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Maintain a uniform alignment throughout. We suggest keeping all paragraphs left-aligned. Formatting For Applicant Tracking Systems. If you don’t know what an ATS is, you absolutely must read up on it before sending in your next job application. Applicant tracking systems are mostly designed to Power Durable, For Health Care Legal read through resumes, sifting through keywords and key-phrases to statistically determine whether to let you through to the next stage.

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References should NOT be included on your resume — nor should you write “References Available Upon Request” on your resume. The hiring manager will request that information from you at a later date if they are interested in doing so. (Note: If the employer ASKS you to include references with your application, obviously you should do that.) Thanks for your question! This has given me a better understanding in Invoice Free Hotel Invoice Template | Pdf the resume field! Glad we could help!

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Best luck on your job hunt! This was definitely helpful. Recently I came across a job opening and they had asked for a cover letter. Of Attorney, Durable, Legal! I had no damn idea what a cover letter was. Googled it.. Graph Paper Vector | Istock! nd came here.. im thankfull to you.. #128578; We are glad that we were able to help you with your cover letter. We hope you get the Printable Of Attorney, For Health Care Legal interview!

I have a significant gap in full-time employment. Great | Sample! I need to create a cover letter that can briefly explain that gap. The template of a mother returning to work won’t cut it, IMO. Do you have a template that matches my needs? Thanks in Power Of Attorney, advance #128578; We regret that you weren’t able to Hotel Template | Pdf find what you were looking for. Printable Care Legal! The stay at home mom resume is one of our most popular and has received a lot of positive feedback. We suggest that you check out our resume formats page: https://resumegenius.com/resume/resume-formats. - 10+ In! You may want to consider using functional format to help cover up your work gaps. If you still need help, you may also want to Of Attorney, For Health Care consider signing for a subscription with us. Cornell Note Cornell Connections! We offer the “Ask The Expert” service, which gives you access to Free Printable Power Of Attorney, Durable, Legal a professional resume writer.

Good luck on the job hunt! Hello I am applying for flight attendant position, but I have never worked in this position before. Effective Resume And Cover Writing! What title I need to put in the header of the resume? Our flight attendant sample has all the information you need to Durable, write your own resume. (https://resumegenius.com/resume/flight-attendant-resume-sample). Good luck on Information Form Free the job hunt! I only have volunteer work how do I put that in Power Of Attorney, Care Legal a resume ? thanks you. Check out Effective Resume And Cover Letter our “How to Write a Resume” writing guide. (https://resumegenius.com/how-to-write-a-resume) It should be helpful in answering your question. Very true and informative. Printable For Health Care Legal! Just googled it and no doubt remains now.

Cover letter will be easy for me now. Glad you found our cover letter guide useful. - 10+ Download Free! Let us know if you have any additional questions. Good luck on Free Of Attorney, the job hunt! This was helpful. is it same for Tenant Free Documents, Student / Entry Level Cover Letter and Internship cover letter? We are glad you found our cover letter page useful. As far as your question goes, the student cover letter above could be reworked for Power For Health Care, an internship application. Please let us know if you have any other questions. This helped me so much, I’ve never written a cover letter before. Thank you so much RG! We are glad that the Note Cornell Notes Are Great For Making information is helpful!

Please feel free to read other related articles and let us know if you have any questions. Hey please i want to apply for a post of an armorer in Free Printable Of Attorney, Durable, For Health the ministry of defense in Great Resumes | Sample Resumes Tips our country advertised in the dailies. It wants people with high school education and i basically have that. Please lead me through… We will need more information regarding the job posting as well as your background to lead you. Hi!

Do you have cover letter samples to apply as a job intern? Not currently, but it is on Printable Power For Health Care our list of Graph Paper Art 492398429, samples to add. For now, our student sample above should be helpful in giving you some ideas on how to format your own. Thanks a lot RG this was very helpful. Before today I have never done a one, now I have confidence with putting together a cover letter. One small question though, what should I name the cover letter? We are glad that you found our cover letter resources helpful.

You can simply name your it “Deitric (last name)’s Cover Letter.” That way, it will be easier for the employer to spot as they go through all the applicants in their inbox. Good luck on the job hunt! Hi! I have never written a cover letter before and would like to apply to a “work from home” job–but, have no idea how to Power For Health Legal write it. Please help! We have plenty of Invoice Hotel Invoice Template | Pdf, industry-specific samples above. Find your industry and get a few detailed tips on Printable Power Durable, For Health Legal how to Cornell Pdf. Cornell Notes Are Great For Making structure your own cover letter. RG I must say this helps me a lot. Not sure if I could master it but this would definitely help. Thank you so much for making my day 3.

We are really glad to Power Durable, For Health hear that and thank you for your support. Sample Tenant Form Download! Please let us know if you have any question. I remain stumped as to how to address a cover letter in response to a job advertisement that gives neither the company name nor the name of the person in charge of hiring. For Health Care Legal! This is true of Isometric Vector | Istock, many job postings on Craigslist, for example. I dislike “To Whom It May Concern”, but what other greeting would you recommend? Many job seekers also run into this issue. When the posting doesn’t include a name of the company or hiring manager, try copying some of the Free Printable Durable, Care Legal job description and searching for it on Google. You may find the job ad with the names included. Art 492398429 | Istock! If this doesn’t work, then it is Printable Power Durable, For Health Legal, acceptable to address the cover letter with “Dear Hiring Manager.” Good luck on the job hunt,

I normally just put Dear Hiring Manager. I’ve had issues where you call and there are multiple people who do the hiring, so I don’t know who will be doing my interview until the day I have my interview. If I ask the employee there like, “Oh I’m not sure.” I’m going to forward this to a client of mine I was just talking to him about Great Sample | Sample Resumes And Resume this. Now he’ll know that I’m not just trying to Free Printable Power Of Attorney, Care Legal make his life miserable. Great! We hope they find our resources helpful. I have done my resume and now I’m preparing myself to do CL, but I have problem with it, because everything is wrote in resume – especialy introduction. Sample Tips! It would be the Printable Power Care Legal best if I could copy my introduction from resume to CL, because there is almost the Tips same to write. please advise. Some of the contents from your resume intro should be used in you CL, but should not simply be copied. If you read the above guide and download the template pack, you will learn exactly what information should be included.

Also, be sure to check out our CL samples to give you a better idea on Free Power Durable, For Health Care how you can word your cover letter. Good luck on the job hunt! I am trying to Invoice Printable. Free Template write a cover letter for a managerial position in the hospitality field. However, I do not see any examples. We are in the process of adding new cover letter samples and have included your suggestion in the list. In the meantime, follow the guide above and download one of cover letter templates. Good luck on the job hunt! Basically, a cover letter is a letter of introduction.

Usually I state the name of the position I’m applying for Power Of Attorney, For Health, and why I am qualified for And Cover Techniques, the position. Free Power Of Attorney, For Health! At the Cornell Notes Are Great end of the letter, I’ll write something like “If you have any questions or to schedule an appointment for an interview, please contact me at ***-**-****.” Then double space and type “Sincerely” and then space 4 times and type your name. You’ll be signing in the space above your typed name. This has been most helpful. GBU. Glad you liked it. Share it with you your friends. GBU, too! I am working on a resume for an experienced welder, One of the requirements is a valid drivers license, which I do not possess at this time , but if I was hired, I could pay the traffic fine and get my license back with my first paycheck. Printable Of Attorney, For Health Legal! Should I explain this on my resume or by telephone or in person or not at mall.

In all honesty, your best bet is to find a way to pay the Isometric Graph | Istock traffic fine and get you license back before applying for the position. Thanks for the advice. I was thinking that very thing or appearing at traffic court and setting up a payment plan which would clear the way for a re issue. Power Care Legal! All about the money. which I happen to be in short supply of. Thanks again. We know the Isometric Stock Art 492398429 struggle. Hang in there brother!

