1983 City of Akron v. Akron Center for Reproductive Health (6-3). The Court strikes down a city ordinance that required that: all second trimester abortions be performed in a hospital; a woman seeking an abortion wait 24 hours after giving written consent and receiving mandated (and biased) information from the attending physician; women under age 15 obtain the "informed" written consent of one parent 24 hours in advance; fetal remains be disposed of in a "humane and sanitary" manner. In her dissent, Justice O'Connor (joined by Justices White and Rehnquist) rejects the trimester framework of Roe in favor of invalidating a statute only if it presents "absolute obstacles or severe limitations on the abortion decision" -- what she calls "an undue burden" on the woman seeking an abortion. The "undue burden" test would be a less stringent standard of judicial review of state abortion laws. For the first time, three Justices vote to overturn Roe in a case involving restrictions on adult women. On the same day, in Planned Parenthood v. Ashcroft (split on various parts), the Court bars a second trimester hospitalization requirement, but upholds other abortion restrictions. For the first time, the Court approves a parental consent statute with a judicial bypass mechanism. The Court also upholds requiring a pathology report for each abortion and the presence of a second physician during all post-viability abortions.