Constitutional Law
Planned Parenthood of Greater Ohio v. Hodges, 917 F.3d 908 (6th Cir. 2019)
Study notes for Planned Parenthood of Greater Ohio v. Hodges: professor notes, cold call prep, exam angles, and memory aids.
States have the authority to regulate public health funding without imposing an undue burden on constitutional rights.
This case centers on the balance of state funding discretion and reproductive rights under the Fourteenth Amendment. The Sixth Circuit emphasizes the state's right to determine eligibility for public health funds, arguing that it aligns with public policy interests even when it affects reproductive health providers like Planned Parenthood. Professors may focus on how the court distinguished between the right to access abortion and funding for related health services, questioning the limits of government control over health care provisions.
Funding Freedom: State's Right to Decide.
| Case | Distinction |
|---|---|
| Whole Woman's Health v. Hellerstedt | This case involves the regulations surrounding abortion clinics which imposed an undue burden, whereas Hodges addresses state funding decisions not directly limiting abortion access. |
| Planned Parenthood of Greater Ohio v. Hodges (District Court) | The District Court granted an injunction against the law, viewing it as an undue burden, while the Sixth Circuit reversed, reaffirming state rights over funding. |
| NIFLA v. Becerra | NIFLA dealt with compelled speech regarding abortion information, whereas Hodges focuses on state funding policies. |
Allowing states to determine funding allocations supports broader public health goals and prioritizes resources toward providers that do not perform non-therapeutic abortions.
Eliminating funding for entities like Planned Parenthood may restrict access to essential health services, particularly affecting low-income patients who rely on these providers for comprehensive care.
This case may appear on exams in discussions concerning the scope of the government's discretion in funding health services and the application of the undue burden standard established in Planned Parenthood v. Casey.