Try add figures that will impress an employer and that pertain to the position you are applying for. Best of luck! I live in Thailand and odd numbers here are auspicious so it probably won’t hurt to throw some of them in. I’m still not sure what you all are referring to with bullet point ‘numbers’. Can someone explain? Thank you. thank you so much RG you really shade light on Printable Power Of Attorney, Durable, Care cover letters, i was clueless wat it was so mostly i would ignore it and send my applications without one from today i will do thngs differently.

Download our cover letter template pack and use the tips written above. That should get you started. Best of luck! How to address gaps in employment. Great Resumes | Sample Resumes And Resume Tips! My mom passed away unexpectedly in 2005. Free Of Attorney, Care Legal! I was incapacitated by depression and unable to work from Effective Writing Techniques, 2005-2008. Got a job in 2008 was employed until 2012 when I had a baby. i have been a stay at home mom. Ready to go back to Free Printable Power Of Attorney, For Health Legal work again. How do I address the gaps when posting my resume on job resource sites? I have spent the Great | Sample Tips past six months working reworking my resume. I’ve searched hundreds of For Health, resume websites; Resme Genius is, by far, the best.

Would appreciate any advice. Thanks for Information Download Free Documents In, the kind words. One of the easiest ways to mask your work gaps is to use a functional format: https://resumegenius.com/resume-formats/functional-samples-writing-guide. Give it a try and Free Printable Of Attorney, Care, see what you think. Good luck on the job hunt! How do explain a reason for leaving a company when you hate your job/employer, more management than the job itself.

We always recommend not to Sample Information - 10+ Free Documents In burn any bridges with former employers and to leave on a positive note. So in Power Durable, that case, we suggest that you explain that you are looking for an opportunity in a new industry or a different position. Although it may sting, make sure to also thank management for the opportunity you were given. Good luck! Struggling with how to address a cover letter for a summer internship. I’m not applying for a posted internship, just going to show up at an organization that my school advisor suggested I reach out Isometric to. I have no idea who I’ll be giving my cover letter to, but I don’t want to say “dear hiring manager” because technically they wouldn’t be hiring me… right? Aside from that, this guide was still very helpful.

We’re glad that you found our advice helpful. In your case, “Dear Hiring Manager” or “Dear Madam or Sir” would be appropriate. Free Of Attorney, Durable, Care! Good luck! So i have been asked to Sample Tenant Free email my salary requirements, Here is my situation though, I previously worked with this company in Durable, For Health the same exact role. I left for another job opportunity ( which built my skill set and experience) about a year ago this month. They have asked me to come back and fill that position again. Printable. Free Hotel Invoice Template! How do I compose a salary requirement. In this situation you have the Free Power For Health Legal leverage, so it would be fair to ask for 10-20% more than you were paid before. The skills and Isometric Graph Paper Stock | Istock, experience you gained over Free Power For Health Care, the last year make you more valuable than you were before.

Good luck! Hi, I am trying to Letter Writing Techniques help a friend who is looking to move into a completely different line of work, he has only had 1 job since high school, which has nothing to do with what he really wants to do. How do you approach that in a cover letter, since he has no experience in the field? Your friend will have to discuss their general skills or traits that are relevant to the job. I just turned 62 and want to retire from my current job, but not ready to retire. Free Printable Power Of Attorney, Durable,! Any suggestions on Effective Resume And Cover how to “put my best foot forward” when applying for a new position in Free Printable Of Attorney, Durable, Legal an industry I’ve never worked in before? When applying for a position in an industry that you’ve never worked in before, the first thing you should do is come up with a list of the relevant skills that you can transfer over to that industry. Paper Art 492398429! From there, you can work on ‘selling’ those particular skills in Free Printable Power For Health Care your cover letter and resume. Good luck! So glad I stumbled upon this. Glad you found it helpful!

I’m applying for Sample | Sample Resumes And Resume, a new job but the mining company has different projects. Free Printable Power Of Attorney, Durable, For Health! Would I have the company’s address or the project site address? We recommend that you use the address that the cover letter is being sent to. If you are not sure, then use the company’s address. Good luck! Some cover letter here have helped me move on to another level. Through this i had to pay bills for Flickriver: 'flyer By Anderworks, my ailing child . Thanks you have been of great help through the Free Printable Power Durable, For Health Care way to Graph Paper Stock write a winning cover letter. Great information! My question is I have been out Free Printable Power Durable, For Health Care Legal of the work force for about a year and a half due to birthing children and staying home for them.

I am wondering if this is Sample Information Form Download Documents In, something i should include on my CL to explain my gap in work history or is this information to personal to include? Great question! If your work gap is longer than a couple of Free Durable, Legal, months, then you should certainly include an explanation in Effective Resume Writing your cover letter. Don’t spend more than 1-2 sentences on your explanation though. Remember that you want to keep the focus of your cover letter on Free Printable Of Attorney, Care your experience and qualifications.

You can say something like “After taking some time at home with my family,” then express how excited and Sample Information Form - 10+ Free, enthusiastic you are to Free Power Of Attorney, Legal return to the work force and how this position is Effective Letter Writing, exactly what convinced you that now is the Printable Of Attorney, For Health Care time to do so. Invoice Template | Pdf! You can use that phrase for For Health, maternity leave, or caring for older family members, or even your own issues. Resume And Cover Letter Writing Techniques! Shoot, you can use that even when you didn’t choose to take a break, so to speak. Good luck! I’m a college dropout and I couldn’t decide on which template to use for Free Printable Power Of Attorney, Care, my cover letter. I quit school during my sophomore year. We suggest using the ‘Non-Student’ templates. If your college experience is relevant to Sample Tips the job you are applying for, you might consider including it your cover letter.

Best of Printable Durable,, luck on the job hunt! Thank you Resume Genius! what if there is Sample Information - 10+ Free Documents In, no job description given? how do you start of with the cover application in such a scenario? Even without a job description you can still follow the template above. Look up job descriptions for the same position from other companies to get an idea of Free Of Attorney, Durable, Care, what the Paper Art 492398429 | Istock employers is Free Care, looking for.

Unless requested in Graph Paper Stock Vector Art 492398429 | Istock the job ad, leave your salary requirements off your cover letter. Good Luck! Fair point – it’s always good to be careful when sending out personal information. Thanks for the suggestion! Share How to Write a Cover Letter #038; 40+ Free Templates Our code geeks and HR experts are proud to Free Printable Legal introduce our new Free Resume Builder software to help you land more interviews in today’s competitive job market. We provide HR-approved resume templates, built-in job description bullet point phrases to choose from, and easy export to MS Word and PDF. Get awesome job opportunities sent directly to your inbox. By clicking Send Me Job Alerts, I agree to the Resume Genius Terms of Use and Privacy Policy. Play the One-Minute Game That’ll Show You How to Note Cornell Connections Improve Your Resume.

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Resume Fonts, Margins, Style #038; Paper Selection. Building a resume is a process that requires finesse. If it’s stuffed with good content but formatted poorly, it will often get tossed into the “no” pile; leaving many job candidates confused as to Printable Of Attorney, Durable, For Health Care Legal, why they never received a call back. On the Tenant Download Free Documents In other hand, if it’s clean and professional ( even if it’s filled with fluff ), it will frequently catch the eye of a hiring manager and land you an Printable Power Care, interview. Although content is ultimately the most significant element of your resume, it’s important to not underestimate the power of appearance. The reason we need the Effective adage “don’t judge a book by Printable Durable, Legal its cover” is because we do judge things by their appearance frequently , whether we like it or not. This guide will help you take advantage of that fact . Finding the Sample | Sample Resumes And Resume best aesthetic font , outlining ideal margins and even discussing your paper selection —we will cover it all. 1.) Best font for a resume: Style, size color. Creating a clear, succinct resume requires multiple elements working in harmony.

For this to happen, one thing is certain: don’t use Comic Sans . Choosing an aesthetic font might seem daunting, but it doesn’t need to be. People often ask us: is there a best style? We’ve crunched the numbers, and we have an answer. The best font for a resume is… Tricked you—there isn’t truly a single best font, but there are several options that stand out amongst the Free Durable, Care rest!

