Additionally, certain states did not repeal pre-1973 laws that criminalized abortion, and some could be in force again if Roe were repealed. There are also states like California and Nevada, who have put laws in place already to maintain the legality of abortion if Roe v. Wade was overturned.
There have been other court cases dealing with states and their place when it comes to abortions. In 1976, there was Planned Parenthood of Central Missouri v. Danforth. Two physicians who oversaw abortions in Missouri filed it. Missouri law said that patients under the age of 18 had to have spousal or parental consent before the abortion procedure. The court then ruled that Missouri's laws were unconstitutional because they delegated to third parties a veto power that that state did not have itself. In 1976 and 1979 during the Bellotti v. Baird trial, they reaffirmed their ruling in Danforth. Massachusetts's law required minors who hoped to get an abortion to obtain parental consent. The court gave states the ability to establish methods to determine if a girl was mature enough to make the decision. In two 1983 cases, the City of Akron v. Akron Center for Reproductive Health and Planned Parenthood v. Ashcroft, the court stated that the city of Akron, Ohio could not force girls under the age of fifteen to get parental consent for an abortion. They court also put a stop to restrictions on abortions after the first trimester be performed in hospital, doctors had to deliver a state sanctioned speech and that the fetal remains be disposed of in a "humane" way. In 1989 Thornburgh v. American College of Obstetricians & Gynecologist that court ruled that the Pennsylvania law that required women to hear a state-scripted speech written to deter abortions were illegal. Webster v. Reproductive Health Services in 1989 basically demonstrated that Roe was not a settle law. The court had upheld a Missouri ban on the use of public employees and facilities for performing abortions.