tate interest" in order to be regulated, the new holding was that state regulation of abortion was permissible so long as such regulation did not place an "undue burden" on a woman's exercise of her constitutional rights with regard to abortion.(39) H.R. 1218 does not raise any questions concerning the permissible regulation of abortion that are independent of the state laws that it is designed to effectuate. To the extent that a state rule is inconsistent with the Court's doctrine, that rule is ineffective and H.R. 1218 would not make it effective. Therefore, it is unnecessary to ask whether, for example, the "life exception" in Subsection (b) of H.R. 1218 is an adequate exception to a rule regulating abortion or whether the inability to circumvent a state law is an "undue burden." Because constitutional limits on the States' regulatory authority are in effect incorporated into Subsection (a) of the Act, Subsection (b) is in addition to any exceptions required by the Court's doctrine. C. Constitutionality of Parental Involvement LawsFollowing the Court's decision in Roe v. Wade,(40) many states enacted parental consent or notification statutes requiring minors to notify or seek the consent of their parents before undergoing an abortion. Parental consent laws generally require one or both parents to give actual consent to the minor's decision to have an abortion. Parental notification laws typically require the physician, or in some statutes another health care provider, to notify one or both of the parents of the minor female at some time prior to the abortion. The Court first considered parental involvement in a minor daughter's abortion in Planned Parenthood of Central Missouri v. Danforth.(41) The Missouri statute gave a minor girl's parent an absolute veto over her decision to have an abortion. The majority, led by Justice Blackmun, found that the veto power was unconstitutional.(42) The majority, however, also noted in this case t...
