A new study shows teens in states with parental involvement laws are increasingly seeking abortion pills online to avoid judges, delays and unsafe alternatives.
(Sergei Gapon / AFP via Getty Images)
The majority of U.S. teenagers live in states that require parental involvement in abortion healthcare decision-making. If parents are unavailable, or teens under 18 do not want to involve their parents, they must go to court and convince a judge that they are mature enough to decide on their own or that the abortion is in their best interest. To avoid this invasive and burdensome process, resourceful teens are now turning to abortion care from telehealth providers located outside their restrictive states, as documented by new research published in the Journal of the American Medical Association.
This first of its kind study examined request rates made to one online medication abortion telemedicine service between Sep. 1, 2021, and Oct. 31, 2023. Researchers compared the volume of requests before and after the Supreme Court’s Dobbs decision on June 22, 2022, which overturned the constitutional right to abortion.
During the study period, the service received 13,716 requests from 15- to 17-year-old adolescents across all 50 states and D.C.
Request rates rose sharply after Dobbs, especially in states with the most restrictive laws. During both periods, teens in states with parental consent and notification laws had higher request rates than states without those laws, and the gap widened significantly post-Dobbs.
The study’s lead author Dr. Dana M. Johnson, a postdoctoral fellow at the University of Wisconsin-Madison School of Medicine and Public Health, summed up her results: “The weekly rate of request was higher for minors living in states that had parental involvement laws compared to the minors living in states that didn’t have parental involvement laws.”
The research also found that young adults aged 18 to 24 years old increasingly turned to telehealth abortion after Dobbs.
“This is evidence that young people are going online for abortion when they need it. This is a really popular abortion care option for young adults and teenagers,” said Johnson, noting that many young people “grew up in the pandemic” visiting doctors via telehealth. “We know that there was a lot of Tiktok and Instagram content about where to get an abortion online shortly after the Dobbs decision. There were so many creators who were very galvanized by the Dobbs decision and were rapidly sharing information about these resources.”
Parental involvement is not medically necessary. There’s no medical reason for teens to have to navigate an additional barrier to care. It’s just cruel.
Dr. Dana M. Johnson
Johnson said the telemedicine service provided teens additional support beyond what they typically offered adults. From qualitative research, Johnson said that many teens are also supported by people in their lives, including siblings, parents and friends.
Johnson stressed that teens are fully mature and capable enough to consent to abortion. “We have a lot of research that, developmentally, teens are fully capable of consenting to their own abortion care. And we also have a lot of research on the harms of parental involvement laws on the social and emotional well-being of teens who need abortion care,” said Johnson, noting that requiring teens to navigate judicial bypass procedures through the courts delays access to medical care, pushing abortion later in pregnancy—a harder and more expensive experience.
Johnson emphasized that teens may be unable to involve a parent for reasons that often reflect real world barriers. “Some of them are, ‘my mom cannot get off work.’ Or ‘I can’t tell my parents because there’s a physical safety issue,’” said Johnson. “Parental involvement is not medically necessary. There’s no medical reason for teens to have to navigate an additional barrier to care. It’s just cruel.”
Parental Involvement Laws and Their Deadly Consequences
Just one year after Roe v. Wade, Massachusetts became the first state to require minors to obtain parental consent for abortion. A lawsuit blocked the law from taking effect until the Supreme Court ruled in 1979 that states could require parental consent or notification, so long as they provided a judicial bypass process. Under that process, minors can obtain court permission for an abortion without parental involvement if they are deemed mature enough to make the decision themselves or if the abortion is found to be in their best interest.
… Some judges impose their own religious and political views on young women during these judicial bypass hearings, at times requiring antiabortion counseling from evangelical Christian ministries or appointing attorneys to represent the embryo or fetus.
Under the Reagan administration, parental involvement laws proliferated as an attempt to restrict minors’ access to reproductive healthcare.
One of the most well-known, devastating consequences of these laws was the 1988 death of Becky Bell in Indiana. When Bell became pregnant as a teenager, Indiana had a parental consent law. Bell was afraid to tell her parents about the pregnancy for fear of disappointing them, but she was also afraid to go before a local judge she heard was reluctant to grant waivers. Believing she had no other option, she turned to an unsafe, likely self-induced abortion. Several days later, Bell was rushed to the hospital with a massive infection and died. Her death became a poignant symbol of the lethal effects of restricting young people’s access to safe abortion.
Bell’s story is, unfortunately, not unique. Across the country, parental consent and notification laws continue to endanger young people by forcing some teens into secrecy, court procedures or in some cases, preventing them from accessing abortion at all .
