This paper examines June Medical Services v. Russo and offers analysis of the road ahead. In June Medical Services v. Russo, Sup. Ct. No. 18-1323 the Supreme Court was presented with the opportunity to correct the Court’s wayward abortion jurisprudence and affirmatively reject Whole Woman’s Health v. Hellerstedt, (2016), which has significantly expanded the abortion industry’s angles of attack on legitimate State health and safety measures. While the Court failed to take advantage of the opportunity, the positions of a majority of the Court in June Medical provide a clear road map to the States for winning future abortion cases.
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