The differential treatment of a minor’s decision to have an abortion and a minor’s decision to relinquish parental rights and consent to adoption is striking. Are the decisions so dissimilar as to justify this difference? Three reasons are commonly given for why minors should not be making the decision about abortion on their own: 1) health risks associated with all medical procedures, including abortion; 2) emotional fallout after abortion; and 3) the seriousness of the decision. The decision about relinquishment of parental rights and consent to adoption seem to share these characteristics with the abortion decision.
2. Emotional Health & Wellbeing
In H. L. v. Matheson,the Court justified parental notification by arguing that "[t]he . . . emotional and psychological consequences of an abortion are serious and can be lasting; this is particularly so when the patient is immature.” Some studies do, indeed, support the proposition that minors’ reactions after abortion differ from adults’ reactions. For example, younger women are more likely to feel guilt instead of relief after an abortion, and increased feelings of guilt and depression for younger women persisted 24 hours, 6 weeks, and 6 months post-abortion. Two to three months after abortion, younger women were more likely to experience shame, guilt, fear of disapproval, regret, anxiety, depression, doubt, and anger than older women. Some of those reactions from women under age 20 included more nightmares and sleep disruptions, and more suicide attempts post-abortion than women over 20 at the time of abortion. Another study, of women selected from a post-abortion support group for those experiencing difficulties, reported that adolescents were more likely to "feel forced by circumstances to have the abortion," and reported greater severity of psychological stress.
In a study specifically designed to test the Supreme Court’s premise that minors are particularly susceptible to psychological distress following abortion, researchers found differences between the reactions of minors and adults one month following abortion, but no differences two years after abortion. The study tested for depression, decision satisfaction, benefit-harm appraisals, and specific emotions related to the abortion. Additionally, the study asked respondents two years after abortion (but not one month following the abortion), if they had the decision to do over again under the same circumstances that existed two years ago, whether they would make the same decision to have the abortion.
The results of the study showed no difference between adolescents and adults on measurements of depression or specific emotions related to the abortion one month following abortion. However, the study revealed statistically significant differences between minors and adults on decision satisfaction and benefit-harm appraisal one month following abortion. At the two-month follow-up, those differences had disappeared, with no significant difference between adults and minors on any factor.
While the majority of birth parents report general satisfaction from their adoption decision, a significant portion experience long-term psychological symptoms, as well as psychological symptoms pre-relinquishment and immediately after placement. During the pre-relinquishment period, a mother experiences emotional issues in adjusting to pregnancy, as well as difficulties in making complex decisions regarding relinquishment. Mothers considering relinquishment report “conflicting feelings of shame, pride, desolation, excitement, fear, terror, and denial,” which can be overwhelming and disruptive.
In the period immediately following relinquishment, birth mothers report that relinquishment brings “a powerful sense of loss and isolation.” Birth mothers reported traumatic dreams, sleep disruption, and “a sense that the experience is surreal.” One study reported that 55% of birth mothers found signing the adoption papers to be “one of the most difficult parts of the adoption process,” and 65% of birth mothers six months after birth reported feeling grief. In comparing adolescents who chose to parent and those who chose to relinquish for adoption, those who relinquished were less comfortable with their decision than those who parented. In one study of birth mothers who returned to school after relinquishment, researchers found that the negative emotions felt by birth mothers adversely affected school performance.  The birth mothers who experienced the most deterioration in school performance were preoccupied with grief and regret concerning the adoption decision and thought recurrently about their personal loss. The majority of birth mothers expressed negative future expectations, expecting the future to be a continuation of the bleakness they currently experienced. The feelings interfered with motivation, and thus, negatively affected school performance. “The greatest deterioration in school performance was noted when birth-mothers felt there was nothing to live for.”
Birth mothers also experience long-term effects of adoption relinquishment on emotions and well-being. While some researchers report feelings of satisfaction by birth mothers four years after birth, and positive outcomes on some socio-demographic and social psychological outcomes, most also experience continuing grief and loss. Long-term effects include ongoing depression, shame and negative self-image. Birth mothers report feeling unloveable. These feelings can cause birth mothers future difficulties in attaching to romantic partners and subsequent children. Issues with future parenting include “intense attachment to and overprotection of children born to and raised by birthmothers after the placement of a child for adoption.” Birth mothers who kept the adoption relinquishment a secret feared that others would reject them if the secret were discovered. Birth mothers experienced what one researcher calls the “psychological presence” of the relinquished child, discrediting the frequently-asserted notion that birth mothers would forget about the relinquishment experience and continue on their pre-pregnancy life trajectory. Birth mothers also experience a higher rate of secondary infertility than the population at large, and many have no other children. In one study, the majority of birth mothers reported “no decrease in feelings of sadness, anger, and guilt since their relinquishment up to 30 years [before].”
 450 U.S. 398 (1981).
 450 U.S. at 411, citing Wallerstein, Kurtz, & Bar-Din, Psychosocial Sequelae of Therapeutic Abortion in Young Unmarried Women, 27 Arch. Gen. Psychiatry 828 (1972)(“The emotional and psychological effects of the pregnancy and abortion experience are markedly more severe in girls under 18 than in adults.”); Babikian & Goldman, A Study in Teen-Age Pregnancy, 128 Am. J. Psychiatry 755 (1971).
