Planned Parenthood of Southeastern Pennsylvania et al. v. Casey, Governor of Pennsylvania, et al. 1992 overturned the strict trimester formula, and emphasized the right to abortion as grounded in the general sense of liberty protected under the Due Process Clause of the Fifth Amendment to the United States Constitution, rather than a generalized right to privacy. Advancements in medical technology, expected to continue, meant that a fetus might be considered viable, and thus have some basis of a right to life, at 22 or 23 weeks rather than at the 28 that was more common at the time Roe was decided. For this reason, the old trimester formula was ruled obsolete, with a new focus on viability of the fetus.
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