In 1991 Rust v. Sullivan the court upheld regulation that barred abortion counseling and referrals in family planning clinics that were receiving federal funds. Basically, under Title X the court could ban those who receive federal funds from doing anything that promoted abortion as a family planning tool. In Planned Parenthood v. Casey the court had upheld all but one of Pennsylvania's Abortion Control Act. It made it so abortion patients in their first trimester had to receive an informed consent booklet and wait twenty-four hours before receiving said abortion, and minor girls had to receive one written consent from a parent. Although this conflicted with previous cases the court ruled that it did not pose an undue burden on the woman. This case weakened Roe v. Wade and gave states more leeway when it came to handling abortions. Even recently in 2000, the court case Stenberg v. Carhart struck down a Nebraska law that banned partial birth abortions. In 2007 this was largely reversed in the Gonzales v. Carhart decision. This case placed a nationwide ban on the use of an abortion method, either before or after viability, in which the baby is partly delivered alive before being put to death. Obviously a state's place on a woman's right to privacy is something that will be up for discussion for a while. There are currently cases in motion concerning abortion in the states that will decide how much more power states can have when it comes to the handling of abortion or if the woman deserves more of a say. .
Before Roe v. Wade, unborn fetuses were protected from abortion by laws that were in every state's legislature. Between 1967 and 1973 some states, starting with Colorado, had weakened these protections. Ever since the federal government handed down their decision, certain states have revised their legislation to suit their needs. In 2010, Nebraska was the state to enact the Pain-Capable Unborn Child Protection Act.