Facially neutral health laws can burden access through costs rather than bans.

Evidence

Texas justified its law as safeguarding the health of women; but the clinics challenging the law denied that it served any health purpose and insisted that complying with it would be so expensive that many clinics would be forced to close, drastically reducing the number of sites providing abortions and unduly burdening women who were seeking them. — G. Alan Tarr, Judicial Process and Judicial…, 3066

Categorization

• SEED: Essay angle: the ‘cost barrier’ doctrine as the modern successor to outright criminal prohibition.