Typically, courts being asked to implicate a fundamental right, like not to have something injected into your body against your will, require the state to prove that its plan is the least restrictive alternative. You don’t go from zero to 60 when it comes to rights; you first go to 10.
In other words, the state has to show not only a compelling interest, and I mean really compelling, but that its plan is the only possible way to achieve the necessary results.
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