Moreover, efficient transfection of primary cells such as fibroblasts or macrophages remains a substantial obstacle.
Law-abiding aliens might wish to return to their home country, for instance, but the strained relationship caused by the difficult repatriation talks might prove to be a substantial obstacle for these aliens as well.
But the filmmakers' tendency to seek the same results with their living actors as they would with their puppets is also a substantial obstacle.
In its opinion, which Justice Kennedy joined, the court said it would permit restrictions that did not impose an "undue burden," defined in the opinion as "a state regulation that has the purpose or effect of placing a substantial obstacle in the path of a woman seeking an abortion of a nonviable fetus".
Just three days earlier, a federal district judge quite correctly rejected the provision as unconstitutional, finding that the admitting privileges rule serves no medical purpose and "places a substantial obstacle in the path of a woman seeking an abortion".
Kennedy quoted O'Connor's language from Casey, in which she defined an "undue burden" as existing when the "purpose or effect [of the regulation] is to place a substantial obstacle in the path of a woman seeking an abortion before the fetus attains viability".
As we held in Casey, an abortion regulation constitutes an undue burden if it "has the purpose or effect of placing a substantial obstacle in the path of a woman seeking an abortion of a nonviable fetus".
Third, effective dissemination is a substantial obstacle, and delivery is easily disrupted by environmental and meteorological conditions.
"Each places a substantial obstacle in the path of women seeking a previability abortion, each constitutes an undue burden on abortion access … and each violates the Federal Constitution".
In the early stages of pregnancy, the court barred only laws that are a "substantial obstacle to a woman seeking an abortion".
