Chief Justice John Roberts’s controlling opinion in the recent Louisiana abortion case June Medical has been widely viewed as a setback for opponents of abortion as a constitutional right. But in fact, it paves the way for increased recognition of the validity of restrictions, such as counseling requirements and waiting periods, with its stated approval of cases that upheld them.

The majority opinion effectively repudiates the standard, but not the holding, of the recent Texas case in which Roberts had dissented. It also makes clear that the vitality of the court’s “undue burden” test for abortion restrictions was not at issue in the case