Justice Anthony Kennedy dissented. Kennedy claimed this type of law was allowed by their ruling in "Planned Parenthood v. Casey", which allowed laws to preserve prenatal life to a certain extent. He called Sandra Day O'Connor's opinion a "repudiation" of the understandings and assurances given in "Casey". Justice Kennedy also detailed what he deemed a constitutionally protected alternative to partial-birth abortion. In a short separate opinion, Chief Justice Rehnquist stated that he did not join "Casey" but felt that Justice Kennedy had applied its precedent correctly, and thus joined his opinion.