if such consent could not be acquired. In Planned Parenthood of S.E. Pennsylvania v. Casey (1992), the Court placed parental involvement firmly within a broader set of legal principles governing a woman's constitutional right to an abortion. Parental involvement, and other regulations, were constitutional so long that they did not place an "undue burden" on a woman's ability to acquire an abortion. In Planned Parenthood of Massachusetts v. Attorney General (1997), the Supreme Judicial Court of Massachusetts found the requirement of both parents consenting to the minor's abortion unconstitutional, but upheld the parental consent of one parent. In 2020, the law was modified to apply only to minors under 16 years of age. In November 2011, the Illinois Supreme Court agreed to consider whether the state must begin enforcing a 1995 law requiring parental notification. The Court ultimately agreed in July 2013 that the law ought to be enforced, with the parental notification law taking effect on August 15. However the parental notification law was repealed by the Illinois General Assembly in 2021, and parental involvement is no longer required. In American Academy of Pediatrics v. Lungren (1997) 16 Cal.4th 307 the Supreme Court of California struck down the 1987 parental consent law of the state (which had been enjoined shortly after enactment, and thus never enforced). This case also made history because it was one of the few cases in the legal history of California where its Supreme Court granted a rehearing of a legal case, after it had previously ruled in American Academy of Pediatrics v. Lungren (1996) 51 Cal.Rptr.2d 201 that the law was constitutional. Debate Arguments in support Advocacy groups have made a number of arguments in favor of parental notification. Minors must have parental approval for most types of medical procedures. A study by the Heritage Foundation stated that overall, parental involvement laws reduce the number of teenage abortions. The pregnant minor might be pressured into having an abortion by an older boyfriend or abusive partner, so as to conceal the fact that he is guilty of rape or statutory rape. Currently, the parents of the minor are financially responsible for any complications resulting from the abortion, unless said minor has been legally emancipated. Arguments in opposition Advocacy groups on the other side have also made a number of arguments against parental notification: Parental notification and consent laws increase the number of unsafe, illegal abortions.