[3] Gesell's finding was the first federal court decision declaring an abortion law unconstitutional.

On the first question, Justice Black, joined by Burger, Douglas, Stewart, and Byron White, held that they could.

[6] However, the decision treated abortion as a surgical option not fundamentally different from any other, and the Court seemed to care most about sufficient leeway being given to a doctor's professional judgement.

[7] The case was one of the first that the Supreme Court heard in regards to abortion restrictions in the United States.

[8] The justices voted to hear Roe v. Wade and Doe v. Bolton, other abortion cases, the day after Vuitch's opinion was announced.