The Supreme Court of California has held that a statute prohibiting abortions not "necessary to preserve" the mother's life is so vague and uncertain as to be violative of the Fourteenth Amendment's Due Process Clause.
People v. Belous, 80 Cal. Rptr. 354, 458 P.2d 194 (1969).
Joseph C. Visalli,
Criminal Law - Abortion Statute - Due Process,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol8/iss2/11