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Keywords

plaintifflitigationstatuteinjunctionliens
plaintifflitigationstatuteinjunctionappealliens

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Lewis v. Thompson

Facts

The injunction at issue was imposed in 1987, in litigation that began in 1979. The Secretary of the Department of Health and Human Services had denied Medicaid coverage for prenatal care to illegal alien pregnant women, asserting that such coverage was not required under the Welfare Reform Act of 1996. The plaintiffs challenged this denial, arguing it violated their rights and the rights of their U.S. citizen children.

The injunction at issue was imposed in 1987, in litigation that began in 1979. As we recognized on the prior appeal in this litigation, Lewis v. Grinker, 965 F.2d 1206 (2d Cir. 1992) ('Lewis V'), the prenatal care provisions of the Medicaid statute are among the most complex in a statute that is one of the 'most intricate ever drafted by Congress.'

Issue

Whether the Welfare Reform Act prohibited most female illegal aliens from receiving Medicaid-sponsored prenatal care, and if so, whether that restriction is unconstitutional with respect to either the alien mothers or their United States citizen children.

The principal issues on this appeal are whether Congress, in enacting in 1996 what is usually called the Welfare Reform Act ('the Act'), prohibited most female illegal (technically 'unqualified') aliens from receiving Medicaid-sponsored prenatal care, and, if so, whether that restriction is unconstitutional with respect to either the alien mothers or their United States citizen children.

Rule

The court ruled that the denial of prenatal care to unqualified aliens was unconstitutional under the reasoning in Plyler v. Doe, which established that children should not be denied benefits based on their parents' immigration status.

The Court ruled that the Act should be read to deny prenatal care to unqualified aliens, but that this denial is unconstitutional under the Supreme Court's reasoning in Plyler v. Doe, 457 U.S. 202, 223-24, 72 L. Ed. 2d 786, 102 S. Ct. 2382 (1982).

Analysis

The court applied the heightened scrutiny standard to the case, determining that the denial of prenatal care to citizen children of alien mothers was discriminatory and violated the Equal Protection Clause. The court found that the statute should be interpreted to provide automatic eligibility for Medicaid benefits to citizen children of unqualified alien mothers upon their birth.

Although we agree with the Court's interpretation of the Act, we conclude that the denial of prenatal care is not unconstitutional. However, we also conclude, in agreement with the District Court, that citizen children of alien mothers are entitled to automatic eligibility for Medicaid benefits for a year after birth equivalent to the automatic eligibility extended to the citizen children of citizen mothers.

Conclusion

The order was reversed to the extent that it continued the injunction requiring the Secretary to provide prenatal Medicaid assistance to plaintiffs. The order was affirmed to the extent that it required automatic eligibility for Medicaid coverage to the citizen children of plaintiffs upon their birth.

We therefore reverse the District Court's order holding the statute unconstitutional as applied to prenatal care, and remand to the Court to modify the injunction so that it requires the Secretary only to enable the citizen children of unqualified alien mothers to obtain automatic Medicaid eligibility on the same basis as the citizen children of citizen mothers.

Who won?

The plaintiffs prevailed in part, as the court ruled that the Secretary must provide automatic eligibility for Medicaid benefits to the citizen children of alien mothers, recognizing the discriminatory nature of the previous denial.

The plaintiffs prevailed in part, as the court ruled that the Secretary must provide automatic eligibility for Medicaid benefits to the citizen children of alien mothers, recognizing the discriminatory nature of the previous denial.

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