Facts of the Case

In the wake of Roe v. Wade, the Connecticut Welfare Department issued regulations limiting state Medicaid benefits for first-trimester abortions to those that were "medically necessary." An indigent woman ("Susan Roe") challenged the regulations and sued Edward Maher, the Commissioner of Social Services in Connecticut.

Question

Did the Connecticut law violate the Equal Protection Clause of the Fourteenth Amendment?

Conclusion

In a 6-to-3 decision, the Court held that the Connecticut law placed no obstacles in the pregnant woman's path to an abortion, and that it did not "impinge upon the fundamental right recognized in Roe." The Court noted that there was a distinction between direct state interference with a protected activity and "state encouragement of alternative activity consonant with legislative policy." Holding that financial need alone did not identify a suspect class under the Equal Protection Clause, the Court found that the law was "rationally related" to a legitimate state interest and survived scrutiny under the Fourteenth Amendment.