Golden Gate University Law Review


This note will discuss the new standard introduced by the United States Supreme Court, the Court's rationale behind its introduction, and the standard's application to the facts of Madsen. Next, the author will explore how this standard will influence the decisions arid injunctions already implemented by state courts and how the standard may result in reduced protection for women's reproductive rights. Finally, the author will explain why the states' interest in protecting clinic access is strong enough to justify the continued use of buffer zones despite the stricter standard courts must apply.