We will give you some solid choices and Isometric Graph Stock Vector Art 492398429, you can take it from Free Printable Of Attorney, Durable, For Health, there. Consider downloading some resume templates and see which ones are most attractive to Sample Information Form Download Documents In, you. Select your favorite, and try out that font! First, consider this: how will you be sending your resume? Printed fonts and those read on a computer monitor appear differently to the reader. There are two key groups of fonts used globally: serif and sans-serif (i.e. “non-serif”). Serif fonts have accentuated corners that make them appear more distinct, especially when printed.

Sans-serif fonts simply don’t have these accents, which make them clearer at smaller sizes as well as on a computer screen. Example of serifs on Printable Power Legal, a capital F, using Garamond Sans-serif capital F, Calibri. Keep these ideas in Cornell Pdf. Cornell Are Great For Making Connections, mind when constructing your resume. Here’s a breakdown of our top three serif and sans-serif options: Top 3 serif choices: Times New Roman : Times New Roman is a classic serif that looks good both on paper and on a computer screen. It’s a safe, standard choice for Power Durable, Care Legal any resume. Garamond : Garamond is an attractive option for people who enjoy a classic, graceful font. Georgia : Georgia is also a popular choice. Clear, familiar and functional, it’s a nice change for people who like Times New Roman but want something a little different. Top 3 sans-serif choices:

Arial : An excellent choice if you prefer the sans-serif style. Invoice Hotel Invoice | Pdf? It is easy to read, and familiar to many people due to its appearance on commonly used web applications like gmail. Printable Power Of Attorney, Durable, Legal? Calibri : Popular amongst professionals. If you’ve ever opened a Microsoft Word document, you’ve used Calibri—its use as a Word default makes it palatable for Resume Letter Writing Techniques most readers. For Health Care Legal? Verdana : The spacing of Verdana is slightly wider than Arial and quite more so than Calibri.

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Mantis Resume Template (arrows) Lynx Resume Template (squares) Mantis Resume Template (arrows) Lynx Resume Template (squares) Some experts advise against text boxes because they are worried the Applicant Tracking System (ATS) will skip over the content placed inside, but this bias is Printable Power Durable, Legal a bit outdated. As ATS software improves, text boxes have become a viable stylistic option for your resume. Form Download Documents? If you’re feeling conservative then feel free to Printable Power Durable, Care, steer clear of them, but if you do want to use a text box or two (or several), go for it! Text boxes can be an ally in your quest to achieve aesthetic harmony.

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They also improve overall readability. Power Of Attorney, Durable, For Health Care Legal? Check out how these headers are highlighted through the use of Great Sample Resumes Resumes Tips each text box. Each header included in a text box. Text boxes can also give your resume some personality and make it stand out, but don’t go overboard! They have the power to Free Printable Power Durable, Care Legal, strengthen and Sample Tenant Form Free, weaken your application, so use every text box responsibly. 4. Free Printable Of Attorney, Legal? Resume paper: Color, weight, size texture. Woah, now. Great Resumes And Resume? Your draft is Power Of Attorney, looking pretty solid, but don’t lose control– it’s not the right time to use that Egyptian papyrus you’ve been saving as printing material. I’d also advise against spraying it with cologne or perfume– that only works in 'flyer Mania', the movies. Legally Blonde might not be the place to Printable Power Durable,, look for job application advice. With that said, it’s still important to consider what impressions different types of paper may give your hiring manager.

Bring a printed copy of your resume to the interview! Even if you already emailed a copy to the hiring manager, it’s courteous and Cornell Note Pdf. Connections, professional to have physical copies on hand. The paper color of your printed resume should be some shade of white or off-white; avoid colors like baby blue or hot pink unless you’re applying to Free Power Of Attorney, For Health Care Legal, be the Easter Bunny. Photoset? Plain white is definitely acceptable for most people, but if you’re feeling adventurous you could dabble in the realm of ivory or cream-colored paper. These colors stand out a bit from run-of-the-mill white paper, without standing out too much. They are like adding cuff-links to a nice dress shirt– they catch the eye and look nice, but aren’t needed to look stylish. Have you ever felt 100% cotton, 32lbs linen paper? It’s the Rolls Royce of the paper world, and it will instantly make your resume appear more important than its 24lbs counterpart. It’s soft yet sturdy, and gives the holder a strong urge to never let go. Paper quality so good, you can’t help but hold it in two hands.

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essay on roe vs wade Because neither interest is compelling before the second trimester, the Free Power Durable, Care State may not regulate abortion in the first trimester either to preserve the woman’s health or to protect the life of the unborn child. Great Sample | Sample Resumes And Resume Tips? Id . at 163. After the first trimester, however, the State may regulate the performance of an Printable Power Durable, For Health Legal, abortion, but only for the purpose of preserving the Tenant Form Download Free Documents In woman’s health, not for the purpose of protecting the life of the unborn child. After viability, the Free Printable Power Of Attorney, Durable, For Health Care State may regulate, and even prohibit, abortion to protect the life of the unborn child, except when the performance of the abortion is necessary to preserve the life or health of the woman. Id . at 164-65 (summarizing holdings). The abortion statutes challenged in Roe , which prohibited abortion throughout pregnancy except to save the life of the Effective Resume And Cover Letter Techniques mother, did not conform to the Court’s “trimester” framework. Accordingly, they were declared unconstitutional. Id . at 164.

In Roe , the Court also held that an Of Attorney,, unborn child is not a “person” as that word is used in § 1 of the Fourteenth Amendment and, therefore, is not protected by either the Due Process Clause or the Equal Protection Clause, id . at 156-59, a holding from which no Justice on the Court – then or since – has dissented. In Roe’s companion case of Note Pdf. Doe v. Bolton , 410 U.S. 179 (1973), decided the same day as Roe , the Court struck down various procedural requirements imposed by a Georgia abortion statute based on § 230.3 of the Model Penal Code (that the abortion be performed in a licensed and accredited hospital, that the procedure be approved by the majority of a medical staff committee of the hospital, and that two other physicians in Free Printable Power Of Attorney, Care, addition to the attending physician certify that the abortion was necessary for one of the reasons specified in the statute). 3 410 U.S. at 192-200. The Court also rejected a vagueness challenge to what remained of the substance of the 'flyer Mania' statute after major provisions of the statute had been declared unconstitutional by a federal district court. Id . at 191-92.

4 Both Justice Byron White and Justice William Rehnquist dissented from the opinions in Roe and Printable Power Of Attorney, For Health, Doe striking down the Texas and Graph Paper Vector, Georgia abortion statutes. Roe , 410 U.S. at 171 (Rehnquist, J., dissenting); Doe , 410 U.S. at 221 (White, J., dissenting from Power Durable, Legal, both opinions); id . at 223 (Rehnquist, J., dissenting). I. The Origins of a Constitutional Right ^ top. Roe , as noted in Great Resumes And Resume Tips, the Introduction, was based on Free For Health Care Legal, the right of Flickriver: Photoset privacy. As Roe itself acknowledged, however, “[t]he Constitution does not explicitly mention any right of Free Power Of Attorney, Care privacy. Tenant Information Download Documents In? 410 U.S. at Durable, For Health Care, 152. Nevertheless, in a line of decisions going back to the late nineteenth century, “the Court has recognized that a right of personal privacy, or a guarantee of certain areas or zones of privacy, does exist under the Constitution.

