In an opinion that clashes with 41 years of precedent, the U.S. Court of Appeals for the Fifth Circuit held that Title X of the Public Health Service Act, as administered, violates a parent's right under Texas law to be notified before contraceptives are given to a child.

Legal council for a group of anti-abortion nonprofit organizations, responding on background, said the effect of the opinion cannot be predicted because the decision is unclear. This was a reference to a partial reversal from the court that leaves in place Title X language that shields the staff of Title X grantees from notifying a parent or guardian.