The decision resulted from the government defendants’ motion to vacate a permanent injunction the court had issued in the class action case nearly nine years earlier.  Concluding that provisions in the Medicaid statute then in effect limiting coverage for undocumented immigrants should not be construed to apply to the provision of prenatal care, the court enjoined the government from denying such coverage to them absent clear evidence of Congress’s intent to do so.  With the passage of the PRWORA, the government argued that because the statute’s plain language and its legislative history clearly demonstrate congressional intent to deny undocumented immigrants public benefits (including nonemergency Medicaid), the injunction must be vacated.

The district court agreed with the defendants that PRWORA section 401(a), which renders most undocumented immigrants ineligible for a broad array of public benefits (including nonemergency Medicaid–funded prenatal care), expresses the congressional intent whose absence precipitated the injunction.  However, instead of granting the government’s motion to vacate, the court also agreed with the equal protection claims raised by the plaintiffs on behalf of their U.S. citizen children.

This case, unlike previous constitutional challenges brought against the PRWORA by immigrant plaintiffs, warranted heightened scrutiny of the provision at issue, the court found.  Because applying section 401(a) to deny nonemergency prenatal care to undocumented women would have the further effect of denying to their U.S. citizen children automatic eligibility for Medicaid (citizen children of similarly situated, otherwise qualified citizen mothers are considered automatically eligible for Medicaid), the court held that this disparate treatment of U.S. citizens based on a condition over which they had no control—i.e., the immigration status of their mothers—must be "substantially related to a legitimate congressional objective."

Balanced against the costs to society that denying prenatal care would impose, as well as the potentially lifelong impact such a denial would have on individual children’s well-being, the court found that the defendants’ dual rationale—discouraging illegal immigration and encouraging immigrant self-sufficiency—failed to satisfy heightened scrutiny’s requirement that the government’s action further "some substantial goal."  Accordingly, the court denied the defendants’ motion to vacate its permanent injunction.