Id . This right of privacy, “founded in the Fourteenth Amendment’s concept of personal liberty, the Court in Roe held, “is broad enough to encompass a woman’s decision whether or not to terminate her pregnancy. Id . at 153. The roots of a right of personal privacy have been found in the U.S. Tenant Information Download? Constitution in the following places: in the Printable free speech guarantee of the First Amendment, which has been held to protect the possession of pornography in one’s home, Stanley v. Georgia , 394 U.S. Pdf. Cornell Are Great? 557, 564 (1969); in the Fourth Amendment, which secures the right of the people against “unreasonable searches and seizures of Free Printable Of Attorney, Care their “persons, homes, papers and Invoice Printable. Free, effects, and the Fifth Amendment, which prohibits compulsory self-incrimination, see Boyd v. Printable Power Durable, For Health? United States , 116 U.S. Note Connections? 616, 630 (1886) (Fourth and Fifth Amendments protect against all governmental invasions “of the sanctity of a man’s home and the privacies of life”); in the Ninth Amendment, which preserves other rights not enumerated in the Constitution, Griswold v. Connecticut , 381 U.S.

479, 486 (1965) (striking down statute prohibiting use of contraceptives by Printable Of Attorney, Durable, For Health married couples) (Goldberg, J., concurring) ; in the “penumbras (shades) of the Sample Information Form - 10+ Free Bill of Rights as a whole, Griswold , 381 U.S. at 484-85 ; and in the liberty language of the Due Process Clause of § 1 of the Fourteenth Amendment, Meyer v. Durable, Legal? Nebraska , 262 U.S. 390, 399 (1923) (striking down a state statute forbidding the teaching of any subject in Cornell Cornell Connections, any language other than English, or the teaching of modern foreign languages below the eighth grade). The right of privacy, the Power Of Attorney, Court in Roe noted, also has “some extension to activities relating to Note Pdf. Cornell Are Great marriage, . . . procreation, . . . family relationships, . Printable Power Durable, For Health? . . and child rearing and education. 410 U.S. at 152-53 , citing the following cases: Loving v. Virginia , 388 U.S. 1, 12 (1967), recognizing liberty interest in marrying the Cornell Cornell Notes Are Great For Making person of one’s choice; Skinner v. Oklahoma , 316 U.S. 535, 541-42 (1942), striking down statute mandating sterilization of Printable certain recidivists; Eisenstadt v. Baird , 405 U.S. 438 (1972), striking down statute prohibiting distribution of contraceptives to unmarried persons; Prince v. Massachusetts , 321 U.S. 158, 166 (1944), recognizing authority of parents over their children, but upholding child labor laws as applied to the children of Jehovah’s Witnesses who were distributing religious literature in exchange for voluntary contributions; Pierce v. Society of Sisters ,268 U.S. 510, 535 (1925), striking down statute mandating public education of children between the ages of eight and sixteen; and Meyer v. Nebraska (holding described above).

II. Critique of Roe’s Privacy Theory ^ top. The Supreme Court’s reliance on privacy theory to support a right to abortion is problematical at several levels. First, as the Court itself recognized, Roe , 410 U.S. at 152, the Constitution itself “does not expressly mention any right of privacy.” To be sure, as Justice Hugo Black noted in Resume And Cover, his dissent in Griswold v. Connecticut , 381 U.S. 479, 508-10 (1965) (Black, J., dissenting), various provisions of the Bill of Rights protect specific privacy interests, for example, the First Amendment’s right of associational privacy, the Fourth Amendment’s protection against unreasonable searches and Free Durable,, seizures and the Fifth Amendment’s prohibition of compelled self-incrimination. But the - 10+ Free Documents Constitution does not create a general right of privacy. See , e.g ., Katz v. Printable Durable,? United States , 389 U.S. 347, 350 (1967) (Fourth Amendment, which “protects individual privacy against certain kinds of governmental intrusions,” “cannot be translated into a general constitutional ‘right to privacy’”).

Recognition of a “general constitutional ‘right to privacy’” cannot be reconciled with the care with which the Framers of the Isometric Paper Stock Vector Art 492398429 | Istock Bill of Rights described the specific rights that were being secured. Second, the concept of “privacy” is amorphous and chameleon (or, in Printable Durable, For Health, Justice Black’s words, “broad, abstract and ambiguous,” Griswold , 381 U.S. at Graph Paper Vector, 509 ). Printable Power Of Attorney, Legal? Roe’ s attempt to collect cases under the rubric of “privacy” – a term that does not even appear in most of the cases cited – simply creates an artificial common denominator among a very disparate and largely unrelated group of cases that have nothing to do with the Resume And Cover subject of abortion, as the Court in Roe freely admitted: “The situation [involving a pregnant woman and her unborn child] . . Of Attorney, Durable, For Health Care Legal? . is Note Pdf. Cornell Notes Are Great Connections, inherently different from Free Printable Care, marital intimacy, or bedroom possession of obscene material, or marriage, or procreation, or education, with which Eisenstadt and Griswold , Stanley , Loving , Skinner , and Pierce and Meyer were respectively concerned.” 410 U.S. at | Sample Tips, 159 (emphasis added). 6 If a pregnant woman’s decision whether or not to carry her pregnancy to Free Power Of Attorney, Durable, For Health Care Legal term is “inherently different” from all of the “privacy” cases on which the Court relied, then it is difficult to Form - 10+ Download Documents In understand how those cases could possibly support recognition of a right to obtain an abortion. Third, most of the cases Roe cited in Printable Power Of Attorney, Legal, support of its privacy theory were decided under one or another of the provisions in the Bill of Isometric Graph Vector Art 492398429 Rights. Printable Power Of Attorney, For Health Care Legal? Roe itself, however, derived the right of privacy (and a subsidiary right to abortion) from the liberty language in the Due Process Clause of the | Sample Resumes Fourteenth Amendment, 410 U.S. at 153, not from any of the specific guarantees set forth in the Bill of Rights. That directly contradicted the Court’s express refusal, only a few years earlier in Griswold , 381 U.S. at 481-82, to rely upon Free Power Of Attorney, Durable, For Health Care Legal the Due Process Clause in postulating a right of privacy. Fourth, even with respect to the Due Process Clause, the Court no longer examines substantive due process claims (of which, more below) through the lens of privacy, and that includes the subject of abortion. In reaffirming the “core holding” of Roe – that the State may not prohibit abortion before viability for any reason or after viability if the pregnant woman’s life or health would be endangered by continuing the pregnancy – the Court, in Planned Parenthood v. Casey , 505 U.S. 833, 846-53 (1992), relied upon Flickriver: 'flyer the liberty language of the Due Process Clause of the Fourteenth Amendment, not upon privacy theory. 7 See also Cruzan v. Director , Missouri Dep’t of Power Of Attorney, Care Health , 497 U.S. 261, 279 n. 7 (1990) (analyzing right to refuse unwanted medical treatment “in terms of a Fourteenth Amendment liberty interest, rather than under a “generalized constitutional right of privacy”).

Focusing more particularly on the Fourteenth Amendment, § 1 thereof provides, in relevant part, that no State shall “deprive any person of life, liberty, or property, without due process of law . . . .” As its language suggests, the Due Process Clause is concerned with the process by Hotel Invoice | Excel which a person may be deprived of life, liberty or property, not the substance of the law authorizing such deprivation. See Lawrence v. Texas , 539 U.S. 558, 592 (2003) (Scalia, J., dissenting) . It was never the Power Of Attorney, Durable, intent of the Framers of the Fourteenth Amendment that the Due Process Clause would serve as a battering ram to Cornell Note Cornell Notes Are Great For Making Connections knock down statutes the substance of which offended the Power Of Attorney, sensibilities of a majority of Justices who happen to sit on the Supreme Court from time to time. See Raoul Berger, Government by Judiciary The Transformation of the Fourteenth Amendment (Liberty Fund 2d ed. 1997) 221-39, 273-306. 8 Despite its focus on process, the Due Process Clause, at various times in our history, has been given substantive content, resulting in the invalidation of | Sample Tips state laws thought to be inconsistent with prevailing understandings of “liberty.” The paradigmatic case in this area, before Roe v, Wade was decided in 1973, is Power Of Attorney, Care Legal, Lochner v. Tenant Information Download Documents? New York , 198 U.S. 45 (1905). In Lochner , the Supreme Court, over the vigorous dissent of Justice Oliver Wendell Holmes, Jr., held that state legislation setting limits on the number of hours a person could work in a bakery daily (ten hours) and weekly (sixty hours) violated the liberty of an employer to contract with his employees on terms that were mutually agreeable to them.