 See Wanda Franz & David Reardon, Differential Impact of Abortion on Adolescents and Adults, 27 Adolescence 161, 163 (1992) (citing Sherry L. Hatcher, Understanding Adolescent Pregnancy and Abortion, 3 Primary Care 407, 410 (1976)); Brenda Major & Catherine Cozzarelli, Psychosocial Predictors of Adjustment to Abortion, 48 Law. & Hum. Behav. 121, 137-38 (1992) (suggesting that ability to effectively cope with abortion is linked with self-efficacy which may be undermined "by younger age and correspondingly fewer resources"); Sharon D. White & Richard R. DeBlassie, Adolescent Sexual Behavior, 27 Adolescence 183 (1992) (explaining that abortion can result in medical and psychological problems, especially for the immature teenager); Anne C. Speckhard & Vincent M. Rue, Postabortion Syndrome: An Emerging Public Health Concern, 48 J. Soc. Issues 95, 97 (1992). But see R.C. Alter, Abortion Outcome as a Function of Sex-Role Identification, 8 Psych. Women Q. 211 (1984) (age not a significant predictor of post-abortion anxiety, depression or hostility); L. Cohen & S. Roth, Coping With Abortion, 10 J. Human Stress 140 (1984) (5 weeks post-abortion, no significant relationship between age and anxiety, depression, or hostility); D.T. Moseley, D.R. Follingstad, H. Harley & R.V. Heckel, Psychological Factors that Predict Reaction to Abortion, 37 J. Clinical Psych. 276 (1981)(in recovery room, no significant correlation between age and post-abortion hostility, depression, or anxiety); J.D. Osofsky & H.J. Osofsky, The Psychological Reaction of Patients to Legalized Abortion, 42 Am. J. Orthopsych. 48 (1972)(age and guilt over the abortion not statistically significantly related).
 J.D. Osofsky, H.J. Osofsky & R. Rajan, R., Psychological Effects of Abortion: With Emphasis Upon Immediate Reactions and Follow-up 188 in The abortion experience (Osofsky & Osofsky, eds. 1971).
E.C. Payne, A.R. Kravitz, M.T. Notman & J.V. Anderson, Outcome Following Therapeutic Abortion. 33 Archives of General Psychiatry 725 (1976). See also M.B. Bracken, M.Hachamovitch & G. Grossman, The Decision to Abort and Psychological Sequelae, 158 J. Nervous & Mental Disease 154 (1974).
 N.E. Adler, Emotional Responses of Women Following Therapeutic Abortion. 45 Am. J. Orthopsych. 446 (1975).
 See Nancy B. Campbell, Kathleen Franco & Stephen Jurs, Abortion in Adolescence, 23 Adolescence 813, 819 (1988).
 See Wanda Franz & David Reardon, Differential Impact of Abortion on Adolescents and Adults, 27 ADOLESCENCE 161, 163 (1992). The selection of study subjects from a group already seeking help makes the sample biased, which may make it difficult to assess how many adolescents suffer negative psychological effects from abortion and how many do not, the study does offer important information about differences between the reactions of adolescents and adults. And for comparison purposes, it is important to note that the empirical data about women who have emotional difficulties following adoption suffer from the same sampling bias. See supra, n. 179.
 See Wendy J. Quinton & Brenda Major, Adolescents and Adjustment to Abortion: Are Minors at Greater Risk?, 7 Psych. Pub. Pol. & L. 491 (2001).
 Id. at 498, asking how much six depressive symptoms bothered study participants since having the abortion.
 Id., asking “All in all, how do you feel about your decision to have an abortion?” Respondents answered on a scale of 1 (“it was definitely the wrong decision”) to 5 (“it was definitely the right decision”).
 Id. at 498-99, asking, harm-based questions one-month following the abortion, respondents to answer on a 5-point strongly-agree to strongly-disagree scale to “I feel stressed about having had this abortion;” “I think this abortion has had a negative effect on me;” and “I feel this abortion has had harmful (or bad) consequences for me.” At the two-year appraisal, the first question was replaced with: “I feel my life is worse today because I had the abortion.” Benefit questions were asked, using the same strongly-agree/strongly-disagree scale: “I think the abortion has had a positive (good) effect on me;” “I have become a stronger person because of having had the abortion;” and “I have grown as a person from the experience.”
 Id. at 499, respondents were asked about emotions specific to the abortion experience: happy, satisfied, good, pleased, contented, sorry, sad, guilty, grief, regret, feelings of loss, blue, low, angry at myself, angry at someone else, disappointed with myself, and relieved. Respondents were asked to answer on a 5-point scale from 1 (not at all) to 5 (a great deal).
 Id. at 499. Again, respondents were asked to answer on a 5-point scale from 1 (definitely no) to 5 (definitely yes.).
 Id. at 501.
