by Linda Kate Gilbreath*
Since Carey v. Population Services International,1 minors under the age of sixteen have had constitutional protections for their access to contraceptives. Protections for adults’ access to contraception remain without question after Dobbs v. Jackson Women’s Health Organization,2 which explicitly limited its holding to the removal of abortion rights. On its face, Carey seems to have predicated minors’ right to access contraception on their then-existing right to access abortion services as part of their authority to make decisions to bear or beget a child. This Contribution argues that minors’ access to contraception is still protected. If we view “bear or beget” as a bundle of sticks, Dobbs took away the abortion stick. It did not take away the whole bundle—even for minors. Furthermore, states requiring that minors either meet strict categories of eligibility or get parental consent to access contraceptives impermissibly infringe on minors’ constitutional right to access contraception and would not pass strict scrutiny.