Charles Adside III, Undue Schizophrenia: Split Decisions, Confused Scholars, and Reversing Unworkable Abortion Precedent, 54 Wilamette L. Rev. 219 (2018). Explained that Roe’s central holding should not be reversed. Argued, however, that the undue burden standard in Planned Parenthood v. Casey should be reversed. Examined how the undue burden standard caused schizophrenia in decision-making and an unworkable precedent. Argued that returning to the Fourteenth Amendment’s tiers of review would produce more consistent abortion precedent.