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Case Basics
Docket No. 
Frances Bellotti, Attorney General of Massachusetts et al.
William Baird et al.
Hunerwadel v. Baird, No. 75-109
(argued the cause for appellant Bellotti)
(argued the cause for appellant Hunerwadel)
(argued the cause for the appellee)
Facts of the Case 

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?

Decision: 9 votes for Bellotti, 0 vote(s) against
Legal provision: Abstention Doctrine

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.

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BELLOTTI v. BAIRD. The Oyez Project at IIT Chicago-Kent College of Law. 04 September 2015. <>.
BELLOTTI v. BAIRD, The Oyez Project at IIT Chicago-Kent College of Law, (last visited September 4, 2015).
"BELLOTTI v. BAIRD," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 4, 2015,