CASE SUMMARY: JUNE MEDICAL SERVICES LLC v. RUSSO (2020)

“We must stand up and speak out against attacks on women’s reproductive rights. The government has no place in a woman’s decision to choose what is best for her health and body.”  Cory Booker

INTRODUCTION

This case note explains why Louisiana’s Act 620, which required abortion providers to have admitting privileges within 30 miles, was struck down. The Court split 4–1–4. Justice Breyer wrote a plurality (joined by Ginsburg, Sotomayor, Kagan). Chief Justice Roberts concurred in the judgment based on stare decisis, not on the plurality’s balancing test. Four Justices dissented. The key point: the record in Louisiana looked materially the same as the Texas record in Whole Woman’s Health, so the law could not stand. The case also confirms third-party standing for providers at that time.[1]

FACTS

Louisiana passed Act 620 in 2014. The State framed it as a health-and-safety rule. After a full trial, the district court found the law would close clinics, reduce physician availability, and increase travel/wait times for patients, while providing no real medical benefit. The Fifth Circuit reversed. The Supreme Court granted certiorari and reviewed the trial record in light of Casey and Whole Woman’s Health.[2]

ISSUES

1. Standing: Can providers sue on behalf of their patients’ rights?[3]
2. Undue burden: Does Act 620 place a substantial obstacle on a large fraction of women seeking abortions in Louisiana?[4]
3. Precedent/method: How do Casey’s undue-burden standard and Whole Woman’s Health’s approach apply to this record?[5]

HOLDINGS

1. Standing: Providers could sue for their patients.[6]
2. Merits: Act 620 is unconstitutional. A majority agreed the law would significantly limit access while offering minimal (if any) benefits.[7]
3. Precedent: The controlling vote (Roberts, C.J.) turned on stare decisis: because the law and record mirrored Texas in Whole Woman’s Health, the same result followed—even though he rejected the plurality’s explicit balancing.[8]

REASONING

• Plurality (Breyer, J.)

The plurality leaned on the district court’s fact-finding. It cited evidence that admitting privileges were difficult to obtain (not tied to competency), that emergency rooms accept patients regardless of a doctor’s privileges, and that complications from abortion are rare. On this record, the law burdened access (closures, delays, travel) without offsetting benefits. Following Whole Woman’s Health, the plurality weighed burdens against benefits and found the burdens decisive.[9]

• Concurrence in the Judgment (Roberts, C.J.)

Roberts dissented in Whole Woman’s Health but said stare decisis controlled here. He read Casey as asking one question: does the law impose a substantial obstacle? He explicitly rejected an open-ended balancing test. [10]Still, because Louisiana presented no meaningful factual distinction from Texas, he concluded Act 620 must fall. His opinion therefore supplies the controlling rule: apply Casey’s obstacle test; if the record lines up with Whole Woman’s Health, the outcome should too.

• Dissents

The dissenters challenged standing, the credibility of the district court’s findings, and the merits. They argued providers have conflicts of interest, the factual record was misread, and States have broad police powers to regulate medical practice for safety. (Separate dissents by Justices Alito, Thomas, Gorsuch, and Kavanaugh)[11]

IMPACT

In the short run, clinics stayed open in Louisiana and provider standing remained intact. Doctrinally, the Court was fractured: the plurality embraced burden–benefit balancing under Whole Woman’s Health, while the Chief Justice recentered Casey on the substantial-obstacle inquiry without balancing. That split limited clarity but produced the same bottom line: Act 620 failed on this record. In the long run, the abortion-rights framework was reworked by Dobbs v. Jackson Women’s Health Organization (2022), which overruled Roe and Casey. [12]Even after Dobbs, June Medical still matters for how courts treat fact-heavy records, third-party standing, and the force of precedent when a case is materially indistinguishable.

CONCLUSION

June Medical is a lesson in method and restraint. The plurality and the Chief Justice used different tests, but both treated the trial record and prior decision as decisive. On those terms, Louisiana’s law imposed serious obstacles with little to no health payoff. The case shows how outcomes in rights-limiting health regulations can turn on facts, not slogans, and how stare decisis can control even when Justices disagree about doctrine.

REFERENCES

[1] June Med. Servs. L.L.C. v. Russo, 140 S. Ct. 2103 (2020), PDF: Supreme Court (last seen 26^th Sept, 2025)

[2] Whole Woman’s Health v. Hellerstedt, 579 U.S. 582 (2016), Opinion text: LII (Cornell Law) (last seen 26^th Sept, 2025)

[3] June Medical, 140 S. Ct. at 2120–41 (plurality) (burdens vs. benefits); id. at 2145–91 (various dissents). PDF: Supreme Court (last seen 26^th Sept, 2025)

[4] Id. at 2117–23 (standing); 2142–45 (Alito, J., dissenting). PDF: Supreme Court (last seen 26^th Sept, 2025)

[5] Planned Parenthood of Se. Pa. v. Casey, 505 U.S. 833 (1992), PDF: Library of Congress – U.S. Reports; HTML: LII (last seen 27^th Sept, 2025)

[6] June Medical, 140 S. Ct. at 2120–41 (plurality) (burdens vs. benefits); id. at 2145–91 (various dissents). PDF: Supreme Court (last seen 27^th Sept, 2025)

[7] Id. at 2117–23 (standing); 2142–45 (Alito, J., dissenting). PDF: Supreme Court (last seen 27^th Sept, 2025)

[8] June Medical, 140 S. Ct. at 2133–42 (Roberts, C.J., concurring in the judgment). PDF: Supreme Court (last seen 27^th Sept, 2025)

[9] Id. at 2117–23 (standing); 2142–45 (Alito, J., dissenting). PDF: Supreme Court (last seen 27^th Sept, 2025)

[10] June Medical, 140 S. Ct. at 2120–41 (plurality) (burdens vs. benefits); id. at 2145–91 (various dissents). PDF: Supreme Court (last seen 27^th Sept, 2025)

[11] Id. at 2117–23 (standing); 2142–45 (Alito, J., dissenting). PDF: Supreme Court (last seen 27^th Sept, 2025)

[12] Dobbs v. Jackson Women’s Health Org., 142 S. Ct. 2228 (2022), PDF: Supreme Court (last seen 27^th Sept, 2025)