In a recent 2025 Human Rights Watch report, clinic staff reported one young person who was so frightened by parental notification that she continued the pregnancy against her wishes. “We scheduled her for an appointment and hoped she could come, and we could walk her through the process [of parental notification or judicial bypass],” but the young person never made it to the appointment. “We lost contact with her.”
Today, 38 states require parental involvement in a minor’s decision to have an abortion:
- Twenty-one states require parental consent.
- Ten require parental notification and seven require both.
- Out of those 38 states, 12 have total bans, while 26 still allow abortion at some point during pregnancy.
Parental involvement laws place a heavy burden on young people by delaying access to care, cause tremendous stress and create additional barriers to access.
Parental involvement laws do not significantly increase the likelihood that minors will consult with their parents about their abortion decision, additional research published in Obstetrics & Gynecology shows. One study found that 77 percent of minors in a state requiring parental involvement consulted with their parents about their abortion decision, a rate similar to that in states that did not require parental consent. Most of the time, minors use a judicial bypass process when their parents are unavailable—they are medically incapacitated, incarcerated, out of the country or otherwise unavailable. Often in these cases, young people have already communicated with their parents about their decision.
On the other hand, the research revealed that the judicial bypass requirement causes significant delays for minors seeking access to abortion care. These delays raise the cost of abortion care, which imposes an increased burden on young people with the least access to financial resources. And while abortion is an extremely safe procedure, delays can push care later into pregnancy and increase the risk of complications.
According to the lead author of the study, Harvard professor Dr. Elizabeth Janiak, these laws fall hardest on the most marginalized and vulnerable young people, disproportionately young people of color and and those with low incomes.
Janiak also warned about the dangers of requiring parental involvement for young people living in abusive households. Disclosing pregnancy can trigger physical or emotional abuse, including direct physical or sexual violence, or being thrown out of the home. In these situations, medical providers, not judges, are the best equipped to help young people navigate their options.
Judges have neither the training nor the time to counsel young abuse survivors, reports the research. The judicial bypass requirement does not provide patients with any information that they are not already receiving from their health care provider. According to a Human Rights Watch report “Whose Abortion Is It?,” foster kids and incarcerated teens are especially vulnerable, as they often lack a stable or supportive parent or guardian to consult.
Even for teens who decide to pursue a judicial bypass, the experience is often described as “invasive, stressful and often traumatizing,” forcing them to justify their decision before a judge who may hold personal or religious biases. Research shows that some judges impose their own religious and political views on young women during these judicial bypass hearings, at times requiring antiabortion counseling from evangelical Christian ministries or appointing attorneys to represent the embryo or fetus. Becky Bell was one of the many teens discouraged by these barriers—an outcome that ultimately proved fatal.
In response to research documenting mounting evidence of harm, some states are rolling back their parental involvement laws. In 2020, Massachusetts became the first state to remove the parental consent requirement for 16 and 17-year-olds seeking abortion care. In a state long categorized as “overwhelmingly Catholic,” this repeal marked a groundbreaking step in upholding the separation of church and state, while also protecting minors’ bodily autonomy.
Illinois soon followed in 2022, repealing its Parental Notice of Abortion Act after nearly a decade of enforcement. In August 2024, the Montana Supreme Court struck down its parental involvement law. On the other hand, Nevada recently began enforcing its parental involvement law. Amid this uneven landscape, many parental involvement laws still continue to burden young women across the country.
Today, resourceful teens are finding safe and confidential pathways to abortion care without having to navigate oppressive parental involvement laws.
After Dobbs, eight states enacted provider shield laws that allow clinicians within their borders to serve patients located in other states—including those with bans and restrictions. These clinicians are governed by the laws in which they are located.
Four of those states—New York, California, Vermont and Washington—do not have parental involvement laws, allowing teens in states with those laws to obtain telehealth abortion safely without involving their parents or a judge.
Teens also have the options of obtaining abortion for free through international telehealth abortion provider Women on Web or from community providers, which they can learn about through the website Plan C. These providers are mailing abortion pills across the United States, and will continue to do so no matter what the FDA or Republican states do to restrict abortion.
For young people who face abortion barriers such as transportation, cost, hostile family environments or privacy concerns, abortion pills by mail offers a safer, more discreet pathway to essential healthcare, protecting them from the fate of Becky Bell.
While an increasing number of teens are discovering this option, Dana Johnson warns this is not enough: “Teens need all options for abortion care. Telehealth is one, but it can’t be the only one,” said Johnson. “Parental involvement laws need to be revisited. They are abortion bans. … They keep teens from accessing necessary care. They should be abolished.”
