The 25 years following the Supreme Court's landmark decision in Roe v. Wade have seen a tremendous amount of social and political activism on both sides of the abortion controversy. Far from settling the issue of a woman's constitutional right to an abortion, the Roe decision galvanized pro-life and prochoice groups and precipitated many small "battles" in what many on both sides view to be a "war" between fetal protection and women's access to reproductive choice. These battles have occurred at the judicial, grassroots, and political levels, with each side gaining and losing ground. Pro-life activists staged a nation-wide campaign of clinic protests, which led to Congress's 1994 enactment of the Federal Access to Clinic Entrances law creating specific civil and criminal penalties for violence outside of abortion clinics. State legislatures imposed limitations on the right to abortion, including mandatory waiting periods and requirements for parental or spousal notification. Many of these limitations were then challenged before the Supreme Court, which struck down or upheld them according to the "undue burden" standard of review articulated in Planned Parenthood of Southeastern Pennsylvania v. Casey.

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