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 Planned Parenthood of Se. Pa. v. Casey, 505 U.S. 833, 112 S. Ct. 2791, 120 L. Ed. 2d 674 (1992), sets the standard that courts are bound to apply in facial challenges to abortion restrictions. In Casey, the Supreme Court set forth the test that must be applied in analyzing whether a restriction placed on a woman's constitutional right to an abortion is an 'undue burden' on that right, thereby rendering the restriction facially unconstitutional. Id. at 878, 894-95. The Supreme Court determined that, because '[l]egislation is measured for consistency with the Constitution by its impact on those whose conduct it affects,' when analyzing abortion restrictions, '[t]he proper focus of constitutional inquiry is the group for whom the law is a restriction, not the group for whom the law is irrelevant.' Id. at 894. Therefore, if, 'in a large fraction of the cases in which [the abortion restriction] is relevant, it will operate as a substantial obstacle to a woman's choice to undergo an abortion,' then reviewing courts should find that the restriction is an 'undue burden, and therefore invalid.' Id. at 895. This test has come to be known as the Casey ...

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