Proposition 187 was a controversial California anti-immigration initiative approved by California voters on November 8, 1994. Because some of its provisions were almost certainly unconstitutional, federal injunctions prohibited its implementation; nonetheless, Proposition 187 symbolized a growing nativism in the United States at the end of the 20th century. Concern over the cost of providing social services to illegal immigrants, the increase of immigrant-related crime, and fear of a continuing flow of illegal immigrants from Mexico led Californians to approve (59 percent to 41 percent) Proposition 187, which denied education, welfare benefits, and nonemergency health care to illegal immigrants. In 1994, it was estimated that more than 40 percent of all illegal immigrants in the United States were in California. Anticipating legal challenges, proponents of Proposition 187 included language to safeguard all provisions not specifically deemed invalid by the courts. Decisions by federal judges in both 1995 and 1998, however, upheld previous decisions regarding the unconstitutionality of the proposition’s provisions, based on Fourteenth Amendment protections against discriminating against one class of people, in this case immigrants. See also Plyler v. Doe.