The notion that the Due Process Clause has substantive (as opposed to Free Power Of Attorney, Durable, Legal only procedural ) content bedeviled constitutional adjudication for a generation, until it was laid to rest, at least with respect to the review of social and economic legislation, in West Coast Hotel v. Parrish , 300 U.S. 379 (1937), which upheld a minimum wage law. Isometric Paper Stock Art 492398429 | Istock? Twenty-five years later, the Supreme Court could state that it had “returned to the original constitutional proposition that courts do not substitute their social and economic beliefs for Free Printable Power For Health Care Legal the judgment of legislative bodies.” Ferguson v. Skrupa , 372 U.S. 726, 730 (1963). Despite the interment of what may be called “economic” substantive due process, “libertarian” substantive due process is alive and Isometric, well. Under this strand of Free Printable Power Of Attorney, For Health Care substantive due process analysis, the Due Process Clause “provides heightened protection against Resume And Cover Writing government interference with certain fundamental rights and liberty interests.” Washington v. Glucksberg , 521 U.S. Free Printable Power Of Attorney, Durable, For Health Care? 702, 720 (1997). Roe v. Wade , while sounding in Isometric Graph Paper Vector, privacy theory, was ultimately based on the liberty language of § 1 of the Due Process Clause of the Free Power Of Attorney, Durable, For Health Care Fourteenth Amendment, see Roe , 410 U.S. at 153, and, therefore, may justly be regarded as the Sample | Sample Resumes And Resume Tips modern paradigm of (libertarian) substantive due process analysis.

See Richard Epstein, Substantive Due Process by Any Other Name , 1973 Sup. Ct. Rev. 159, 184. But Roe flunks the test the Court uses for evaluating substantive due process claims.

In determining whether an asserted liberty interest (or right) should be regarded as fundamental for Free Of Attorney, For Health Care purposes of substantive due process analysis (infringement of which would call for strict scrutiny review), the Supreme Court applies a two-prong test. First, there must be a “careful description” of the Tenant Form Download Free Documents In asserted fundamental liberty interest. Durable, For Health Care Legal? Glucksberg , 521 U.S. at 721 (citation and Effective Writing Techniques, internal quotation marks omitted). Second, the interest, so described, must be firmly rooted in “the Nation’s history, legal traditions, and practices.” Id. at 710. An asserted interest in (or right to) abortion does not meet the second prong of the Glucksberg test. Quite the contrary. Printable Of Attorney, Durable, Care Legal? As much research has established, especially that of Professor Dellapenna ( see n. Photoset? 4, supra ) , abortion was a crime in Power Of Attorney, Durable, Care Legal, English and American common law, at least after “quickening” (that stage of pregnancy when the woman first detects fetal movement, usually sixteen to eighteen weeks’ gestation), and very possibly without such a limitation. With the gradual replacement of common law crimes by Great | Sample Resumes Tips statutory crimes in the nineteenth century, the overwhelming majority of States had made the performance of an abortion at any stage of pregnancy a crime well before the Fourteenth Amendment was adopted in 1868. And the case law interpreting these statutes revealed that the principal, if not exclusive, purpose in enacting these statutes was to protect unborn human life, not (or not solely) to safeguard women from dangerous medical and/or surgical procedures.

See Paul Benjamin Linton, Planned Parenthood v. Casey : The Flight from Free Of Attorney, Durable, For Health Care Legal, Reason in the Supreme Court , XIII St. Louis U. Pub. L. Rev. 15, 109-15 (1993). In light of the foregoing, an interest in (or right to) abortion cannot be said to be firmly rooted in our “history, legal traditions, and practices.” III. Applications of Roe ^ top. The Supreme Court has decided almost three dozen abortion cases since and including Roe v. Wade and Doe v. Bolton . And Cover? A detailed analysis of the holdings in these cases would unduly prolong the length of this essay. The principal holdings, however, may be briefly summarized:

In addition to the Texas abortion statutes struck down in Roe , the Free Of Attorney, For Health Legal Court has struck down state statutes prohibiting particular abortion methods, Planned Parenthood of Central Missouri v. Danforth , 428 U.S. | Sample And Resume Tips? 52, 75-79 (1976) (saline amniocentesis), Stenberg v. Printable Of Attorney, Care? Carhart , 530 U.S. Pdf. Are Great? 914 (2000) (partial-birth abortion), but more recently has upheld the Power federal Partial-Birth Abortion Ban Act, Gonzales v. Carhart , 550 U.S. 124 (2007). The Court has upheld statutes prohibiting non-physicians from performing abortions, Mazurek v. Armstrong , 520 U.S.

968 (1997) ( per curiam ) and has held that non-physicians may be prosecuted for performing abortions, Connecticut v. Menillo , 423 U.S. 9, 11 (1975) ( per curiam ) . The Court has struck down statutes and ordinances requiring all abortions (or all abortions after the first trimester) to be performed in hospitals, Doe v. Bolton , 410 U.S. Isometric Graph Paper Stock? 179, 193-95 (1973) (all abortions), City of Akron v. Akron Center for Reproductive Rights ( Akron Center I ) , 462 U.S. 416, 431-39 (1983) (all abortions after the first trimester), Planned Parenthood Ass’n of Free Power Of Attorney, For Health Care Legal Kansas City , Missouri , Inc. v. Ashcroft , 462 U.S. 476, 481-82 (1983) (all abortions after the first twelve weeks of pregnancy), but has upheld a statute requiring all second trimester abortions to Sample Form - 10+ Download Free Documents In be performed in either a hospital or a licensed outpatient clinic, Simopoulos v. Virginia , 462 U.S. 506, 510-19 (1983). The Court has struck down parental consent and notice statutes and ordinances if they did not contain a judicial bypass mechanism that would afford the Free Printable Care Legal pregnant minor the Tenant Form opportunity to Power For Health Legal avoid obtaining the Note Pdf. Notes consent of (or giving notice to) her parents or legal guardian, 9 Danforth , 428 U.S. at 72-75 (one-parent consent), Akron Center I , 462 U.S. at 439-42 (one-parent consent without judicial bypass), Bellotti v. Baird , 443 U.S.

622 (1979) (two-parent consent) (inadequate judicial bypass), Hodgson v. Minnesota , 497 U.S. 417, 450-55 (1990) (two-parent notice without judicial bypass), 10 but has upheld statutes that contained an adequate judicial bypass, Ashcroft , 462 U.S. at Printable For Health Care Legal, 490-93 (one-parent consent). Hodgson , 497 U.S. at 497-501 (Kennedy, J., concurring in Invoice Free Invoice Template, the judgment in part and dissenting in part), id. at 461 (O’Connor, J., concurring in part and concurring in the judgment in part) (two-parent notice with judicial bypass), Ohio v. Free Durable, For Health Care Legal? Akron Center for Reproductive Health ( Akron Center II ) , 497 U.S. 502 (1990) (one-parent notice with judicial bypass), Planned Parenthood v. Casey , 505 U.S. 833, 899-900 (1992) (one-parent consent), Lambert v. Wicklund ,520 U.S. 292 (1997) (one-parent notice) ( per curiam ) . Note Notes Connections? The Court has struck down statutes requiring a married woman to obtain the consent of, or give notice to, her husband before undergoing an abortion, Danforth , 428 U.S. at 67-72 (consent), and Casey , 505 U.S. at 887-98 (notice) . The Court has upheld state and federal statutes restricting public funding of abortions, Beal v. Doe , 432 U.S. 438 (1977), Maher v. Roe , 432 U.S. 464 (1977), Harris v. McRae , 448 U.S. 297 (1980), and Free Printable Durable, Care Legal, Williams v. Zbaraz , 448 U.S. 358 (1980), as well as state statutes and municipal government policies prohibiting the performance of abortions by public employees within the scope of their employment or in publicly owned and operated facilities (other than those necessary to save the life of the Invoice Printable. Free Hotel Template | Excel | Pdf mother), Poelker v. Doe , 432 U.S.

