9 N.W.3d 37
Iowa2024Background
- Plaintiffs (Planned Parenthood of the Heartland, Emma Goldman Clinic, Dr. Traxler) sued Governor Reynolds and the Iowa Board of Medicine seeking declaratory relief and a temporary injunction against a 2023 Iowa statute banning most abortions after detection of a fetal heartbeat (Iowa Code ch. 146E).
- The statute requires abdominal ultrasound and written notice, and includes narrow exceptions (medical emergency, rape if reported within 45 days, incest if reported within 140 days, fetal anomalies before 20 weeks, limited post-20-week exceptions).
- The district court granted a temporary injunction (issued July 17, 2023) applying the Casey undue-burden test and finding plaintiffs likely to succeed on their due process claim; the State sought interlocutory review.
- This appeal focused principally on the proper constitutional standard of review for due-process challenges to abortion restrictions under the Iowa Constitution.
- The Iowa Supreme Court majority held abortion is not a fundamental right under the Iowa Constitution and applied rational-basis review, reversed the temporary injunction, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper level of constitutional scrutiny for an abortion restriction under Iowa Constitution | Apply Casey’s undue-burden test (or an intermediate balancing approach) to protect women’s liberty interests | Apply rational-basis review because abortion is not a fundamental right under Iowa Constitution | Court: Abortion is not a fundamental right under Iowa Constitution; apply rational-basis review |
| Likelihood of success for temporary injunction (substantive due process) | Under undue burden, statute likely unconstitutional; injunctive relief appropriate | Under rational basis, plaintiffs unlikely to succeed so injunction improper | Court: Under rational basis, statute is rationally related to legitimate state interests; injunction should be dissolved |
| Standing (provider and third-party standing) | Providers can assert their own injuries and third-party standing for patients | Challenge to provider and third-party standing | Court: Planned Parenthood has Article III-equivalent standing and satisfies prudential third-party standing exceptions |
| Ripeness of challenge (filed before gubernatorial signing) | Case is ripe because enactment and imminent enforcement were certain and plaintiffs would suffer hardship | Filed pre-signature; not yet ripe | Court: Suit was ripe given the imminence of enactment, harm, and need for immediate adjudication |
Key Cases Cited
- Planned Parenthood of the Heartland v. Reynolds, 915 N.W.2d 206 (Iowa 2018) (held abortion a fundamental right under Iowa Constitution; applied strict scrutiny)
- Planned Parenthood of the Heartland v. Reynolds, 975 N.W.2d 710 (Iowa 2022) (overruled 2018 on strict-scrutiny point; declined majority rule on replacement standard)
- Dobbs v. Jackson Women’s Health Org., 597 U.S. 215 (2022) (U.S. Supreme Court: abortion is not a federal fundamental right; federal due-process challenges reviewed under rational basis)
- Planned Parenthood of the Heartland v. Iowa Bd. of Med., 865 N.W.2d 252 (Iowa 2015) (applied undue-burden standard to strike down telemedicine restriction)
- Racing Ass’n of Cent. Iowa v. Fitzgerald, 675 N.W.2d 1 (Iowa 2004) (describing burden on challenger under rational-basis review)