The adoption of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (hereinafter “PRWORA”) led to considerable litigation over immigrants’ rights to welfare benefits and access to health care. The approaches adopted by different courts (both federal and state) diverged significantly based on the various statutory schemes involved as well as distinct approaches to equal protection. However, no “on point” cases have reached the United States Supreme Court, so the “correct” approach remains unclear. Following the fiscal crisis of 2008, several states moved for increased exclusion of certain immigrants residing in the country legally from state healthcare or welfare schemes. Decisions regarding such increased exclusion are currently under challenge in both the federal and state courts, including Connecticut, Hawai’i, Maine, Massachusetts, New Jersey, and Washington. Such challenges are now in front of the Courts of Appeals in both the First and Ninth Circuits. In the past, courts have come to very different conclusions as to the issues involved. On the one hand, the Massachusetts Supreme Judicial Court has held that strict scrutiny applies to the exclusion of immigrants from a state healthcare scheme (with federal funding) and that the law under challenge did not satisfy that requirement. On the other, the Connecticut Supreme Court has held that a decision to abolish a state health care scheme for immigrants not entitled under the state-federal Medicaid scheme did not involve any discrimination, because no comparable citizen was being provided with state benefits. This Article discusses recent cases and analyzes potential resolutions of such issues consistent with equal protection law. Part I outlines the legal context, including the relevant Supreme Court case law and the provisions of PRWORA. Part II briefly outlines the facts and outcomes of four of the most significant cases, which highlights the differing approaches adopted by the courts. Part III sets out an analytical approach to the issues; and Part IV summarizes the findings and conclusions set forth in this Article.