Williams v. Planned Parenthood Shasta-Diablo, Inc.

Background

A group of anti-abortion protesters challenged a California court order that limits their protest activity to a public sidewalk separated from a clinic by a busy four-lane avenue. The clinic (represented in the record by its escort coordinator) obtained an injunction after the trial court found the protesters caused “increased stress and anxiety” to patients and staff. The State supreme court originally approved the restriction, the U.S. Supreme Court vacated that approval and sent the case back for reconsideration, and the California court again upheld the injunction on remand.

Reasoning

The core question is whether the state could lawfully ban protesters from the public sidewalk outside the clinic to prevent emotional upset or to ensure access. Justice Scalia’s dissent (joined by two colleagues) says the record does not show protesters physically blocked entrances or engaged in violent conduct; testimony indicated no one was prevented from entering, no manhandling, and few arrests. Scalia argues the California court relied on a newly asserted “access” interest that lacks factual support and conflicts with prior U.S. decisions limiting bans on approaching clinic patrons.

Real world impact

Because the Supreme Court denied review, the California injunction remains in effect for now, continuing to keep protesters across the avenue and away from the clinic entrances. The dissent warns this allows significant limits on protesters’ speech near clinics despite sparse evidence of physical obstruction. The denial leaves in place a state-level balance between protecting clinic patients’ emotional safety and protesters’ speech rights.

Dissents or concurrances

Justice Scalia would have granted review, reversed the California judgment, and sent the case back for further proceedings, emphasizing the weak factual record supporting the broad restriction.