519 (1977), and Webster v. Reproductive Health Services , 492 U.S. 490, 507-11 (1989). The Court has also upheld federal administrative regulations (since rescinded) requiring physical and Free Power For Health Care Legal, financial separation of Tenant Form Documents In Title X family planning projects from other projects operated by Title X grantees that perform, counsel or refer for abortion, Rust v. Free For Health Legal? Sullivan , 500 U.S. 173 (1991). The Court has upheld a requirement that a pathology report be prepared for all fetal tissue obtained in the course of an abortion, Ashcroft , 462 U.S. at 486-90 , but has struck down a requirement that fetal remains be disposed of in a “humane and sanitary manner,” Akron Center I , 462 U.S. at 451-52 . Effective And Cover Letter? The Court has upheld some record keeping and Free Power For Health Care Legal, reporting requirements, Danforth , 428 U.S. at 79-81 , Casey , 505 U.S. at 900-01 , while striking down others, Thornburgh v. American College of Printable. Free Obstetricians Gynecologists , 476 U.S. 747, 765-68 (1986), because of what the Court perceived as inadequate guarantees of patient confidentiality. The Court has upheld a requirement that a second physician be present during the performance of a post-viability abortion to provide immediate medical care for a viable child who survives an Free Printable Power, abortion procedure, Ashcroft , 462 U.S. at 482-86 , but has struck down a second-physician requirement that did not contain an express or implied exception for medical emergencies, Thornburgh , 476 U.S. at 769-71 . The Court has also struck down standards of care for the performance of post-viability abortions that were either vague, Colautti v. Franklin , 439 U.S. 379, 397-401 (1979), or posed an Effective Letter Techniques, unacceptable risk to the mother’s health, Thornburgh , 476 U.S. at Power Durable, For Health Care Legal, 768-69 , but has upheld a statute mandating fetal viability testing at Isometric Graph Stock Vector | Istock, twenty weeks’ gestation, Webster , 492 U.S. at 513-21 . In a pair of decisions, later overruled in Free Printable Power Durable, For Health Legal, part by Planned Parenthood v. Casey , 505 U.S. 833 (1992), which is discussed in the next part of this essay, infra , the Effective Resume Writing Court held that States and municipalities could not require a short waiting period before the performance of a non-emergency abortion; that they could not required detailed informed consent information to Printable Power Durable, Care be given to Invoice Printable. Free | Excel the pregnant woman seeking an abortion; and that they could not require portions of the informed consent information to be conveyed in person to the patient by the attending physician, see Akron Center I , 462 U.S. at 442-51 and Thornburgh , 476 U.S. at 759-65 . 11.

IV. Printable Power Care? Roe Revisited: Planned Parenthood v. Casey ^ top. In 1992, the Supreme Court revisited Roe and, in a Joint Opinion authored by Justices Sandra Day O’Connor, Anthony Kennedy and David Souter, substantially modified its holdings. Planned Parenthood v. Casey , 505 U.S. Great Resumes | Sample? 833 (1992). In Casey , the Printable Of Attorney, Durable, For Health Court reaffirmed what it characterized as the “essential” (or “central”) holding of Roe , consisting of three parts: First, a woman has “the right . . . . to choose to have an abortion before viability and to obtain it without undue interference from the State. Before viability, the State’s interests are not strong enough to support a prohibition of | Sample And Resume abortion or the imposition of a substantial obstacle to the woman’s effective right to elect the procedure.” 505 U.S. at 846. Second, the State has the power “to restrict abortions after fetal viability, if the law contains exceptions for pregnancies which endanger the woman’s life or health.” Id . And, third, “the State has legitimate interests from the outset of the pregnancy in protecting the health of the woman and For Health Legal, the life of the fetus that may become a child.” Id . While reaffirming the “essential” (or “central”) holding of Roe , the authors of the Joint Opinion rejected Roe’s “trimester” framework as an unnecessarily “rigid construct” which “in its formulation . . . misconceives the nature of the Paper Stock | Istock pregnant woman’s interest,” and Power Legal, “in practice . . . Sample Resumes And Resume Tips? undervalues the State’s interest in potential life . . . .” Id . at 872-73. The trimester framework “misconceives the nature of the pregnant woman’s interest” because “[w]hat is at Free Durable, For Health Legal, stake is [her] right to And Cover Letter Techniques make the ultimate decision [to obtain an abortion prior to viability], not a right to be insulated from all others in doing so.” Id . at 877. Free Power Durable, For Health Care Legal? “Though the Great Sample Resumes Tips woman has a right to Free Power Durable, Care Legal choose to terminate or continue her pregnancy before viability,” the Joint Opinion explained, “it does not at Resume And Cover Techniques, all follow that the State is Of Attorney, Durable, For Health Care Legal, prohibited from 'flyer By Anderworks, taking steps to ensure that [her] choice is thoughtful and informed.” Id . at Free Durable,, 872.

The trimester framework “undervalues the State’s interest in Sample | Sample Tips, potential life,” the Joint Opinion continued, because the State has a “substantial state interest in potential life throughout pregnancy,” id . at 876, not just after viability. In light of their dissatisfaction with the trimester framework of Roe and how it had been applied in Free Durable, For Health Care Legal, subsequent cases, the authors of the Sample Tenant Form - 10+ Download Documents In Joint Opinion developed a new standard for reviewing pre-viability abortion regulations, the so-called “undue burden” test. Casey , 505 U.S. at 874-79. Under that test, “a state regulation [that] has the purpose or effect of placing a substantial obstacle in the path of a woman seeking an Legal, abortion of a nonviable fetus” is Photoset, unconstitutional. Id . at 877. Applying that test to the statutes challenged in Casey (multiple provisions of the Pennsylvania Abortion Control Act of 1982, as amended), a majority of the Court upheld the detailed informed consent requirement (including the mandated twenty-four hour waiting period), the parental consent requirement and the record keeping and reporting requirements, id . at 881-87, 899-901, but a differently constituted majority struck down the spousal notice requirement , id . at 887-98 . 12 In upholding the informed consent requirement (and the accompanying waiting period), the Court overruled, in part, its earlier conflicting precedents in Akron Center I and Thornburgh . Id . at 881-82. 13. Both Justice Harry Blackmun and Justice Paul Stevens dissented from the Joint Opinion’s abandonment of Power For Health Care Roe’s trimester framework and the strict scrutiny standard of review, while Chief Justice William Rehnquist, joined by Sample Tenant Information - 10+ Download Free Justices Byron White, Antonin Scalia and Clarence Thomas, dissented from the reaffirmation of the “essential” holding of Roe , arguing that the rational basis standard should be applied to all regulation of abortion.

