Doe v. Wilson

1997: Organizations filed suit seeking to enjoin the Department of Health Services (DHS) from enforcing emergency regulations issued to comply with the federal Personal Responsibility and Work Opportunity Reconciliation Act (PRA) section rendering undocumented immigrants ineligible for state or local public prenatal care benefits. PRA prohibited states, after August 22, 1996, from expending public funds to furnish undocumented persons with routine prenatal health services as California had theretofore done, unless new state legislation to the contrary was thereafter enacted. California did not enact any such new legislation. Congress asserted that PRA furthered a compelling public interest by removing incentive for “pregnant illegal aliens” to enter the country to receive prenatal benefits. The Court of Appeal held that DHS did not abuse its discretion in finding that an emergency existed and justified the enactment of emergency regulations to comply with federal law, where the PRA provision became effective immediately on passage and terminated state-funded public benefits for routine prenatal care for undocumented immigrants.