In Re Initiative Petition No. 349, State Question No. 642

1992 OK 122, 838 P.2d 1, 65 O.B.A.J. 3225, 1992 Okla. LEXIS 177, 1992 WL 184028
CourtSupreme Court of Oklahoma
DecidedAugust 4, 1992
Docket76437
StatusPublished
Cited by126 cases

This text of 1992 OK 122 (In Re Initiative Petition No. 349, State Question No. 642) is published on Counsel Stack Legal Research, covering Supreme Court of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Initiative Petition No. 349, State Question No. 642, 1992 OK 122, 838 P.2d 1, 65 O.B.A.J. 3225, 1992 Okla. LEXIS 177, 1992 WL 184028 (Okla. 1992).

Opinions

KAUGER, Justice.

Although this proceeding, filed in reference to Initiative Petition No. 349 (petition/abortion petition), initially presented multiple issues, the United States Supreme Court’s decision in Planned Parenthood v. Casey, — U.S. -, -, 112 S.Ct. 2791, 2815, 120 L.Ed.2d 674 (1992) has rendered a single issue dispositive — whether Initiative Petition No. 349 is constitutional. We find: 1) that the issue of the constitutionality of the initiative petition is governed by the United States Supreme Court’s pronouncement in Casey; and that we are bound to follow the mandate of the United States Supreme Court on matters of federal con-, stitutional law; and 2) that when the unconstitutionality of the initiative petition is manifest, a pre-election judicial determina[3]*3tion of the issue is both appropriate and necessary to avoid a costly and useless election.

The Casey court held that: 1) a woman’s right to obtain an abortion is a liberty interest protected by the Due Process Clause of the Fourteenth Amendment;2 2) viability marks the earliest point at which the State’s interest is constitutionally adequate to justify a legislative ban on non-therapeutic abortions; and 3) before viability, a woman may choose to have an abortion without undue interference by the State. Because Oklahoma women who do not fall within four narrowly defined categories would be absolutely prohibited from exercising the pre-viability liberty interest expressly recognized by Casey, we are required to find the initiative petition unconstitutional. We also find that an examination of the constitutionality of the initiative petition is necessary, both to avoid misleading citizens about the legal effect of the proposition upon which they may vote, and to avoid a costly election which would ultimately be an exercise in futility. [Nevertheless, this ruling does not prohibit the circulation of a proper initiative petition or of legislation which passes constitutional muster.]

RELEVANT PROCEDURAL HISTORY

The proponents, Oklahoma Coalition to Restrict Abortion, Inc., and Fred W. Sellers, Jr. (collectively, proponents/Seilers) filed petition pamphlets with the Secretary of State on June 29, 1990. On December 31, 1990, the protestants, Nancy Feldman and Kim Little (collectively, Feldman) filed a protest to the legal sufficiency of the petition. On January 8, 1991, the Secretary of State filed the proposed ballot title prepared by the Attorney General. The proponents filed a timely appeal to the ballot title on January 17, 1991. Although Feldman also appealed the ballot title, the challenge was dismissed by order of this Court on April 13, 1992, as being untimely. However, a valid ballot title challenge is before us — the one filed by the proponents. The initial briefing period concerning the legal sufficiency of Initiative Petition No. 349 was commenced when this Court ordered a briefing schedule on March 3,1992. The final filings of the parties were submitted to the Court on June 4, 1992.

The issue of the constitutionality of the initiative petition was fairly raised within certain of the other issues raised by Feld-man in the challenge to the legal sufficiency of the petition.3 On July 14,1992, in the interest of fairness, we ordered the parties and the Attorney General to submit simultaneous briefs addressing Casey and its impact on the constitutionality of the proposed ballot title and the substance of Initiative Petition No. 349.4 Those briefs were filed on July 24, 1992.

