This thesis examines the effects of the change from strict scrutiny to the undue burden standard in Planned Parenthood v. Casey (1992). A history of abortion in the United States and the various ways in which government regulates it is explored. Particular attention is focused on the role of the federal judiciary in abortion regulation. Theories of judicial decision making are discussed as means to understand the outcome of cases. Several models are tested to determine which, if any, model explains judicial decision making. The effect of the change in standard, as well as an alternate precedent, are examined.