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The opinion later elaborates on the undue burden standard: A finding of an undue burden is a shorthand for the conclusion that a state regulation has the purpose or effect of placing a substantial obstacle in the path of a woman seeking an abortion of a nonviable fetus.
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Cooke has noted that ‘Peter certainly had some understanding of the rituals of the criminal law, and also understood the distinction between the “passing” of a sentence of death and the “recording” of death.