1977 Hyde Amendment barred the use of federal funds to reimburse the cost of abortions under the Medicaid program except for those necessary to save the life of the mother. Its constitutionality was upheld by the Court by a five to four vote in Harris v. McRae, 448 U.S. 297 (1980). Justice John Stevens, who President Gerald Ford appointed to succeed Douglas, dissented in Harris. In Maher v. Roe, 432 U.S. 464 (1977) by a six to three vote the Court upheld a state restriction on Medicaid funding for abortions. The principal effect of these decisions was to restrict the access of poor women to abortions. However, in a series of decisions in the late 1970s, the Court struck down as unconstitutional state laws which required inter alia: (1) spousal consent and, in the case of minor mothers, parental consent for elective abortions, Planned Parenthood of Central Missouri v. Danforth, 428 U.S. 52 (1976); (2) parental consent in Bellotti v. Baird (II), 443 U.S. 622 (1979); and in Bigelow v. Virginia, 421 U.S. 809 (1975), a state law which banned advertising of
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