Schulte v. Douglas

567 F. Supp. 522, 1981 U.S. Dist. LEXIS 10211
CourtDistrict Court, D. Nebraska
DecidedJuly 30, 1981
DocketCV81-0-162, CV81-0-197
StatusPublished
Cited by3 cases

This text of 567 F. Supp. 522 (Schulte v. Douglas) is published on Counsel Stack Legal Research, covering District Court, D. Nebraska primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schulte v. Douglas, 567 F. Supp. 522, 1981 U.S. Dist. LEXIS 10211 (D. Neb. 1981).

Opinion

*523 MEMORANDUM AND ORDER

URBOM, Chief Judge.

On June 22,1981, this court preliminarily enjoined the enforcement of part of the Nebraska Criminal Code relating to abortions: §§ 28-329, 28-330, and 28-331, R.R. S.Neb. (Reissue 1979). Cross-motions for summary judgment are now on file. In support of their motions the parties rely upon the pleadings, affidavits and evidence presented before and affidavits presented after the filing of the motions.

The plaintiffs challenge the constitutionality of the three sections on the grounds that they are vague and overbroad, thereby depriving physicians, who are subject to felony criminal prosecutions for violation of the statutes, of due process of law. 1

In Colautti v. Franklin, 439 U.S. 379, 99 S.Ct. 675, 58 L.Ed.2d 596 (1979), the Supreme Court of the United States discussed the “void for vagueness” doctrine as it applies to restrictive abortion legislation. The court said:

“It is well settled that, as a matter of due process, a criminal statute that ‘fails to give a person of ordinary intelligence fair notice that his contemplated conduct is forbidden by statute,’ ... or is so indefinite that ‘it encourages arbitrary and erratic arrests and convictions,’ ... is void for vagueness.... This appears to be especially true where the uncertainty induced by the statute threatens to inhibit the exercise of constitutionally protected rights

439 U.S. at 390-391, 99 S.Ct. at 683

It is also well settled that at least where certain “fundamental rights” are involved, such as the right of privacy as it pertains to abortion, state legislation limiting such rights may be justified only by a “compelling state interest” and must be narrowly drawn to express only the legitimate state interests at stake. Roe v. Wade, 410 U.S. 113, 155, 93 S.Ct. 705, 728, 35 L.Ed.2d 147 (1973). Failure to confine such legislation renders the legislation unconstitutionally overbroad. Roe v. Wade, 410 U.S. at 164, 93 S.Ct. at 732.

With these standards of vagueness and overbreadth in mind I turn to an evaluation of the challenged portions of §§ 28-329, 28-330 and 28-331.

A. Viability determination

Both §§ 28-329 and 28-330 impose restrictions on abortions after the point of viability. Section 28-326(6) defines viability as:

“... that stage of human development when the unborn child is potentially able *524 to live outside the womb of the mother by natural or artificial means.”

The plaintiffs contend that this definition of viability is unconstitutionally vague and overbroad, in that it does not include the terms “meaningful” and “sustained” — additional qualifications the plaintiffs argue were imposed by the Supreme Court in Roe v. Wade, supra, and Colautti v. Franklin, supra.

It is true that in Roe v. Wade, supra, the Supreme Court spoke of viability not only as the point at which the fetus is “potentially able to live outside the mother’s womb, albeit with artificial aid,” 410 U.S. at 160, 93 S.Ct. at 730, but also as the point at which the fetus “has the capability of meaningful life outside the mother’s womb.” 410 U.S. at 163, 93 S.Ct. at 731 (emphasis added).

In Colautti v. Franklin, 439 U.S. at 387, 99 S.Ct. at 681, the court reiterated the “potentially able to live outside the mother’s womb” viability definition of Roe v. Wade, supra, and continued:

“... We added [in Roe ] that there must be a potentiality of ‘meaningful life,’ id., at 163 [93 S.Ct. at 731], not merely momentary survival. And we noted that viability ‘is usually placed at about seven months (28 weeks) but may occur earlier, even at 24 weeks.’ Id., at 160 [93 S.Ct. at 730]. We thus left the point flexible for anticipated advancements in medical skill.”
439 U.S. at 387, 99 S.Ct. at 681

The Colautti court concluded:

“... Viability is reached when, in the judgment of the attending physician on the particular facts of the case before him, there is a reasonable likelihood of the fetus’ sustained survival outside the womb, with or without artificial support____”
439 U.S. at 388, 99 S.Ct. at 682 (emphasis added)

The plaintiffs argue that these additional qualifications give “specific and comprehensible guidance and direction” to physicians in determining viability (see affidavit of plaintiff Dietrich, filing 26) and that without these terms the definition of viability as set forth in § 28-326(6) and incorporated into §§ 28-329 and 28-330 (the latter by reference to and incorporation of § 28-329), is unconstitutionally vague and overbroad.

I agree with the plaintiffs that the definition of viability as stated in § 28-326(6) is in conflict with the definition of that term in Roe v. Wade, supra, and Colautti v. Franklin, supra. While it is not necessary that the definition of viability include the very terms “meaningful” and “sustained” or either of them, 2 it is necessary that the definition be limited to include only that stage of fetal development in which the potentiality for life is more than mere momentary survival. This the Nebraska definition fails to do.

The narrow scope of the Nebraska definition of viability is evidenced by the affidavit of Dr. Hilgers (defendant’s Exhibit 14), in which Dr. Hilgers states that in his expert medical opinion, viability, as defined by § 28-326(6), is “clearly present” from and after the twentieth week of pregnancy. Such a limited definition of viability was not contemplated by Roe and its progeny. In Roe v. Wade, 410 U.S. at 160, 93 S.Ct. at 730, the court noted that viability as defined by the court “is usually placed at about seven months (28 weeks) but may occur earlier, even at 24 weeks.” Because the time when viability is achieved may vary with each pregnancy, the court refused to specify a point in the gestation period as the point of viability but, rather, left the determination of whether a particular fetus is “capable of meaningful life outside the mother’s womb” to the professional judgment of the attending physician. Planned Parenthood of Missouri v. Danforth, 428 *525 U.S. 52, 64-65, 96 S.Ct. 2831, 2838-39, 49 L.Ed.2d 788 (1976). If, as Dr. Hilgers opines, the Nebraska definition of viability precludes a physician from finding that a fetus is not viable at any point in time after the twentieth week of pregnancy, the definition is clearly overbroad and must therefore be stricken as unconstitutional.

B.

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Bluebook (online)
567 F. Supp. 522, 1981 U.S. Dist. LEXIS 10211, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schulte-v-douglas-ned-1981.