Law School Case Brief
Harris v. McRae - 448 U.S. 297, 100 S. Ct. 2671 (1980)
Where a statutory classification does not itself impinge on a right or liberty protected by the U.S. Constitution, the validity of classification must be sustained unless the classification rests on grounds wholly irrelevant to the achievement of any legitimate governmental objective. This presumption of constitutional validity, however, disappears if a statutory classification is predicated on criteria that are, in a constitutional sense, "suspect," the principal example of which is a classification based on race.
After initial proceedings and intervention had occurred in an action brought against federal officials in the United States District Court for the Eastern District of New York with respect to the first version of the so-called "Hyde Amendment" whereby the United States Congress, through appropriations legislation (90 Stat 1418; 91 Stat 1153, 1323, 1460; 92 Stat 1567; 93 Stat 656, 923) has limited the types of medically necessary abortions for which federal funds may be spent under the Medicaid program of the Social Security Act (42 USCS 1396 et seq.)--the first version of the "Hyde Amendment" being the most restrictive version in that it made federal funds unavailable for abortions "except where the life of the mother would be endangered if the fetus were carried to term" (90 Stat 1434)--the plaintiffs, led by Cora McRae, included indigent pregnant women who sued on behalf of other women similarly situated, two officers of the "Women's Division of a Methodist Church organization, the "Women's Division" itself as an organization, individual physicians performing abortions for Medicaid recipients, and a public benefit corporation operating hospitals which provide abortion services, and the claims they asserted raised challenges on various grounds, including claims arising under the First and Fifth Amendments, to subsequent versions of the Hyde Amendment. Rejecting the plaintiffs' contention that it was unnecessary to address the constitutionality of the Hyde Amendment because, as the plaintiffs asserted, a state participating in the Medicaid program was obligated under the provisions of the Social Security Act governing the Medicaid program to fund all medically necessary abortions, even if federal reimbursement was unavailable, the District Court ruled that the Hyde Amendment, although valid under the First Amendment's establishment of religion clause, violated the First Amendment's free exercise clause and the equal protection component of the Fifth Amendment's due process clause.
Did the Hyde Amendment to the Medicaid Act, Title XIX of the Social Security Act violate the Due Process Clause under the Fifth Amendment or the Religion Clauses under the First Amendment by denying funding for medically necessary abortions?
The Court reversed, holding that Title XIX did not require a participating state to pay for medically necessary abortions for which federal reimbursement was unavailable under the Hyde Amendment. The Court held that the funding restrictions of the Hyde Amendment did not violate U.S. Const. amends. I, V. McRae et al. lacked standing to raise a challenge to the Hyde Amendment under the Free Exercise Clause of U.S. Const. amend. I. The Due Process Clause did not confer an entitlement to funds in order to obtain an abortion or any other protected right. The fact that the funding restrictions coincided with the religious tenets of the Roman Catholic Church did not, without more, contravene the Establishment Clause.
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