Undue burden standard
More recently, the standard has been used in cases involving state restrictions on a woman's access to abortion. The standard was applied by Associate Justice Sandra Day O'Connor in her dissent in City of Akron v. Akron Center for Reproductive Health, 462 US 416 (1983). O'Connor used the test as an alternative to the strict scrutiny test applied in Roe v. Wade, 410 U.S. 113 (1973).