In Planned Parenthood of Se. Pa. v. Casey, 505 U.S. 833, 112 S. Ct. 2791, 120 L. Ed. 2d 674 (1992), the Supreme Court overruled previous decisions applying strict scrutiny to laws regulating abortion rights, acknowledging that those decisions "undervalued the State's interest in the potential life within the woman," id. at 875, and were inconsistent with the Court's "jurisprudence relating to all liberties" which "recognized that not every law that makes a right more difficult to exercise is, ipso facto, an infringement of that right," id. at 873. Instead, the court held that a statute that affects abortion rights is not unconstitutional if "it serves a valid purpose, one not designed to strike at the right itself," and does not "impose an undue burden on a woman's ability" to exercise her rights. Id. at 874. In Casey, Justices O'Connor, Kennedy and Souter applied the "undue burden" test, 505 U.S. at 874; Chief Justice Rehnquist and Justices White, Scalia and Thomas would have applied rational basis review, 505 U.S. at 966 (concurring in part and dissenting in part); and Justices Stevens, 505 U.S. at 917 (concurring in part and dissenting in part), and Blackmun, 505 U.S. at 923 (concurring in part and dissenting in part), would have applied strict scrutiny. Casey therefore holds that the "undue burden" standard applies, because "when a fragmented Court decides a case and no single rationale explaining the result enjoys the assent of five Justices, the holding of the Court may be viewed as that position taken by those Members who concurred in the judgments on the narrowest grounds." In other words, "Casey thus requires courts to determine whether a large fraction of the women 'for whom the law is a restriction' will be 'deterred from procuring an abortion as surely as if the government has outlawed abortion in all cases.