Whalen v. Roe case brief

Whalen v. Roe case brief summary

429 U.S. 589 (1977)

CASE SYNOPSIS

Appellant health commissioner sought review of a judgment from the United States District Court for the Southern District of New York that held that the New York State Controlled Substances Act of 1972, N.Y. Pub. Health Law § 3300 et seq. (1976), which required that records be kept of all prescriptions for controlled substances with a potential for abuse, was unconstitutional.

CASE FACTS
The New York State Controlled Substances Act of 1972, N.Y. Pub. Health Law § 3300 et seq.(1976) scheduled all controlled substances and required a centralized filing system of all prescriptions written for controlled substances that had potential for abuse.

DISCUSSION

• The Court reversed a judgment that held that the state could not record in a centralized computer file, the names and addresses of all persons who obtained, pursuant to a doctor's prescription, the drugs for which there was both a lawful and an unlawful market. 
• The Court agreed that there was a constitutionally protected zone of privacy that included the interest in avoiding disclosure of personal matters and the interest in independence in making important personal decisions. 
• The Court held the law adequately protected privacy when it limited access to the lists and built in protection from disclosures. 
• The Court also held that there was not sufficient evidence to establish that the law had affected any decisionmaking abilities. 
• Finding that the law was the product of an orderly and rational legislative decision, the Court reversed the judgment and upheld the law.

CONCLUSION

The Court reversed the judgment and held that the law did not violate privacy rights because it established adequate measures to protect individual privacy and that there was no evidence that the law had affected any patient's decision to obtain a prescription.