[4]*4In response to this Court’s order of July-14, 1992, the proponents, Sellers, and the protestants, Nancy Feldman, Kim Little, Janet M. Taliaferro, Andrew Tevington, and Pam Fleischaker (collectively, protestants) and the Attorney General filed briefs specifically addressing the constitutionality of the initiative petition in relation to the United States Supreme Court’s decision in Planned Parenthood v. Casey, — U.S. -, -, 112 S.Ct. 2791, 2815, 120 L.Ed.2d 674 (1992). We also granted the amici’s motion to brief the issue. The protestants, the amici curiae, and the Attorney General assert that Initiative Petition No. 349 is unconstitutional under the United States Supreme Court’s ruling in Casey. As we read the proponents submission, they concede that the initiative petition was unconstitutional when it was drafted, that it was unconstitutional when it was circulated, and that it is unconstitutional now. However, the proponents insist that we should allow the petition to go forward as an exercise in political advocacy. We find that the initiative petition is unconstitutional based on controlling federal precedent enunciated by the United States Supreme Court as recently as June 29, 1992.

I.

THE CONSTITUTIONALITY OF THE INITIATIVE PETITION IS GOVERNED BY THE UNITED STATES SUPREME COURT’S PRONOUNCEMENT IN PLANNED PARENTHOOD v. CASEY. BECAUSE WOMEN WHO DO NOT FALL WITHIN FOUR NARROWLY DEFINED CATEGORIES MAY NOT EXERCISE THE PRE-VIABILITY LIBERTY INTEREST RECOGNIZED BY CASEY, WE ARE REQUIRED TO FIND THE INITIATIVE PETITION UNCONSTITUTIONAL.

When the initiative petition was filed, it appeared that a major re-examination of the law in relation to a woman’s right to obtain a nontherapeutic abortion was in progress. Legal commentators anticipated either the overruling or the substantial undercutting of the principles of Roe v. Wade, 410 U.S. 113, 163-64, 93 S.Ct. 705, 731-32, 35 L.Ed.2d 147, 182-83 (1973).5 In Webster v. Reproductive Health Serv., 492 U.S. 490, 518, 109 S.Ct. 3040, 3052, 106 L.Ed.2d 410, 435-36 (1989), the United States Supreme Court rejected the strict trimester approach of Roe v. Wade. The Webster Court also found that a State’s interest in protecting human life did not come into play only at viability as previously expressed in Roe.6 Additional evidence of the [5]*5uncertainty surrounding Roe’s continuance as a rule of law can be seen by the vote in Webster. Five Justices — Chief Justice Rehnquist, Justices White and Scalia, who have consistently voted to overrule Roe, as well as Justices O’Conner and Kennedy— joined in part IID of the majority opinion criticizing Roe.7

After June 29, 1992, when the United States Supreme Court promulgated its opinion in Planned Parenthood v. Casey, — U.S. -, -, 112 S.Ct. 2791, 2815, 120 L.Ed.2d 674 (1992), co-authored by Justices O’Conner, Kennedy, and Souter,8 which reiterates, and perhaps strengthens, the central premise of Roe — that women, may for some time period, make independent decisions to obtain nontherapeutic abortions — the submission could not go forward. Casey reaffirmed the central premise of Roe v. Wade, 410 U.S. 113, 153-54, 93 S.Ct. 705, 727, 35 L.Ed.2d 147, 177 (1973), reh’g denied, 410 U.S. 959, 93 S.Ct. 1409, 35 L.Ed.2d 694 (1973), that the right of privacy founded in the Fourteenth Amendment’s concept of personal liberty includes a woman’s right to have an abortion. Five members of the Casey Court’s precedential inquiry joined in part IIIA of the opinion which found that “Roe’s

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Bluebook (online)
1992 OK 122, 838 P.2d 1, 65 O.B.A.J. 3225, 1992 Okla. LEXIS 177, 1992 WL 184028, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-initiative-petition-no-349-state-question-no-642-okla-1992.