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First Circuit upholds Trump's Planned Parenthood funding cut

Lorna Morales,
 December 15, 2025

Victory for pro-life policy reverberated through the courts on Dec. 12, as the First Circuit delivered a decisive blow to Planned Parenthood's attempt to preserve federal funding.

On Friday, a three-judge panel overturned a lower court's block on a key provision in President Donald Trump's "Big, Beautiful Bill," signed into law on July 4, finding the Medicaid funding cut to abortion providers likely constitutional, as Courthouse News Service reports.

Let's rewind to the beginning. This summer, President Trump signed the aforementioned bill into law, a measure that included a provision stripping Medicaid funding for one year from abortion providers receiving over $800,000 in such funds in fiscal year 2023.

Targeting Major Abortion Providers Specifically

This provision also extends to affiliated entities, effectively targeting Planned Parenthood providers almost exclusively. Only two other unrelated organizations meet the defunding criteria, underscoring the law’s precision in addressing major players in the abortion industry.

Shortly after the bill’s passage, Planned Parenthood Federation of America, along with two affiliates, challenged the legislation. They argued it unfairly singled them out, but the law’s focus on high-volume recipients suggests a deliberate strategy to curb abortion access through fiscal policy.

Federal law already bans using federal funds for abortions, yet Planned Parenthood relies on Medicaid for services like birth control and cancer screenings. The organization’s claim of collateral damage to non-abortion care raises questions about prioritizing one controversial service over broader fiscal responsibility.

Court Battles Heat Up Quickly

U.S. District Judge Indira Talwani, an Obama appointee in Massachusetts, initially issued a preliminary injunction blocking the funding cut. She argued the law might be an unconstitutional bill of attainder and infringe on First Amendment and equal protection rights.

However, the First Circuit panel had stayed Talwani’s injunction in September pending appeal. Comprising Judges Gustavo Gelpí, Seth Aframe, and Lara Montecalvo -- all Biden appointees -- the panel’s eventual ruling on Friday was a surprising win for conservative values.

Their decision overturned Talwani’s block, asserting Planned Parenthood is unlikely to succeed in proving the law unconstitutional. The panel reasoned that the measure doesn’t punish but uses Congress’s taxing and spending power to impose a tough but fair choice on fund recipients.

Judicial Logic Supports Policy Goals

Judge Gelpí articulated this balance with clarity. “It instead uses Congress’s taxing and spending power to put appellees to a difficult choice: give up federal Medicaid funds and continue to provide abortion services or continue receiving such funds by abandoning the provision of abortion services,” he wrote.

That logic cuts to the core of conservative principles: government shouldn’t bankroll entities tied to practices many Americans find morally objectionable. If Planned Parenthood values abortion provision over federal support, that’s a choice, not a punishment—an elegant checkmate to their victimhood narrative.

The panel also dismissed claims of First Amendment violations, suggesting further fact-finding on whether non-abortion affiliates truly fall under the law’s “common control” definition. On equal protection, they found the law rationally tied to reducing abortions, a legitimate federal goal.

Planned Parenthood Faces Harsh Realities

A November report from Planned Parenthood revealed that 20 health centers have closed since the bill’s passage. While this is framed as a crisis, it also signals that taxpayers are no longer indirectly subsidizing an abortion giant’s sprawling network.

In a separate challenge, 22 states and Washington, D.C., secured another injunction from Talwani blocking defunding in their jurisdictions. This patchwork resistance shows the left’s desperation to prop up Planned Parenthood despite clear federal intent.

The U.S. Department of Health and Human Services, overseeing Medicaid, offered no immediate comment on the ruling. As the dust settles, this First Circuit decision stands as a testament to the enduring fight for life, even against judicial and political headwinds.

About Lorna Morales

Lorna is a staff writer for Conservative Legal News. She covers the legal battles shaping America, from the Supreme Court to state courts and brings a conservative perspective while breaking down complex cases in plain English.

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