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“Undue Burden.” This is the single phrase that has shaped the landscape of abortion jurisprudence for the past twenty-five years. With these two, unclear words, the Supreme Court heightened support for the state’s ability to regulate a woman’s access to abortion. However, as courts have worked to decipher what constitutes an undue burden, legislatures have worked around the phrase’s vagueness to continually chip away at a woman’s right to an abortion. Without clarification on the meaning of undue burden, the phrase has served as a mechanism for increasing the number and type of regulations that restrict abortion access. In 2014, approximately 926,200 abortions were performed, and 788 abortion clinics operated in the United States. While abortions remain a

Making Sense of Whole Woman's Health v. Hellerstedt: The Development of a New Approach to the Undue Burden Standard