This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The case concerns the New Mexico Human Services Department's rule restricting state Medicaid funding for abortions to cases of rape, incest, or when necessary to save the mother's life. Plaintiffs, including medical providers and advocacy organizations, challenged the rule, arguing it discriminates against women by denying funding for medically necessary abortions that do not meet these criteria (paras 1, 6-7).
Procedural History
- District Court, July 3, 1995: The court permanently enjoined the enforcement of the revised rule, finding it violated the Equal Rights Amendment of the New Mexico Constitution (paras 8-9).
- Court of Appeals, October 13, 1995: Certified the appeal to the Supreme Court of New Mexico due to the significant constitutional question involved (para 9).
Parties' Submissions
- Plaintiffs: Argued that the rule violates the Equal Rights Amendment by applying a discriminatory standard of medical necessity to women and infringes on a woman's right to reproductive choice under the New Mexico Constitution (paras 1, 3, 8).
- Defendant (Department): Contended the rule was a cost-saving measure and aligned with federal restrictions under the Hyde Amendment. It also argued that the rule did not discriminate because it addressed a physical condition unique to women (paras 1, 48-49).
- Intervenors (Klecan and Schaurete): Claimed the rule was necessary to protect the potential life of the unborn and argued that the plaintiffs lacked standing (paras 8, 23).
Legal Issues
- Does the rule restricting Medicaid funding for medically necessary abortions violate the Equal Rights Amendment of the New Mexico Constitution? (paras 2-3, 26-27)
- Do the plaintiffs have standing to challenge the rule? (paras 11-14)
- Did the district court exceed its authority by enjoining the enforcement of the rule? (paras 55-59)
Disposition
- The Supreme Court of New Mexico affirmed the district court's decision, holding that the rule violated the Equal Rights Amendment and permanently enjoining its enforcement (para 61).
- The court reversed the district court's decision allowing the intervenors to participate as of right (para 61).
Reasons
Per Minzner J. (Franchini C.J., Baca J., McKinnon J., and Armijo J. concurring):
Standing: The plaintiffs, including medical providers and advocacy organizations, had standing to challenge the rule because they demonstrated a direct interest and a close relationship with Medicaid-eligible women, who faced significant barriers to asserting their own rights (paras 11-14).
Equal Rights Amendment: The court found that the rule discriminated against women by applying a stricter standard of medical necessity to abortions than to other medical procedures. This violated the Equal Rights Amendment, which requires heightened scrutiny of gender-based classifications. The court rejected the Department's argument that the rule was justified by cost-saving measures or the State's interest in potential life, finding no compelling justification for the discriminatory treatment (paras 26-54).
Separation of Powers: The court held that the district court did not exceed its authority by enjoining the rule. The order required the Department to comply with constitutional guarantees while using funds already appropriated by the Legislature, which did not violate the separation of powers (paras 55-60).
Intervention: The court reversed the district court's decision allowing the intervenors to participate, finding their interests as taxpayers and protectors of potential life were either too indirect or adequately represented by the Department (paras 15-22).