Medina v. Planned Parenthood South Atlantic
606 U. S. ____ (2025) (2025)
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Rule of Law:
For a provision in a statute enacted under Congress's Spending Power to confer a privately enforceable right under 42 U.S.C. § 1983, the statute must contain clear and unambiguous rights-creating language. Language that merely directs a state to provide a benefit to individuals is insufficient.
Facts:
- Planned Parenthood South Atlantic (PPSAT) operates two clinics in South Carolina, providing a wide range of medical services, including abortions, to both Medicaid and non-Medicaid patients.
- Julie Edwards, a Medicaid beneficiary with diabetes which complicated her healthcare needs, preferred to receive her gynecological and reproductive health care from PPSAT due to positive past experiences.
- In July 2018, the Governor of South Carolina issued an executive order based on a state law prohibiting the use of public funds for abortions.
- Pursuant to this order, the state's health department determined that PPSAT was no longer qualified to participate in the state's Medicaid program.
- This termination would prevent Edwards and other Medicaid patients from using their government-funded insurance to obtain any services at PPSAT clinics.
Procedural Posture:
- Planned Parenthood South Atlantic and patient Julie Edwards filed a § 1983 class-action lawsuit against the Director of South Carolina's Department of Health and Human Services in the U.S. District Court for the District of South Carolina.
- The district court granted summary judgment for the plaintiffs and issued a permanent injunction preventing the state from terminating PPSAT's participation in Medicaid.
- South Carolina (appellant) appealed to the U.S. Court of Appeals for the Fourth Circuit, which affirmed the district court's decision.
- The state petitioned for a writ of certiorari, which the U.S. Supreme Court granted. The Court vacated the Fourth Circuit's judgment and remanded for reconsideration in light of Health and Hospital Corp. v. Talevski.
- On remand, the Fourth Circuit again affirmed the district court's injunction in favor of the plaintiffs (appellees).
- South Carolina again petitioned for a writ of certiorari, which the U.S. Supreme Court granted.
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Issue:
Does Section 1396a(a)(23)(A) of the Medicaid Act, the 'any-qualified-provider' provision, unambiguously confer an individual right on Medicaid beneficiaries to choose their healthcare provider that is enforceable under 42 U.S.C. § 1983?
Opinions:
Majority - Gorsuch, J.
No. Section 1396a(a)(23)(A) of the Medicaid Act does not unambiguously confer individual rights enforceable under § 1983. To create such a right, a Spending Clause statute must use clear and unambiguous 'rights-creating language,' not merely confer a benefit. The provision at issue, which states that a plan must 'provide that... any individual... may obtain' care, describes a state's duty to the federal government rather than bestowing a right upon an individual. This language stands in stark contrast to the provisions in Health and Hospital Corp. v. Talevski, which explicitly used the word 'right.' The statutory context, including the fact that this is one of 87 plan requirements and that states must only achieve 'substantial compliance' with the Act, indicates a focus on aggregate state performance, not individual entitlements. Policy arguments about the need for private enforcement cannot overcome the lack of clear statutory text required to put states on notice that accepting federal funds means consenting to private lawsuits.
Concurring - Thomas, J.
No. I join the majority's opinion in full, but write separately to advocate for a fundamental reexamination of the Court's § 1983 jurisprudence, which has expanded far beyond the statute's original meaning. It is questionable whether Spending Clause legislation can ever 'secure' rights within the meaning of § 1983, as this would amount to an unconstitutional commandeering of state governments. Furthermore, the modern, expansive understanding of 'rights' to include government benefits is inconsistent with the term's meaning when § 1983 was enacted during Reconstruction.
Dissenting - Jackson, J.
Yes. The Medicaid Act's free-choice-of-provider provision unambiguously confers an enforceable right upon Medicaid beneficiaries. The majority adopts a narrow and ahistorical reading of § 1983 that undermines the statute's civil rights purpose. The provision satisfies the Gonzaga test because its text is individual-centric ('any individual... may obtain'), it uses mandatory language ('must... provide'), and its original session law heading ('FREE CHOICE BY INDIVIDUALS') is classic rights-creating language. The majority wrongly treats the statute in Talevski as the only permissible model for creating a right, ignoring Congress's ability to use other clear language. South Carolina had ample notice of potential § 1983 liability from longstanding government positions, prior case law, and Congress's own statutory clarifications, making the Court's notice concerns unfounded.
Analysis:
This decision significantly raises the bar for plaintiffs seeking to enforce conditions of Spending Clause statutes through § 1983 litigation. By solidifying the demanding Gonzaga standard and explicitly warning against reliance on older, more lenient precedents like Wilder, the Court has made it clear that only explicit 'rights-creating' terminology will suffice. This ruling effectively shifts the primary enforcement mechanism for many federal grant conditions away from private lawsuits and toward federal administrative action, such as withholding funds, a remedy the government is often reluctant to employ. The decision will likely foreclose private enforcement of numerous provisions in Medicaid and other federal-state programs that lack the specific 'magic words' the Court now seems to require.
