A three-judge panel of the U.S. Court of Appeals for the Fifth Circuit in New Orleans on April 7, 2020, overturned Judge Yeakel's restraining order in Planned Parenthood v. Abbott to halt enforcement of the Texas governor's abortion ban issued as part of the COVID-19 crisis health mandates. The Fifth Circuit stated that Judge Yeakel failed to apply the standard of Jacobson v. Massachusetts, a 1905 case that supports judicial deference to the political branches in times of a pandemic.
