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Planned Parenthood of the Heartland v. Reynolds

Description:  Iowa state legislators are challenging a 2018 Iowa Supreme Court decision that declared abortion “a fundamental right” and struck down the required 24-hour waiting period that ensured women have the opportunity to receive and evaluate important health information before proceeding with an abortion.


Iowa Supreme Court
Friday, Jul 1, 2022

DES MOINES, Iowa – Following the recent landmark rulings from the Iowa Supreme Court and the U.S. Supreme Court finding no constitutional right to an abortion, Alliance Defending Freedom attorneys representing Gov. Kim Reynolds filed a petition Friday asking the Iowa Supreme Court to rehear its case to declare that courts must give a greater level of deference to pro-life laws like Iowa’s 24-hour waiting period, which helps ensure a woman is fully informed and certain about abortion before having one. That deference, known as “rational-basis review,” means that a law is presumed constitutional unless a party can prove that the government has no rational interest whatsoever in enacting the law.

The state high court’s recent decision in Planned Parenthood of the Heartland v. Reynolds correctly reversed a previous decision by the court that had found a right to abortion in the state constitution. But the court stopped short of declaring what the standard of review should be for pro-life laws going forward. The U.S. Supreme Court’s ruling in Dobbs v. Jackson Women’s Health Organization, which empowered states to regulate abortion in a manner that best preserves the lives of unborn children and their mothers, makes clear that standard should be rational-basis review—not Planned Parenthood v. Casey’s malleable “undue burden” test.

“While we celebrate the Supreme Court’s recent ruling that there are important interests in protecting life, we know our work must continue to enact and preserve laws that protect unborn children and mothers,” said ADF Senior Counsel Denise Harle, director of the ADF Center for Life. “The Iowa Supreme Court took a critical step in recognizing that no right to abortion exists in the state constitution. Now that we have guidance from the U.S. Supreme Court, we are urging the state high court to take the next logical step.”

“In adopting the rational-basis standard, the [U.S.] Supreme Court disavowed Casey’s ‘arbitrary’ and ‘unworkable’ undue-burden test,” the petition for rehearing explains. “Continued adherence to that standard would under­mine, not advance, the evenhanded, predictable, and consis­tent development of legal principles. So the Court rightly discarded it.” And with “the benefit of the Supreme Court’s reasoning, this Court now should do the same,” the petition continued.

  • Pronunciation guide: Harle (HAR'-lee)

Alliance Defending Freedom is an alliance-building, non-profit legal organization committed to protecting religious freedom, free speech, parental rights, and the sanctity of life.

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ABOUT Denise Harle

Denise Harle serves as senior counsel with Alliance Defending Freedom, where she is the director of the Center for Life. Prior to joining ADF, Harle served as deputy solicitor general in the Office of the Florida Attorney General, where she drafted appellate briefs and presented oral arguments on behalf of the state in a wide variety of constitutional cases, including defending the constitutionality of pro-life laws. In 2017, she participated in the prestigious Supreme Court Fellow program, sponsored by the National Association of Attorneys General. She clerked for Justice Ricky L. Polston on the Florida Supreme Court and worked for several years as an appellate litigator at a large firm in California. Harle earned bachelor’s degrees, summa cum laude, in psychology and interdisciplinary social science from Florida State University, a master’s degree in political science from Stanford University, and a Juris Doctor from Duke University School of Law. At Duke, she served as the executive editor of Law & Contemporary Problems. A member of the state bars of California, Florida, and Georgia, she is admitted to multiple federal district and appellate courts, as well as the U.S. Supreme Court.