In the case of Carey, State's Attorney of Cook County, Illinois v. Wynn et al., 1978, the U.S Supreme Court addressed whether a state law that allowed for involuntary commitment and treatment of narcotics addicts violated due process rights under the Fourteenth Amendment. The plaintiffs argued that they were denied their right to procedural due process because they were not given notice or an opportunity to be heard before being committed. They also claimed that their substantive due process rights were violated as there was no compelling state interest in treating them against their will. The court held that while individuals have a significant liberty interest in avoiding forced confinement and treatment, this must be balanced against the state's legitimate interests in public health and safety. It found that Illinois' scheme provided sufficient procedural safeguards including judicial review prior to commitment and periodic reevaluations during treatment. Furthermore, it ruled on substantive grounds stating addiction is a serious health problem with substantial social consequences which justifies intervention by states even if it involves compulsory measures. Therefore, it concluded neither procedural nor substantive constitutional violations occurred through involuntary commitment and treatment under Illinois’ Narcotic Addiction Act.

In the dissenting opinion for Carey v. Wynn, Justice William Rehnquist disagreed with the majority's view that Illinois' restriction on abortion funding violated the Equal Protection Clause of the Fourteenth Amendment. He argued that there was no constitutional right to government-funded abortions and emphasized a state's legitimate interest in protecting potential human life. Furthermore, he contended that it is not discriminatory for a state to choose to fund childbirth over abortion because both options are not medically necessary procedures but rather personal choices made by pregnant women. Therefore, according to him, states should have discretion in deciding which medical services they want to subsidize without being subjected to strict scrutiny under equal protection analysis.