an abortion every year and who need the assistance of adults to do that."(11) Only Congress, with its constitutional authority to regulate interstate commerce, can curb this flagrant disregard of state laws.A. PennsylvaniaSince Pennsylvania's current parental consent law took effect in March of 1994, news reports have repeatedly maintained that many Pennsylvania teenagers are going out of state to New Jersey and New York to obtain abortions. In fact, in 1995 the New York Times reported that "Planned Parenthood in Philadelphia has a list of clinics, from New York to Baltimore, to which they will refer teen-agers, according to the organization's executive director, Joan Coombs."(12) Moreover, the Times gave accounts of clinics that had seen an increase in patients from Pennsylvania.(13) One clinic, in Cherry Hill, New Jersey, reported seeing a threefold increase in Pennsylvania teenagers coming for abortions.(14) Likewise, a clinic in Queens, New York reported that it was not unusual to see Pennsylvania teenagers as patients in 1995, though earlier it had been rare.(15) In the period just prior to the Pennsylvania law taking effect, efforts were underway to make it easier for teenagers to go out of state for abortions. For instance, Newsday reported that "[c]ounselors and activists are meeting to plot strategy and printing maps with directions to clinics in New York, New Jersey, Delaware and Washington, D.C., where teenagers can still get abortions without parental consent. . . . 'We will definitely be encouraging teenagers to go out of state,' said Shawn Towey, director of the Greater Philadelphia Woman's Medical Fund, a nonprofit organization that gives money to women who can't afford to pay for their abortions."(16) Moreover, some abortion clinics in nearby states, such as New Jersey and Maryland, use the lack of parental involvement requirements in their own states as a "selling point" in advertising directed at minors in Pennsylvani...
