The U.S. Supreme Court’s June decision invalidating Texas abortion restrictions could make it harder for states to justify voting restrictions, Stanford Law School’s Pamela Karlan said while speaking at the American Bar Association’s annual meeting earlier this month.

The court’s test for examining abortion rights is doctrinally similar to the test used for voting rights, Karlan told Bloomberg BNA in an interview.

Therefore, the court’s clarification of abortion’s “undue burden” standard could have ramifications for cases challenging recent voting restrictions, like voter identification laws, she said.

It’s a subtle shift, but it means courts will probably be more skeptical of voter ID laws, Karlan said.

Until the 1980s, the Supreme Court analyzed voting and abortion restrictions under “standard-style strict scrutiny,” Karlan said.

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But the court began subjecting some voting and abortion regulations to a lower standard of review during William Rehnquist’s tenure as Chief Justice, between 1986 and 2005, Karlan said.

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The tests applicable to voting and abortion restrictions are very similar, Karlan said.

So the court’s recent clarification of the “undue burden” analysis in a challenge to Texas abortion restrictions provides some guidance for voting rights disputes too, she said.