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Lewis v. Grinker
No. 00-6104 (2d. Cir. July 27,2001) ; Clearinghouse Number: 42159
Description
Second Circuit Reverses Order Requiring HHS to Provide Medicaid Coverage for Prenatal Care to Illegal Aliens
Abstract
Reversing the district court’s order requiring the U.S.
Department of Health and Human Services (HHS) to provide Medicaid
coverage for prenatal care to illegal aliens, the Second Circuit
held that provisions of the Personal Responsibility and Work
Opportunity Act of 1996 prohibiting most female illegal aliens from
receiving Medicaid-sponsored prenatal care were not
unconstitutional. Plaintiffs brought this action in 1979 to
challenge the denial of Medicaid benefits to undocumented aliens
not permanently residing in the United States under color of law.
In 1991 the district court permanently enjoined defendant HHS
secretary from denying prenatal care to unqualified aliens. After
enactment of the 1996 welfare law, defendant asked the district
court to reconsider its injunction. Refusing, the district court
held that the denial of Medicaid-sponsored prenatal care to
unqualified aliens was an unconstitutional violation of
plaintiffs’ equal protection rights under the Fifth
Amendment. The court of appeals however, held that deterrence of
illegal immigration as the rationale for the denial of prenatal
care to unqualified aliens sufficed for rational basis review.
Although the record disclosed no evidence that prospective illegal
immigrants considered the unavailability of prenatal care in
deliberating whether to enter the country illegally, the court
found it reasonable for Congress to suppose that the denial of care
would deter some of them. The court affirmed, however, the district
court’s order entitling citizen children of alien mothers to
automatic eligibility—equivalent to that for the citizen
children of citizen mothers—for Medicaid benefits for a year
after birth.
Additional Information
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