In a notable rebuke—albeit a restrained one—the 1st Circuit Court of Appeals on Friday vacated preliminary injunctions that had blocked enforcement of a federal law cutting off Medicaid funding to certain abortion providers, including Planned Parenthood. The decision is especially striking given that the three-judge panel was composed entirely of judges appointed by President Joe Biden.

The injunctions had been issued in July by U.S. District Judge Indira Talwani of Massachusetts, who barred enforcement of Section 71113 of the “One Big Beautiful Bill,” a statute duly passed by Congress and signed into law by President Trump. That provision withholds Medicaid funding from abortion providers that continue to offer abortion services.

At the time, Talwani’s ruling raised serious separation-of-powers concerns, as it effectively prevented Congress from exercising its constitutional authority over federal spending. The appeals court made clear that such judicial intervention went too far.

In a detailed 41-page opinion, the 1st Circuit concluded that the plaintiff organizations—including Planned Parenthood affiliates—were unlikely to succeed on the merits of their claims. Specifically, the court rejected arguments that the law:

• Constituted a bill of attainder

• Violated the First Amendment

• Ran afoul of the Equal Protection Clause

On the bill of attainder claim, the panel emphasized that Congress did not impose punishment, but rather set conditions on the receipt of federal funds:

“That the law imposes a difficult choice on the recipient of federal funds does not demonstrate that Congress is punishing the recipient for past action.”

The court noted that Planned Parenthood and similar entities remain free to continue providing abortions—they simply cannot do so while also receiving Medicaid funds.

Regarding equal protection, the panel applied rational basis review and found Congress had plausible reasons for targeting large recipients of Medicaid funding in pursuit of its stated goal of reducing abortions. The court stressed judicial restraint, quoting Supreme Court precedent that courts should not override policy decisions simply because they may be controversial or politically charged.

While the ruling does not resolve the case on the merits, it removes the immediate barrier preventing enforcement of the law. The plaintiffs may still seek en banc review or appeal to the Supreme Court, but the decision represents a significant win for both the Trump administration and Congress.

More broadly, it stands as a reminder that courts are not meant to substitute their policy preferences for those of the legislative branch—particularly when Congress is acting squarely within its constitutional power of the purse.