Connecticut limited Medicaid
benefits for abortions to those that were considered medically necessary.
Roe wanted an abortion and
wanted Medicaid to pay for it. She sued, claiming that the Connecticut
law was an unconstitutional violation of the Equal Protection Clause of the 14th Amendment
because it denied the guaranteed right to an abortion to indigent women.
In Roe v. Wade (410 U.S. 113 (1973)). it was established
that there is a fundamental right to an abortion based on
the right to privacy.
Totally different 'Roe' in
The US Supreme Court found the
Connecticut law to be constitutional.
The US Supreme Court found
that 'financial need' did not create a suspect class, so the proper level of review was rational
The Court found that the law
was rationally related to a
legitimate State interest.
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."
government may not place obstacles in the path of a woman's exercise of
her freedom of choice, it need not remove those not of its own
This case basically said that
just because you have a constitutional right to something, it doesn't mean
that the State has an obligation to pay for it.
"The Constitution does
not provide judicial remedies for every social and economic ill."
But compare to Gideon v.
Wainwright (372 U.S. 335 (1963)),
which found that an indigent person did have the right to
legal counsel in criminal trials, even if they couldn't pay for it.
Of course, the difference
is that the 6th Amendment explicitly states that, "in all criminal prosecutions, the
accused shall enjoy the right... to have the Assistance of Counsel for