Efforts to deter women from deciding to terminate their pregnancies take their toll on both women and health care providers. Unable to overturn Roe v Wade and ban abortion outright, opponents have sought to prevent women from obtaining abortions by imposing restrictions and burdening service providers. Among the most common measures adopted at the state level are mandatory delay, state-scripted information, and parental notification requirements, while both federal and state policy makers have restricted Medicaid coverage for abortion. In its 1992 decision in Planned Parenthood v Casey, the US Supreme Court made clear that states may not criminalize abortion prior to viability or allow anyone to veto a woman's decision to terminate her pregnancy. Nonetheless, the Court adopted a less protective "undue burden" standard for reviewing the constitutionality of restrictions on a woman's right to choose. In the wake of Casey, courts and legislative bodies continue to grapple with the extent to which the abortion choice is protected under federal and state constitutions. Meanwhile, women and health care providers are forced to endure the hardships caused by restrictive laws and policies.