Massachusetts enacted a law specifying consent requirements for unmarried minors seeking abortions. William Baird, on behalf of an abortion counseling organization, Parents Aid Society, filed a class action under the Fourteenth Amendment challenging the statute against state Attorney General Frances Bellotti and all district attorneys within the state. Baird argued that the statute created a parental veto. Parental vetoes were ruled unconstitutional in Planned Parenthood of Central Missouri v. Danforth. The federal District Court struck down the law. Bellotti appealed to the Supreme Court of the United States, contending that the District Court should have abstained until a decision on the statute by the Massachusetts Supreme Judicial Court.
Should the federal District Court have abstained from rendering a judgment until a decision from the Supreme Judicial Court of Massachusetts?
Yes. In a unanimous opinion authored by Justice Harry A. Blackmun, the Court held that the District Court should have abstained and vacated the judgment. There was ambiguity in whether the Massachusetts statute created a "parental veto," which under Planned Parenthood v. Danforth affected the constitutionality of the statute. Since the Supreme Judicial Court's ruling would have resolved the ambiguity, the District Court should have abstained.
Decisions
Decision: 9 votes for Bellotti, 0 vote(s) against Legal provision: Abstention Doctrine
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Full Opinion by Justice Harry A. Blackmun
