Opinion: Even in abortion-protecting states, teens face unnecessary barriers to care

OpinionFirst Opinion Even in abortion-protecting states, teens face unnecessary barriers to care Parental involvement laws hurt more than they help Manage alerts for this article Email this article Share this article By Sunaya KrishnapuraJune 10, 2026 Krishnapura is a pediatrics resident in the Stanford Pediatrics Residency Program. On May 28 the Nevada Supreme Court made the unanimous decision of halting enforcement of the state’s abortion parental notification law, allowing teens to access abortion services without being mandated to inform their caregivers. The ruling comes in response to a case filed by a Nevada physician and Planned Parenthood against a 1985 parental notification law that had been blocked under Roe v. Wade and was first enforced beginning in July 2025. While the state Supreme Court’s decision grants only a preliminary injunction while the case proceeds through the lower courts, it marks a momentous step in addressing the current barriers to abortion access for teens even in abortion-protective states.Advertisement Four years after the landmark Dobbs decision swiftly unraveled half a century of progress and bodily protections, about two-thirds of adolescent girls in the United States are living in an area with a complete abortion ban, gestational limits, or parental involvement laws (laws requiring parental consent or parental notification for a minor to obtain an abortion). Even in states with more liberal policies, teens continue to face major obstacles to abortion access. Currently, 38 states mandate that adolescents seeking an abortion obtain parental consent, notify their parents, or do both, creating significant and disproportionate barriers to care for teens compared to adults. Parental notification laws have been largely upheld in the courts. However, the recent decision in Nevada and an ongoing suit filed in Colorado by an OB-GYN may prove to be the turning point in the fight to safeguard abortion rights, particularly in liberal states. The cases highlight an often overlooked fact: Legal protection for abortion does not mean equitable access for minors.Advertisement Following the Dobbs decision, 10 states voted to enshrine abortion rights in their state constitutions. Of note, a measure passed in Nevada in 2024 to protect abortion rights within the state constitution, but per state law, the measure must pass a second time (in November 2026) for the state constitution to be amended. Despite these legislative wins, seven of these states have parental consent and notification laws that impede access for minors. If successful, the cases in Colorado (a state that does constitutionally protect the right to abortion) and Nevada may set precedents for legal challenges in other states, prompting a broader reexamination of inequities in reproductive health care policies for adolescents. Health care providers are uniquely poised to lead these advocacy efforts. At present 41 states have restricted access to abortion. Thirteen of them have complete abortion bans and seven have imposed restrictive gestational limits (abortion bans at 18 weeks gestation or less). Additionally, as of May, 38 states had parental involvement laws in place with varying provisions regarding parental consent and notification. Twenty-one of these states require parental consent, 10 require parental notification, and seven require both. Furthermore, two states have passed abortion trafficking laws, making it illegal to help an adolescent travel for abortion care without parental consent. So far, laws limiting travel have been held up in court. While some may argue that parental involvement laws encourage family communication and thus benefit teens, this is not always the case. Traditionally, when caring for adolescents, health care providers advocate for and facilitate family-centered care as outcomes are improved when there is alignment between the parent and teen. However, in cases where disclosure can impede care, the medical community affirms the right to adolescent confidentiality. Research has shown that teens have the decision-making capacity to appreciate the risks, benefits, and alternatives to abortion to provide consent. They also tend to include their parents in this decision-making when possible.Advertisement Typically, those who chose not to disclose their pregnancies — whether because of fear of violence and familial rejection, loss of financial support, or irreversible strain on the parent-child relationship — were able to correctly forecast the parental response. Unwanted disclosure has been linked to adverse mental health outcomes, including increased symptoms of depression. Additionally, studies in Illinois and Colorado found that state parental notification requirements did not increase parental support for abortion. Instead, the requirements led to delayed access to care for minors. There are exceptions to parental involvement laws. Among the 38 states with these laws, 38 provide an exception in the case of medical emergencies, and 37 have judicial bypass procedures, which allow a court to grant approval for an abortion. However, the judicial process is long and laborious and is associated with increased stress and fear for minors. These provisions also do not guarantee that an adolescent will be granted an exception. Judicial bypass denials have even increased in some states, with Florida denying up to 13% of requests. Ultimately, these adolescents have two pathways for accessing care: 1) a life-threatening emergency or 2) single-handedly navigating a complex legal system that even adults struggle with. Suffice it to say that these exceptions are grossly inadequate. With progressively limited options in their home states, adolescents have increasingly turned to telemedicine to access care. In fact, a new study found that after the Dobbs decision in 2022, the demand for online medication abortions among adolescents increased threefold in states with parental consent and parental notification laws. Most recently, the Supreme Court’s decision on May 14 preserved national abortion pill access via telehealth, at least while a case winds its way through the courts. However, this avenue too may cease to exist as several states attempt to restrict access to abortion pills.Advertisement It is true that teen birth rates have trended downward and are at historic lows nationally. However, there is considerable variability in these rates across states and racial and ethnic groups. Birth rates for Black, Hispanic, and American Indian/Alaska Native adolescents were each more than two times higher than the rate for White adolescents. Additionally, in 2023 seven states (Alabama, Tennessee, Oklahoma, Kentucky, Louisiana, Arkansas, and Mississippi) had birth rates of 20 births per 1,000 teens or greater. Of note, complete abortion bans are in effect in each of these states. There is also concern that current abortion policies may threaten the observed decline in teen birth rates in the past few years. We need look no further than Texas as a case study and a potential forecast for the future. After Texas implemented a six-week abortion ban, the state saw its first increase in teen fertility rates in 15 years. Abortion bans threaten the significant progress that has been made nationally to reduce these rates. While several lawsuits against parental involvement laws have emerged in the wake of the Dobbs decision, these legal challenges have largely been unsuccessful. However, the lawsuit spearheaded by a Colorado physician, Rebecca Cohen, against the state’s parental notice requirements may prove to be a seminal case. In November 2024, Coloradans voted to amend the state constitution to include the right to abortion. In the case of Cohen vs. Polis, the plaintiffs state that the state’s parental notification law infringes on minors’ rights under Colorado’s Equal Rights Amendment, which ensures protections against gender discrimination. At present the defendants have filed a motion to dismiss, and a ruling from the court is now pending. Millions of adolescents live in states where they believe they have access to abortion care if they require it. They may be startled, if the time comes, to discover they have little option but to travel hundreds of miles for the mere possibility of care, resulting in limited health care options, higher-risk procedures, and worse mental health outcomes.Advertisement Teens cannot vote, but they deserve a voice. Health care providers like me have a moral obligation to lend ours. Sunaya Krishnapura is a pediatrics resident in the Stanford Pediatrics Residency Program. Letter to the editor Have an opinion on this essay? 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