14. The Joint Opinion in Casey is notable in five respects: First, in Printable Power Of Attorney,, reaffirming what it characterized as the “essential” (or “central”) holding of Roe , the Tenant Information Form Download In authors of the Joint Opinion raised the issue but refused to state whether they believed that Roe had been correctly decided as an original matter of Power Durable, For Health constitutional interpretation, Casey , 505 U.S. at 871 (“[w]e do not need to say whether each of us, had we been Members of the Court when the valuation of the Tenant Information Form Free state interest [in the protection of For Health “potential life”] came before it as an original matter, would have concluded, as the Roe Court did, that its weight is insufficient to justify a ban on abortions prior to viability even when it is subject to Isometric Paper Vector Art 492398429 certain exceptions”), 15 relying instead on Free Power Durable, For Health Legal, “principles of institutional integrity” and “the rule of stare decisis [deferring to precedent].” Id . at 845-46; see also id. at Resumes | Sample And Resume, 854-69. Power Of Attorney, Care Legal? Second, the Paper Vector Joint Opinion provided no principled basis for distinguishing between the “essential” (or “central”) and the inessential (or peripheral) holdings of Roe , reaffirming the Free former and overruling the latter. Flickriver: Mania'? As Justice Scalia commented, “I must . . Durable, Care Legal? . confess that I have always thought, and Flickriver: Photoset, I think a lot of other people have always thought, that the arbitrary trimester framework, which the Court today discards, was quite as central to Free Power Of Attorney, Durable, Care Roe as the Free Hotel Invoice | Excel arbitrary viability test, which the Court today retains.” Id . at 993. (Scalia, J., concurring in the judgment in part and Printable Of Attorney, For Health Legal, dissenting in Free Invoice Template | Excel, part). Third, in reaffirming the “essential” holding of Free Printable Roe , the Joint Opinion abandoned Roe’s reliance on privacy theory, resting its analysis, instead, on the liberty language of Isometric Paper Stock § 1 of the Fourteenth Amendment. Fourth, the Joint Opinion tacitly abandoned Roe’s characterization of the right to abortion as “fundamental.” 16 And, fifth, the Printable For Health Legal Joint Opinion substituted a new standard of review – “undue burden” – in Isometric Graph Paper Stock Vector Art 492398429 | Istock, place of the strict scrutiny standard employed in Roe for evaluating fundamental rights, which clearly allows for a broader scope of Power Care regulation (but not prohibition) of pre-viability abortions.

17. The strict scrutiny standard of judicial review applies to Invoice Free Hotel | Pdf laws that either interfere with the exercise of a fundamental constitutional right ( e.g ., voting) or discriminate on the basis of Power Of Attorney, Care Legal a suspect classification ( e.g ., race). Flickriver: By Anderworks? A law reviewed under this standard is Free Power Of Attorney, Durable,, presumed to be un constitutional and will not be upheld unless its proponents are able to demonstrate that it is necessary to promote a compelling state (or governmental) interest. Few, if any, laws reviewed under this standard survive. At the opposite end of the spectrum is the rational basis standard of review, which applies to Isometric Graph Stock Vector Art 492398429 almost all other legislation. 18 Under this standard, a law is presumed to be constitutional and will be upheld so long as it has a rational relationship to any legitimate state (or governmental) purpose.

Most laws reviewed under this standard survive constitutional scrutiny. V. The Roberts Court and the Future of Printable Power Of Attorney, Care Abortion Jurisprudence ^ top. Under the leadership of Chief Justice John Roberts, the Supreme Court has taken a more cautious approach to the review of abortion regulation. Most obviously, the Court, in an opinion by Justice Kennedy, upheld the federal Partial-Birth Abortion Ban Act in Gonzales v. Carhart , 550 U.S. 124 (2007) ( Carhart II ), after a differently constituted Court struck down a similar (but more vaguely worded) state statute only seven years earlier in Stenberg v. Carhart , 530 U.S. 914 (2000) ( Carhart I ). Less obviously, the Court has suggested that, at least with respect to the regulation of abortion, “facial challenges,” i.e ., a claim that a given statute is Resume, unconstitutional in its entirety, are disfavored, Carhart II , 550 U.S. 124 at Free Power Care Legal, 130 (“these facial attacks should not have been entertained in the first place”), and “as-applied” challenges, i.e ., a claim that a statute is unconstitutional in particular circumstances, are preferred, id . at 168 (“[a]s-applied challenges are the basic building blocks of constitutional adjudication”) (citation and internal quotation marks omitted).

Relatedly, in another decision of the Roberts Court, the Court unanimously held, in an opinion by Justice O’Connor, that when only a limited number of applications of an abortion statute would be unconstitutional, the proper remedy (if otherwise consistent with legislative intent) is to enjoin enforcement of those applications only, not to declare the entire statute unconstitutional. Ayotte v. Planned Parenthood of Northern New England , 546 U.S. 320, 328-31 (2006) (reviewing parental notice law). Significantly, in Ayotte , Justice O’Connor acknowledged that the Court did not take this more circumspect approach in Carhart I, id . at 330-31 (explaining that “the parties . . . did not ask for, and we did not contemplate, relief more finely drawn” than complete invalidation). 19. In light of the Roberts Court’s more cautious approach to the review of abortion legislation, fewer challenges to abortion statutes may be expected.

Moreover, even with respect to those challenges that are brought and Sample | Sample Resumes And Resume, are determined to have merit, both the Supreme Court and Free For Health Care Legal, the lower federal courts are likely to strike down the statute and enjoin its enforcement only with respect to Cornell Pdf. Are Great its invalid applications, not in its entirety. VI. A Comment on the Scope of the Free Printable For Health Care Health Exception ^ top. Finally, a brief comment on Flickriver: Photoset, an unresolved area of abortion law – the scope of the health exception required by Roe (as reaffirmed in Power Of Attorney, Legal, Casey ). In Roe , the Supreme Court held that the States may prohibit abortion after viability “except when it is necessary to preserve the life or health of the mother.” 410 U.S. at Resume And Cover Letter Writing, 164. Printable Power Of Attorney, Legal? The Court, however, did not define the term “health.” In the companion case of Doe v. Bolton , the Court considered a challenge to what remained of the Georgia abortion statute after major provisions of the statute had been declared unconstitutional by a federal district court. As a result of the district court’s decision, a physician could perform an abortion whenever he determined, in “his best clinical judgment,” that the abortion was “necessary.” At issue in Cornell Notes For Making Connections, Doe was whether this standard was impermissibly vague. The Court concluded that it was not: [T]he medical judgment [as to whether an abortion is “necessary”] may be exercised in the light of all factors – physical, emotional, psychological, familial, and the woman’s age – relevant to the well-being of the patient.

All these factors may relate to Printable Of Attorney, Durable, For Health health. Whether Doe , properly understood, mandates an open-ended “health” exception for post-viability abortions is debatable. Although there is the merest hint in one older case that the Flickriver: By Anderworks Court (as then constituted) may have regarded the broad language in Free Power Of Attorney, For Health, Doe as a limitation on the State’s authority to prohibit post-viability abortions, see Colautti v. Franklin , 439 U.S. 379, 400 (1979), the And Cover Letter Writing Court has never directly considered the validity of a post-viability ban. Lower federal courts have read Doe as a gloss on the scope of the health exception that must be included in any post-viability ban, 20 but that reading misinterprets Doe , as Justice Thomas noted in his dissent from the denial of certiorari in Voinovich v. Power Durable, Legal? Women’s Medical Professional Corp . , 523 U.S.

1036 (1998): Our conclusion that the statutory phrase at issue in Doe [whether the abortions was “necessary”] was not vague because it included emotional and psychological considerations in no way supports the proposition that, after viability, a mental health exception is Hotel Invoice Template | Excel, required as a matter of federal constitutional law . Doe simply did not address that question. 523 U.S. at 1039 (emphasis in Printable Power Durable, For Health Care, original). As things now stand, whether the open-ended “health” language of Doe is a limitation on the authority of the States to prohibit post-viability abortions remains an open question, but one that should be answered by a challenge to an appropriately drafted statute. Given the present composition of the Isometric Art 492398429 Court, there is reason to Power Durable, For Health Care Legal believe that such a statute would be upheld. In recognizing a constitutional right to abortion, the Great Sample Resumes And Resume Tips Court in Roe believed that it was meeting the “profound problems of the present day.” 410 U.S. at 165. The “problems” which the Court thought would be ameliorated by Power Of Attorney, Care its decision included the medical risks associated with pregnancy, a “distressful life and future” for Sample Tenant - 10+ Free the pregnant woman confronted with an unwanted pregnancy, “[p]sychological harm,” the Free Power Legal difficulty in Graph Vector Art 492398429 | Istock, providing “child care,” “the distress, for all concerned, associated with the unwanted child,” “the problem of bringing a child into a family already unable, psychologically or otherwise, to care for it,” and, for some, “the additional difficulties and continuing stigma associated with unwed motherhood . . . Free Printable Power Of Attorney, Durable, Legal? .” Id . at Sample Information Form - 10+, 153. More than thirty years of experience with legalized abortion has failed to solve these problems, as well as others for which abortion was touted as a panacea (crime and poverty). Indeed, the regime of legal abortion has aggravated them. See Clarke D. Forsythe and Stephen B. Presser, The Tragic Failure of Roe v. Power Of Attorney, For Health Care? Wade: Why Abortion Should be Returned to Isometric Graph Paper | Istock the States . 10 Tex.

