In 1992, the U.S. Supreme Court, led by Justices
O'Connor, Kennedy, and Souter, adopted a new standard for reviewing the constitutionality of
restrictions on abortion. Under the new standard, a reviewing court would consider whether an
abortion restriction has the effect of imposing an "undue burden" on a woman's right to obtain an
abortion. This report will examine Justice O'Connor's notable opinions on abortion, and explore her
role in the development of the undue burden standard.