childbirth instead. See Casey, 505 U.S. at 883, 112 S.Ct. 2791 (holding that a state may express a preference for childbirth over abortion). The issue in this case is whether the legislature reasonably asserted the state’s legitimate interests without unduly compromising the constitutional rights of women.

Many of the same legal principles which the Court set out in Eubanks v. Stengel, 28 F.Supp.2d 1024 (W.D.Ky.1998), guide the analysis here. 2 Because the Statute and *453 the Pennsylvania law are similar, logic suggests that Casey controls the outcome in this case. However, Casey does not preordain that result. The Supreme Court left open the possibility that future plaintiffs could prove that a similar regulation might be unconstitutional. Casey, 505 U.S. at 887.

The Court concludes that the Statute does not violate the United States Constitution. It has substantially similar effects as the law upheld in Casey. Plaintiffs have not shown a greater undue burden on women seeking an abortion in Kentucky. The requirement that physicians pay the cost of the state pamphlets does not offend the First Amendment of the Constitution.

I.

Plaintiffs ask the Court to permanently enjoin enforcement of the Statute on behalf of themselves and their patients. 3 The Court has federal question jurisdiction because Plaintiffs challenge a state statute under the United States Constitution. 28 U.S.C. § 1331 (2000). Plaintiffs can assert both their own constitutional claims as well as those of their patients. As physicians, they may face disciplinary proceedings under the Statute and, thus, may seek pre-enforcement review. Doe v. Bolton, 410 U.S. 179, 188, 93 S.Ct. 739, 35 L.Ed.2d 201 (1973). Their patients face many practical obstacles to asserting their own claims. Singleton v. Wulff, 428 U.S. 106, 115-16, 96 S.Ct. 2868, 49 L.Ed.2d 826 (1976); Eubanks, 28 F.Supp.2d at 1029.

II.

To analyze the Statute and its potential impact, one must first understand the current informed consent procedures at abortion clinics. The parties generally agree on current practice.

A woman who believes that she is pregnant calls the clinic for an appointment. At that time, she is asked to estimate the gestation age of her fetus based on her last menstrual period. The clinic tells her what she must bring to her appointment. For example, she is told the cost of the procedure and that she must have someone drive her home after the procedure. The woman is free to ask any questions about the procedure or possible alternatives. However, the clinic does not initiate counseling at that time. Upon arrival for her appointment, each woman must pay for the procedure in cash. If the woman cannot pay in full, her appointment is rescheduled. Upon payment of the fee, the woman receives an ultrasound to determine gestation age of her fetus. 4 The woman is then ushered into a room with other women where they are shown a film that describes the abortion procedure and its risks. After the film, each woman speaks one on one with a clinic counselor. If the woman expresses ambivalence, the counselor encourages her to reschedule the procedure. Otherwise, the counselor *454 asks the woman to sign an informed consent form. Thereafter, anesthesia is administered, if used, and the physician can begin the procedure. The entire procedure — from the time a woman arrives for her appointment until she leaves — takes approximately half a day.

III.

The Informed Consent Statute’s avowed purpose is to change the manner in which women make the decision to proceed with an abortion. The Statute does this in much the same manner as the Pennsylvania law at issue in Casey. However, the Statute’s precise requirements are not entirely clear. For instance, the Statute requires that at least twenty-four hours prior to an abortion procedure, physicians provide all patients with specific medical and social service information. Plaintiffs and Defendants disagree over whether the Statute requires one or two trips to the abortion provider to satisfy the requirement that the information be provided in an “individual, private setting.” Plaintiffs argue that a telephone call meets the statutory requirements while Defendants claim that the Statute requires an in-person visit to accurately determine the age of the fetus.

The Court cannot say that the Statute actually requires two visits. Its plain language may allow some telephone consultations. Based on the evidence, however, the Court concludes that some women would find it extraordinarily difficult to comply with the Statute without two personal visits if they ask to review the pamphlets. Absent a federal constitutional challenge, this Court would have no reason to clarify the Statute’s potential ambiguity. However, one reasonable statutory interpretation raises obvious constitutional issues. To determine the Statute’s constitutionality, therefore, this Court must assume that the Statute requires two visits for some women.

IV.

Plaintiffs bring a facial challenge. Such a challenge faces high hurdles because courts are reluctant to decide cases based on uncertain future events. United States v. Salerno,

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Bluebook (online)
126 F. Supp. 2d 451, 2000 U.S. Dist. LEXIS 19021, 2000 WL 1886263, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eubanks-v-schmidt-kywd-2000.