Madsen v. Women\u27s Health Center, Inc.: The Constitutionality of Abortion Clinic Buffer Zones

This note will discuss the new standard introduced by the United States Supreme Court, the Court\u27s rationale behind its introduction, and the standard\u27s 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\u27s reproductive rights. Finally, the author will explain why the states\u27 interest in protecting clinic access is strong enough to justify the continued use of buffer zones despite the stricter standard courts must apply