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Planned Parenthood v. Neely.


 The U.S. District Court for the District of Arizona ruled that the Arizona statute requiring parental consent before an abortion may be performed on an unmarried or unemancipated minor was unconstitutional. The statute was found to be both unconstitutionally vague in its description of medical procedures, and unconstitutionally narrow in defining a medical emergency to allow for waivers of such consent in life-threatening situations. The ruling held that the statute's ambiguities would force physicians to choose not to perform medical procedures they perceived to be necessary in order to avoid criminal prosecution. The court pointed to the Pennsylvania abortion statute (involved in the recent Casey decision) as an example of the kind of statute that ought to be enacted. It particularly urged the legislature to re-examine the judicial bypass provisions, indicating that the time constraints for application and appeal placed an undue burden on the minor. Further, the court urged the legislature to recognize the importance of effective counsel to assist minors in these types of proceedings.