 Mary O’Leary Wiley & Amanda Baden, Birth Parents in Adoption: Research, Practice, and Counseling Psychology, 33 The Counseling Psychologist 13, 15 (2005).
 Id. at 16.
 Id. See also Linda Theron & Nadine Dunn, Coping Strategies for Adolescent Birth-Mothers Who Return to School Following Adoption, 26 South Africa J. Ed. 491 (2006).
 Defined in the psychological literature as the first two years following relinquishment. Id. at 26.
 Wiley & Baden at 26, citing A. Brodzinsky, Surrendering an Infant for Adoption: The Birthmother Experience in The Psychology of Adoption (A. Brodzinsky & M. Schechter, eds. 1990).
 Wiley & Baden at 26.
 Id. at 27, citing L.F. Cushman, D. Kalmuss & P.B. Namerow, Placing an Infant for Adoption: The Experience of Young Birth Mothers, 38 Social Work 264 (1993).
 D. Kalmuss, P.B. Namerow, & U. Bauer, Short-term Consequences of Parenting Versus Adoption Among Young Unmarried Women, 54 Journal of Marriage and the Family 80 (1992).But see S.D. McLaughlin, S. Pearce, D.L. Manninen & L.D. Winges, To Parent or Relinquish: Consequences For Adolescent Mothers, 33 Social Work 320 (1988)(no significant difference in psychological outcomes for adolescents who placed and adolescents who parented).
 Theron & Dunn at 495.
 Id. at 496. See also Wiley & Baden at 26, noting that birth mothers consistently report that their hope to be able to “get on with their life” doesn’t reach fruition,” citing A. Brodzinsky, Surrendering an Infant for Adoption: The Birthmother Experience in The Psychology of Adoption (A. Brodzinsky & M. Schechter, eds. 1990) & A.D. Sorosky, A. Baran, & R. Pannor, The Effects of Sealed Record in Adoption, 133 Am. J. Psych. 900 (1976).
 Theron & Dunn at 497.
 From two years post-placement.
 Wiley & Baden note that research on the long-term effects of adoption relinquishment tend to be based on self-selecting samples or samples from birth mothers seeking treatment. Wiley & Baden at 30. Because of this sampling bias, “No data were found in either the clinical or empirical literature on birth parents that suggest that birth parents cope well with their decision to relinquish.” Id. While this sampling bias may make it difficult to assess how many birth parents suffer long-term effects and how many do not, the studies do offer important information about negative effects that birth mothers may experience long-term. And for comparison purposes, it is important to note that the empirical data about women who have emotional difficulties following abortion suffer from the same sampling bias.
 P.B. Namerow, D. Kalmuss & L.F. Cushman, The Consequences of Placing Versus Parenting Among Young Unmarried Women, 25 Marriage & Fam. Rev. 175 (1997).
 Wiley & Baden at 29; A.D. Sorosky, A. Baran & R. Pannor, Adopted Children in Clinical Child Psychology (D. Cantwell & P. Tanguay, eds. 1978).
 G.M. Burnell & M.A. Norfleet, Women Who Place Their Infants Up for Adoption: A Pilot Study, 16 Patient Counseling & Health Ed. 169 (1979); R. Winkler & M. Van Keppel, Relinquishing Mothers in Adoption: Their Long-Term Adjustment, Institute of Family Studies (Melbourne, Australia) Monograph No. 3 (1984).
 Wiley & Baden at 29.
 Id. at 29-30.
 Cinda L. Christian, Ruth G. McRoy, Harold D. Grotevant, Chalandra M. Bryant, Grief Resolution of Birthmothers in Confidential, Time-Limited Mediated, Ongoing Mediated, and Fully Disclosed Adoptions, 1 Adoption Quarterly 35, 39 (1997), citing E. Rynearson, Relinquishment and its Maternal Complications: A Preliminary Study, 139 Am. J. Psych. 338 (1982).
 Wiley & Baden at 30. Secrecy about the adoption, and the lack of opportunity to express feelings about the adoption, correlate strongly with unresolved grief, guilt and shame about the adoption placement. M. DeSimone, Birth Mother Loss: Contributing Factors to Unresolved Grief, 24 Clinical Social Work J. 65 (1996).
 D.L. Fravel, R.G. McRoy & H.D. Grotevant, Birthmother Perceptions of the Psychologically Present Adopted Child: Adoption Openness and Boundary Ambiguity, 49 Family Relations 425 (2000).
 M.J. Carr, Birthmothers and Subsequent Children: The Role of Personality Traits and Attachment History, 9 J. Soc. Distress & the Homeless 339 (2000); M. DeSimone, Birth Mother Loss: Contributing Factors to Unresolved Grief, 24 Clinical Social Work J. 65 (1996); E.Y. Deykin, L. Campbell & P. Patti, The Postadoption Experience of Surrendering Parents, 54 Am. J. Orthopsych. 271 (1984).
 Wiley & Baden at 31, citing J.T. Condon, Psychological Disability in Women Who Relinquish a Baby for Adoption, 144 Med. J. Australia 117 (1986).