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On July 14, 2010, in Planned Parenthood of the Heartland v. Heineman, the U.S. District Court for the District of Nebraska issued a preliminary injunction halting the implementation of a bill that would have imposed on abortion providers new requirements for obtaining informed consent. The court held that the new, more rigorous informed consent requirements would have likely placed an undue burden on women seeking abortions. In doing so, the court implied that both the burden on the physician and on the patient were relevant to the undue burden analysis. This Comment argues that to determine whether a particular informed consent requirement places an undue burden on a woman’s ability to get an abortion, courts should evaluate its effect on both the woman and the doctor.