hat a state has greater authority to regulate abortion procedures for minor girls than for adult females.(43)In Bellotti v. Baird,(44) the Court remanded a parental consent statute that was unclear as to whether the parents had authority to veto the abortion and as to the availability of a judicial bypass procedure. The statute returned to the Supreme Court in Bellotti v. Baird (Bellotti II).(45) The statute in Bellotti II required a minor to obtain the consent of her parents or circumvent this requirement through a judicial bypass proceeding that did not take into account whether the minor was sufficiently mature to make an informed decision regarding the abortion. The Supreme Court invalidated the statute without a majority opinion.Justice Powell's plurality opinion held that a state could limit the ability of a minor girl to obtain an abortion by requiring notification or consent of a parent if, but only if, the state established a procedure where the minor girl could bypass the consent or notification requirement.(46) This has become the de facto constitutional standard for parental consent and notification laws. In upholding parental involvement laws, the plurality found three reasons why the constitutional rights of minors were not identical to the constitutional rights of adults: "The peculiar vulnerability of children; their inability to make decisions in an informed, mature manner; and the importance of the parental role in child rearing."(47) Thus, the plurality sought to design guidelines for a judicial bypass proceeding that allowed states to address these interests.In H.L. v. Matheson,(48) a minor girl challenged the constitutional validity of a state statute that required a physician to give notice to the parents of a minor girl whenever possible before performing an abortion on her. By a vote of six to three, the statute was found to be constitutional. The Court held that a state could require notification of the parents ...
