Ayotte v. Planned Parenthood of Northern New England
In Ayotte v. Planned Parenthood of Northern New England (2006), the U.S. Supreme Court reversed a lower court ruling against an abortion parental notification law, The Parental Notification Prior to Abortion Act, N.H. Rev. Stat. Ann. §§ 132:24-132:28. The Court ruled that lower courts should not broadly invalidate such a law, and the Court remanded for further review by the lower courts.
The Court emphasized that "we try not to nullify more of a legislature's work than is necessary, for we know that '[a] ruling of unconstitutionality frustrates the intent of the elected representatives of the people.'" 546 U.S. 320, 326(2006) (quoting Regan v. Time, Inc., 468 U.S. 641, 652 (1984) (plurality opinion) (brackets in original)).
Justice Sandra Day O'Connor delivered the opinion of the unanimous court.
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