This comment will discuss how the ultrasound bill, like similar ones in other states, is unconstitutional for two reasons....Part II of this comment will focus on the Supreme Court's role in shaping abortion policy....Part III will describe Virginia’s new ultrasound requirement and how the above-mentioned Supreme Court decisions affect the new bill’s legality. Part III(A) will lay out the relevant portions of the bill and discuss its legislative history. Part III(B) will analyze the bill through Casey’s undue burden lens....Part III(C) will argue that requiring a woman to have a mandatory medical procedure effectively prevents her from refusing medical care, a right given to her by the Supreme Court. Part IV will state the conclusion that Virginia’s new ultrasound requirement should be found unconstitutional because it violates both a woman’s right to have an abortion without an “undue burden” and her right to refuse medical care.
Alison B. Linas, Comment, Virginia's "War on Women": How Forcing Women to Have an Ultrasound Before Abortion is Unconstitutional, 16 Rich. J. L. & Pub. Int. 47 (2012).