Rev. of Law Politics 85, 108-36 (Fall 2005). In reaffirming, as modified, Roe in Printable Of Attorney, Durable, Care, Casey , the 'flyer Supreme Court “call[ed] the contending sides of a national controversy to end their national division by accepting a common mandate rooted in the Constitution.” 505 U.S. at 867. Given the issues at stake in abortion, that call, not surprisingly, has not been heeded. The abortion liberty has no “roots” in the Nation’s history, traditions and legal practices. Free Printable Durable,? And the “national division” over the abortion controversy, which Roe created and Casey continued, will not end until, initially, the Are Great For Making Supreme Court returns the issue of abortion to Printable Durable, the States and, eventually, the Constitution is amended to protect the Invoice Printable. Free Template | Pdf lives of all unborn children. A discussion of the various standards of judicial review may be found in Part IV of this essay, infra . back. When Roe was decided, an Free For Health Care Legal, unborn child was “viable,” i.e ., capable of living outside of his or her mother, at twenty-eight weeks of gestation.In light of medical advances made since Roe , viability may occur at twenty-three to twenty-four weeks, or, in some instances, even earlier, as the Supreme Court recognized almost twenty years ago in Planned Parenthood v. Casey , 505 U.S. 833, 860 (1992) (noting that viability may occur at twenty-three to twenty-four weeks). back.

Section 230.3 of the Model Penal Code, one version or another of which was adopted by thirteen States before Roe v. Wade , allowed abortion whenever the physician believed that there was a “substantial risk” that continuance of the pregnancy “would gravely impair the physical or mental health of the mother,” that “the child would be born with grave physical or mental defect,” or that “the pregnancy resulted from rape, incest, or other felonious intercourse.”In Doe , the Court also struck down a requirement that an abortion could be performed only upon a bona fide resident of the State of Information Form Download Free In Georgia. Doe , 410 U.S. at 200. Free Power Of Attorney, Durable, For Health Legal? back. As a result of the district court's judgment, a physician could perform an abortion whenever, in his best clinical judgment, the procedure was necessary. back. Interested readers, however, may wish to consult some of the following sources. An early critique of the Court's handiwork in Roe , which includes a brief review of the initial academic responses to Printable. Hotel Invoice Template | Pdf Roe (both favorable and unfavorable) is John T. Noonan, Jr.'s, A Private Choice: Abortion in America in Of Attorney, Durable, For Health Care, the Seventies (The Free Press 1979).

Dennis J. Horan, Edward R. Grant and Paige C. Cunningham (eds.), Abortion and the Constitution: Reversing Roe v. Wade Through the Form - 10+ Download Documents In Courts (Georgetown University Press 1987), is a compendium of Power Of Attorney, Durable, Care Legal articles written by Sample Resumes Resumes And Resume a variety of Of Attorney, Durable, For Health Legal authors criticizing various aspects of the holdings and analysis in Roe . The most comprehensive and thorough analysis of Roe's treatment of the historical treatment of abortion in English and American law, as well as the restatement of Invoice Printable. Hotel Invoice Template | Excel | Pdf that history in James C. Mohr's Abortion in America (Oxford University Press 1978), is Printable For Health Care, Joseph W. Dellapenna's Dispelling the Myths of Abortion History (Carolina Academic Press 2006) (an extremely abbreviated version of Professor Dellapenna's analysis appears in Abortion and Sample Resumes And Resume, the Constitution , supra , at 137-58). A concise critique of the Court's historical excursus in Care, Roe , particularly its explanation for Sample Information - 10+ Free In the reasons nineteenth century abortion statutes were enacted, may be found in Appendix A to Paul Benjamin Linton's article, Planned Parenthood v. Casey : The Flight from Reason in the Supreme Court , XIII St. Louis U. Pub. L. Rev. 15, 103-19 (1993). Printable Power Care? The poor quality of the analysis and reasoning in Roe has led some academics to rewrite the opinion.

A collection of such opinions and opposing dissents, along with a useful selected bibliography, appears in And Cover Letter, Jack M. Balkin (ed.), What Roe v. Wade Should Have Said (New York University Press 2005). back. All of the holdings in these cases, and the full citations thereto, appear in Part I of this essay, supra . back. Planned Parenthood v. Casey is discussed in more detail in Part IV of this essay, infra . back. Justices Oliver Wendell Holmes, Jr., Louis D. Brandeis and Hugo Black, as well as Judge Learned Hand, who served on the Second Circuit Court of Appeals for Free Printable Power Care Legal decades, all agreed that the use of the liberty language of the Due Process Clause to invalidate the substance of state enactments is fundamentally illegitimate. See Berger, Government by Judiciary , at 227-28 n. 27 (Black), 282 n. 46 (Holmes, Brandeis and Resume And Cover Letter Techniques, Hand). back. Consent of (or notice to) a parent or legal guardian may be waived by Free Printable Power Of Attorney, Durable, For Health Legal a court in a judicial bypass hearing if the minor can demonstrate to the satisfaction of the Great Sample Resumes | Sample And Resume court that she is Printable Of Attorney, Durable, For Health, mature enough to make the decision to obtain an abortion without the Sample Resumes consent of Printable Power Of Attorney, Durable, (or notice to) her parent(s) or legal guardian, or, alternatively, that obtaining consent (or giving notice) would not be in her best interests. The Court has upheld both consent statutes, see , e.g ., Planned Parenthood v. Casey , 505 U.S. 833, 899-900 (1992), and Planned Parenthood Ass'n of Kansas City , Missouri v. Ashcroft , 462 U.S. Tenant Free Documents In? 476, 490-93 (1983), and notice statutes, see , e.g ., Ohio v. Akron Center for Reproductive Health , 497 U.S.502 (1990), and Hodgson v. Minnesota , 497 U.S. 417 (1990). Power Durable, Care? back. See also Ayotte v. Planned Parenthood of Great Sample Tips Northern New England , 546 U.S.

320 (2006) (one-parent notice statute could not be enforced constitutionally in medical emergencies requiring the Free Printable Power Of Attorney, immediate performance of an abortion). back. A general and non-specific requirement that a physician obtain the informed consent of the patient before performing an abortion was upheld in Danforth , 428 U.S. at Sample Tenant Form Download Free Documents In, 65-67. back. The Court also upheld the medical emergency definition. Casey , 505 U.S. at 879-80. back. The holdings in Printable Power Durable,, Akron Center I and Thornburgh are discussed in Part III, supra . back. These alternative standards of review are discussed below. back.

See also id. at 853, 858, 864, 869. back. Nowhere in Invoice | Excel | Pdf, the Joint Opinion is the right to abortion described as fundamental. back. The Joint Opinion in Casey has been subjected to withering criticism. See Paul Benjamin Linton, Planned Parenthood v. Casey : The Flight from Reason in the Supreme Court , XIII St. Louis U. Pub. L. Rev. 15, 103-19 (1993); Michael Stokes Paulsen, The Worst Constitutional Decision of All Time , 78 Notre Dame L. Rev. 995 (2003). Free Of Attorney, Durable, Care Legal? Casey is also extensively discussed and critiqued in Professor Dellapenna's magnum opus , Dispelling the Myths of Abortion History , supra , n. Invoice Free Hotel Invoice? 4. back. Under federal constitutional equal protection doctrine, an intermediate standard applies to classifications based on sex or illegitimacy.

Under that standard, often referred to as heightened scrutiny, the classification must be substantially related to an important state (or governmental) interest. back.