Planned Parenthood v. AG

CourtDistrict Court, D. New Hampshire
DecidedDecember 29, 2003
DocketCV-03-491-JD
StatusPublished

This text of Planned Parenthood v. AG (Planned Parenthood v. AG) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Planned Parenthood v. AG, (D.N.H. 2003).

Opinion

Planned Parenthood v . AG CV-03-491-JD 12/29/03 P UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Planned Parenthood of Northern New England, Concord Feminist Health Center, Feminist Health Center of Portsmouth, and Wayne Goldner, M.D. v. Civil N o . 03-491 JD Opinion N o . 2003 DNH 222 Peter Heed, Attorney General of New Hampshire

O R D E R

The plaintiffs bring an action pursuant to 42 U.S.C. § 1983,

seeking to have the Parental Notification Prior to Abortion Act

(“Act”), 1 passed by the New Hampshire legislature, declared

unconstitutional. The plaintiffs also seek an injunction to

prevent enforcement of the Act. The Attorney General contends

that the Act is constitutional and objects to an injunction.

At the plaintiff’s request, this case has been given

expedited consideration by the court in view of the fact that the

Act is due to become effective on December 3 1 , 2003.

1 2003 N.H. Laws ch. 173, effective date, December 3 1 , 2 be codified at N.H. Rev. Stat. Ann. (“RSA”) § 132:24-:28. After carefully reviewing the provisions of the Act and the

applicable United States Supreme Court precedents, the court has

concluded that the Act fails to meet the constitutional

requirements as determined by the United States Supreme Court.

Therefore, the Act cannot be enforced.

Background

In June of 2003, the New Hampshire Senate and House of

Representatives passed “AN ACT requiring parental notification

before abortions may be performed on unemancipated minors.” The

Act defines “abortion” a s : the use or prescription of any instrument, medicine, drug, or any other substance or device intentionally to terminate the pregnancy of a female known to be pregnant with an intention other than to increase the probability of a live birth, to preserve the life or health of the child after live birth, or to remove an ectopic pregnancy or the products from a spontaneous miscarriage.

RSA 132:24, I (eff. 12/31/03). The central provision of the Act

is a prohibition on abortion in the absence of parental

notification: No abortion shall be performed upon an unemancipated minor or upon a female for whom a guardian or conservator has been appointed pursuant to RSA 464-A because of a finding of incompetency, until at least 48 hours after written notice of the pending abortion has been delivered in the manner specified in paragraphs II and III.

2 RSA 132:25, I . Paragraph II requires written notice to be

addressed to the parent at the parent’s “usual place of abode”

and to be “delivered personally by the physician or an agent.”

Paragraph III provides an alternative to allow notice by

certified mail, return receipt requested, with delivery

restricted to the addressee. Notice is not required if the physician “certifies in the

pregnant minor’s medical record that the abortion is necessary to

prevent the minor’s death and there is insufficient time to

provide the required notice; or [ ] [t]he person or persons who

are entitled to notice certify in writing that they have been

notified.” RSA 132:26,I. If the pregnant minor does not want to

notify a parent, she may, alternatively, seek court authorization

for the abortion. RSA 132:26, I I . In that case, the court is

required to hold a hearing and then determine whether “the pregnant minor is mature and capable of giving informed consent

to the proposed abortion” or “whether the performance of an

abortion upon her without notification of her parent, guardian,

or conservator would be in her best interests.” Id. Such court

proceedings “shall be confidential and shall be given such

precedence over other pending matters so that the court may reach

a decision promptly and without delay so as to serve the best

interests of the pregnant minor.” RSA 132:26,II(b).

3 Violation of the Act carries penalties. “Performance of an

abortion in violation of this subdivision shall be a misdemeanor

and shall be grounds for a civil action by a person wrongfully

denied notification.” RSA 132:27. Liability may be avoided if

the person who performed the abortion can establish “by written

evidence that the person relied upon evidence sufficient to convince a careful and prudent person that the representations of

the pregnant minor regarding the information necessary to comply

with this section are bone [sic] fide and true, or if the person

has attempted with reasonable diligence to deliver notice, but

has been unable to do so.” Id.

The plaintiffs simultaneously filed their complaint and a

motion for a preliminary injunction to prevent the Act from being

enforced once it becomes effective on December 3 1 , 2003. The

Attorney General filed an objection, and the plaintiffs filed a reply. No surreply was filed. The parties have agreed that the

court may decide the plaintiffs’ requests for a declaratory

judgment and permanent injunctive relief on the merits based on

their present filings.

4 Discussion

The plaintiffs contend that the Act is unconstitutional

because it lacks an exception to the parental notice requirement

in circumstances when the delay would threaten the health of the

pregnant minor. They also contend that the Act’s exception to

prevent death is unconstitutionally narrow and that the confidentiality requirement for court proceedings is

insufficient. The Attorney General argues that a health

exception is not constitutionally required in a parental

notification law, that either the judicial bypass or other New

Hampshire statutes adequately protect the health of a pregnant

minor, that the Act would not be applied to physicians who act in

good faith, and that the confidentiality provision is sufficient.

I. Declaratory Judgment

Pursuant to 28 U.S.C. § 2201(a), the court “may declare the

rights and other legal relations of any interested party seeking

such declaration, whether or not further relief is or could be

sought.” The plaintiffs seek a declaration that the Act is

unconstitutional on its face.

The parties dispute the appropriate standard for evaluating

a facial challenge to the validity of a state law regulating

abortion. When plaintiffs bring a facial constitutional

5 challenge to state law, they ordinarily must show that “‘no set

of circumstances exists under which the Act would be valid.’”

Pharm. Res. & Mfrs. of Am. v . Concannon, 249 F.3d 6 6 , 77 (1st

Cir. 2001) (quoting United States v . Salerno, 481 U.S. 739, 745

(1987)), aff’d sub nom Pharm. Research & Mfrs. of Am. v . Walsh,

538 U.S. 644 (2003). That high hurdle, however, applies only when the plaintiffs challenge a state law “that does not regulate

constitutionally protected conduct.” Donovan v . City of

Haverhill, 311 F.3d 7 4 , 77 (1st Cir. 2002).

In Casey, the Court considered the facial constitutionality

of a Pennsylvania law that imposed conditions on performing

abortions for both adult and minor patients and, without

mentioning Salerno, applied a standard of whether the challenged

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