The case of Beltran v. Myers, Director, California State Department of Health et al., 1980 revolved around the issue of whether or not a state can deny Medicaid benefits for medically necessary abortions when it pays for all other medical expenses incurred by indigent pregnant women. The Supreme Court held that states participating in the Medicaid program are not required to fund elective abortions as part of their plan under Title XIX (Medicaid) and may limit funding to those procedures that are "medically necessary". However, they must provide clear standards defining what constitutes a "medically necessary" abortion. This decision upheld California's Medi-Cal regulations which limited public funding for abortions to cases where the procedure was deemed medically necessary by a physician.

In the dissenting opinion for Beltran v. Myers, it was argued that California's policy of denying prenatal care to undocumented immigrant women violated the Equal Protection Clause of the Fourteenth Amendment. The dissenting justices believed that this policy created a class-based distinction without sufficient justification and thus should be subjected to strict scrutiny review. They contended that providing prenatal care is in public interest as it ensures healthier babies and reduces future healthcare costs, regardless of their mothers' immigration status. Furthermore, they noted that children born in the U.S., even if their parents are undocumented immigrants, are American citizens under the Constitution; hence denying them access to adequate health services during gestation could negatively impact their well-being after birth which contradicts with principles of equal protection under law.