Williams v. Zbaraz
Headline: Court allows states to withhold Medicaid funding for most abortions, upholding Illinois’s funding limits and declining to strike down the federal Hyde restrictions, affecting indigent women’s publicly funded abortion access.
Holding:
- Allows states to limit Medicaid abortion funding to Hyde Amendment exceptions.
- Means indigent women may lack publicly funded access for many medically necessary abortions.
- Vacates the District Court’s ruling striking down the Hyde Amendment for lack of jurisdiction.
Summary
Background
The case was brought by two doctors who perform abortions for low-income women, a welfare rights group, and an indigent pregnant woman who sought a medically necessary abortion. They challenged an Illinois law that bars state medical assistance payments for abortions except when a physician finds the woman’s life would be endangered. The District Court enjoined the State from denying payments for medically necessary abortions before fetal viability. The United States later intervened when the Court of Appeals directed the District Court to consider the constitutionality of the federal “Hyde Amendment,” which restricts use of federal Medicaid funds for most abortions.
Reasoning
The Supreme Court concluded the District Court lacked a proper controversy to declare the Hyde Amendment unconstitutional and vacated that part of the judgment. The Court nonetheless reviewed the remaining questions and applied its decision in Harris v. McRae, holding that Title XIX (Medicaid) does not require a State to fund medically necessary abortions for which federal reimbursement is barred by the Hyde Amendment. The Court also concluded that the Hyde Amendment does not violate equal protection principles, and for the same reasons the Illinois funding restrictions do not violate the Fourteenth Amendment. The Supreme Court therefore vacated the District Court’s judgment and sent the cases back for proceedings consistent with this opinion.
Real world impact
As the Court explained, States are not compelled by federal Medicaid law to pay for abortions beyond the Hyde exceptions, and Illinois’s funding limits are lawful under the reasoning in Harris v. McRae. The portion of the District Court’s ruling invalidating the Hyde Amendment was vacated for lack of jurisdiction, and the cases were remanded for further proceedings consistent with the Court’s conclusions.
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