State, Department of Health & Social Services v. Planned Parenthood of Alaska, Inc.

28 P.3d 904, 2001 Alas. LEXIS 97, 2001 WL 856197
CourtAlaska Supreme Court
DecidedJuly 27, 2001
DocketS-9109
StatusPublished
Cited by64 cases

This text of 28 P.3d 904 (State, Department of Health & Social Services v. Planned Parenthood of Alaska, Inc.) is published on Counsel Stack Legal Research, covering Alaska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State, Department of Health & Social Services v. Planned Parenthood of Alaska, Inc., 28 P.3d 904, 2001 Alas. LEXIS 97, 2001 WL 856197 (Ala. 2001).

Opinion

OPINION

FABE, Chief Justice.

I. INTRODUCTION

Alaska's Medicaid program funds virtually all necessary medical services for poor Alaskans-'"regardless of race, age, national origin, or economic standing" 1 -but it denies funding for medically necessary abortions. Alone among Medicaid-eligible Alaskans, women whose health is endangered by pregnancy are denied health care based solely on political disapproval of the medically necessary procedure. This selective denial of medical benefits violates Alaska's constitutional guarantee of equal protection. Our conclusion is supported by the majority of jurisdictions that have considered comparable restrictions on state funding of medically necessary abortions: these state courts have concluded that, under their state constitutions, government health care programs that fund other medically necessary procedures may not deny assistance to eligible women whose health depends on obtaining abortions. 2

This case concerns the State's denial of public assistance to eligible women whose health is in danger, It does not concern State payment for elective abortions; nor *906 does it concern philosophical questions about abortion which we, as a court of law, cannot aspire to answer. We join the California Supreme Court in clarifying that "this case does not turn on the morality or immorality of abortion, and most decidedly does not concern the personal views of the individual justices as to the wisdom of the legislation itself or the ethical considerations involved in a woman's individual decision whether or not to bear a child." 3 Indeed, as the California Supreme Court emphasized, "similar constitutional issues would arise if the Legislature ... funded [Medicaid] abortions but refused to provide comparable medical care for poor women who choose childbirth." 4 The constitutional issue in this case therefore "does not involve a weighing of the value of abortion as against childbirth, but instead concerns the protection of either procreative choice from discriminatory governmental treatment." 5 As the California court recognized, the issue presented is "not whether the state is generally obligated to subsidize the exercise of constitutional rights for those who cannot otherwise afford to do so." 6 Rather, the issue is whether the State, having enacted a benefits program, may discriminate between recipients in the manner attempted by the Department of Health and Social Services (DHSS) today. We hold that it may not. Onee the State undertakes to fund medically necessary services for poor Alaskans, it may not selectively exclude from that program women who medically require abortions.

Although the State argues that courts may not enjoin unconstitutional use of the legislative appropriations power, this proposition is unsupported by case law from any jurisdiction. The legislature's spending power does not create license to disregard citizens' constitutional rights. In rejecting this part of the State's argument, we concur with every state and federal court that has considered this issue.

II. FACTS AND PROCEEDINGS

Alaska provides medical services for poor Alaskans primarily through the Medicaid program. 7 Medicaid is a comprehensive health care program designed to provide medical assistance for all eligible poor per *907 sons in the state. 8 But a DHSS regulation, 7 Alaska Administrative Code (AAC) 48.140, imposes a limit on the state's health care funding: It denies Medicaid assistance for medically necessary abortions unless a pregnant woman is at risk of dying or her pregnancy resulted from rape or incest 9 Because DHSS offers no other funding source for abortions, 7 AAC 48.140 ensures that a woman who medically requires an abortion will receive no assistance from the state.

The range of women whose access to medical care is restricted by the regulation is broad. According to medical evidence provided to the superior court, some women-particularly those who suffer from pre-exist-ing health problems-face significant risks if they cannot obtain abortions. Women with diabetes risk kidney failure, blindness, and preeclampsia or eclampsia-conditions characterized by simultaneous convulsions and comas-when their disease is complicated by pregnancy. Women with renal disease may lose a kidney and face a lifetime of dialysis if they cannot obtain an abortion. And pregnancy in women with sickle cell anemia can accelerate the disease, leading to pneumonia, kidney infections, congestive heart failure, and pulmonary conditions such as embolus. Poor women who suffer from conditions such as epilepsy or bipolar disorder face a particularly brutal dilemma as a result of DHSS's regulation-medication needed by the women to control their own seizures or other symptoms can be highly dangerous to a developing fetus. Without funding for medically necessary abortions, pregnant women with these conditions must choose either to seriously endanger their own health by forgoing medication, or to ensure their own safety but endanger the developing fetus by continuing medication. Finally, without state funding, Medicaid-eligible women may reach an advanced stage of pregnancy before they can gather enough money for an abortion; resulting late-term abortions pose far greater health risks than earlier procedures.

In June 1998 the plaintiffs-two medical doctors and Planned Parenthood of Alaska-filed a complaint against DHSS. They sought to enjoin enforcement of 7 AAC 48.140 and also sought a judgment declaring that the State's denial of funding for medically necessary abortions violates Alaska's Constitution. Superior Court Judge Sen K. Tan granted summary judgment in favor of Planned Parenthood. Based on this court's holding that "reproductive rights are fundamental [and] include the right to an abortion," 10 the superior court concluded that 7 AAC 48.140 impermissibly interferes with Medicaid-eligible women's constitutional rights to privacy. Because the State failed to articulate a compelling state interest for this interference, the superior court permanently enjoined DHSS from enforcing the regulation "so as to deny coverage for medically necessary abortions." The State now appeals. 11

*908 III. STANDARD OF REVIEW

We review a grant of summary judgment de novo, exercising our independent judgment to "determine whether the parties genuinely dispute any material facts and, if not, whether the undisputed facts entitle the moving party to judgment as a matter of law." 12 On questions of constitutional law, we also apply our independent judgment. 13

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Bluebook (online)
28 P.3d 904, 2001 Alas. LEXIS 97, 2001 WL 856197, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-department-of-health-social-services-v-planned-parenthood-of-alaska-2001.