1992 Planned Parenthood v. Casey (split on various parts). The Court upholds most of Pennsylvania's strict Abortion Control Act, including forcing doctors to provide state-scripted information 24 hours before a non-emergency abortion. The Court also upholds the state's narrow definition of medical emergency, but finds that requiring a woman to notify her husband does pose an undue burden to her, because it allows a husband to prevent his wife from obtaining an abortion. Justices O'Connor, Kennedy, and Souter vote to replace the strict scrutiny standard of Roe (where the Court said pre-viability restrictions on abortion must be scrutinized to be sure they do not violate a woman's right to abortion) with the "undue burden" test Justice O'Connor espoused in City of Akron (see previous).