Substantial numbers of pregnant adolescents do not consult either their mother or father prior to obtaining an abortion. A Minnesota study found that 43% of adolescents obtaining abortions used the court bypass option to avoid disclosure to a parent. (Factors Associated with the Use of Court Bypass by Minors to Obtain Abortions, RW Blum et al, Family Planning Perpectives 22:158, July/Aug 1990.) Male partners have been found to be more likely to be consulted than parents once pregnancy is confirmed (83% v. 56%). (Patterns of Consultation Among Adolescent Minors Obtaining An Abortion, MD Resnick et al, Amer. J. Orthopsychiatr. 64:310, April,1994.) An Atlanta study of adolescents obtaining abortions at five different private facilities found that 51% confided in their parents. (Parental Consent: Factors Influencing Adolescent Disclosure Regarding Abortion, MS Griffin-Carlson, KJ Macklin, Adolescence 28(109):1,Spring,1993.) According to the Centers for Disease Control, 20% of the reported abortions in the U.S. are among those who are 19 years of age or less. (Abortion Surveillance: Preliminary Data-United States,1993, MMWR 45(11):235, Mar 22,199

In Baldaraz v. Granbury School District, the parents of a 17-year-old high school student brought suit in U.S. District Court in Fort Worth, Texas, after she suffered a uterine infection and psychological distress following an abortion without her parents' knowledge. According to the complaint, a high school drug awareness counselor discovered that the girl was pregnant and called her out of class to urge her to have an abortion. The suit detailed elaborate plans made by the counselor in order to procure the abortion. According to the complaint, the parents had no knowledge of the abortion until the next day when their daughter began experiencing "extreme pain and discomfort". That same day a doctor diagnosed the girl as suffering from a severe uterine infection as a result of an incomplete abortion. According to the complaint, the counselor denied any involvement in arranging for the abortion when the girl's parents met with her and other school officials a week later. The principal of the school was said to have labeled the girl's account of the incident as a "hallucination". (Texas school counselor sued for urging 17-year-old student to have abortion, Action, The Rutherford Institute, October,1991 p.5)

In a Texas case of Clement v. Riston, M.D. Jefferson Co., Texas, 1990, the plaintiff, a minor, suffered severe emotional distress after she underwent an abortion performed by the defendant doctor. The plaintiff claimed that the defendant failed to get proper consent from the parent before performing the abortion. The defendant contended that the parental consent code was unconstitutional and that any emotional distress was caused by the plaintiff's relationship with one of her high school teachers and the football coach. A verdict of $20,000 was returned for the plaintiff.

Comments: The man who had sexual intercourse with the minor girl which resulted in her pregnancy and subsequent abortion appeared to be several years older than the minor. Recent studies have demonstrated that it is frequently the case that teen pregnancies result from males having sex with teenagers who are much younger than themselves which may be in violation of state criminal laws prohibiting sex with a minor. For example, a recent Population Reference Bureau study found that about two-thirds of births to teenage girls nationwide are fathered by adult men age 20 or older. The United States at Mid-Decade, CJ DeVita, Population Bulletin 50(4), Population Reference Bureau: Washington DC, March 1996. The Alan Guttmacher Institute reported in 1994 that six of ten girls who had sex before age 15 were coerced by males an average of six years older than the female. (Sex and America's Teenagers,1994, The Alan Guttmacher Institute: New York.) A Washington state study of 535 women who became pregnant as adolescents found that two-thirds had been sexually abused and 44% had been raped. The average age of the adolescent at first rape was 13.3 years while that of the perpetrator was 22.6 years. Sexual Abuse as a Factor in Adolescent Pregnancy and Child Maltreatment, D Boyer, D Fine, Family Planning Perspectives 24(1)4,Jan/Feb 1992)

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