other abortion regulation) can legally make it more difficult for a female to acquire an abortion. But there is a threshold beyond which the increased difficulties become unconstitutional. Requiring spousal involvement before a woman can acquire an abortion has been interpreted as falling on the unconstitutional side of that threshold, while parental involvement has been interpreted as falling on the constitutional side. Or, to use the language of Planned Parenthood of Southeastern Pennsylvania v. Casey (1992), spousal notification laws place an "undue burden" on a woman's ability to get an abortion, whereas parental involvement laws do not. Parental involvement laws have three basic features. First, they are binding on minors, not adults. Second, they require, at minimum, that minors notify their parents before an abortion is performed, and in some cases consent from the parents. And third, they allow minors to acquire a judicial bypass if consent cannot be acquired. These regulations are but one example of the detailed fabric of abortion legislation and regulation that has evolved since the Supreme Court's decision to legalize abortion in its 1973 Roe v. Wade and Doe v. Bolton. The first major case involving parental involvement legislation was decided in 1976 in Planned Parenthood of Central Missouri v. Danforth. This case involved a Missouri law that required consent from various parties before an abortion could be performed– written consent by the patient, spousal consent for married individuals, and parental consent for minors, specifically. The court ruled that the parental consent provision was unconstitutional due to its universal enforcement. The ability of a minor to acquire an abortion against her parents' wishes became a recurring theme in several more cases following Planned Parenthood of Central Missouri v. Danforth. Bellotti v. Baird (1979) addressed a Massachusetts law that required a minor to acquire parental consent before an abortion was performed. But, unlike the Danforth case, this law allowed for judicial bypass if consent could not be acquired. Similar reasoning can be found in H.L. v. Matheson (1981). This case ruled on the relatively milder regulation of parental notification as opposed to parental consent. In this case, the Court ruled that parental notification is constitutional since the parent could not veto the adolescent's final decision to acquire an abortion. In Planned Parenthood of Kansas City v. Ashcroft (1983), the Supreme Court ruled that parental consent is constitutional so long as it also allowed a judicial bypass