428 U.S. 106, 96 S. Ct. 2868, 49 L. Ed. 2d 826, 1976 U.S.
PROCEDURAL HISTORY: Appellant, Chief of the Bureau of Medical Service of Missouri, sought review of a decision of the United States Court of Appeals for the Eighth Circuit, which held that appellee physicians had standing to challenge a state statute which excluded abortions that were "not medically indicated" from the services available under Medicaid benefits to needy persons. The Chief also challenged the jurisdiction of the appellate court.
-The physicians filed a complaint in district court that challenged the state limit set on abortion funding, alleging standing based on the fact that each had provided and anticipated providing abortions to patients who were eligible for Medicaid payments.
-The district court dismissed the case for lack of standing.
-The appellate court reversed, holding that the physicians had standing and that, on the merits, Mo. Rev. Stat. § 208.152(12) violated the Equal Protection Clause.
-On appeal, the Court affirmed the physicians' standing, holding that there was adequate injury asserted for the physicians to bring a claim.
-The Court held that the physicians were qualified to litigate the constitutionality of the Chief's interference with, or discrimination against, an abortion funding decision, because there were significant obstacles that could have prevented women patients from litigating.
The Court held that the appellate court erred by determining the claim on its merits when the Chief had not presented evidence but only filed a motion for dismissal.
-Injustice was more likely to be caused than avoided by deciding the issue without the Chief's having had an opportunity to be heard.
CONCLUSION: The Court affirmed the appellate court's decision to allow the physicians to assert the rights of women patients as against the Chief's interference with abortion. The Court reversed the appellate court's determination of the issue on the merits.
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