Medina v. Planned Parenthood South Atlantic
606 U.S. 357 (2025)
Rule of Law:
For a federal spending-power statute to confer individual rights enforceable under 42 U. S. C. §1983, it must clearly and unambiguously use rights-creating terms with an unmistakable focus on individuals, a demanding test rarely met in such legislation.
Facts:
- Congress created Medicaid in 1965 to subsidize state healthcare for individuals whose income and resources are insufficient to meet medical costs.
- To participate in Medicaid, states must submit a plan for medical assistance that satisfies over 80 conditions, including the any-qualified-provider provision, §1396a(a)(23)(A).
- Planned Parenthood South Atlantic (PPSAT) operates two clinics in South Carolina, offering a range of services to Medicaid and non-Medicaid patients, and also performs abortions.
- In July 2018, South Carolina determined that PPSAT could no longer participate in the State’s Medicaid program, citing a state law prohibiting public funds for abortion.
- At the same time, South Carolina took steps to ensure other providers would continue offering necessary medical care and family planning services.
- Julie Edwards, a Medicaid patient, preferred PPSAT for her gynecological care and wished to shift all her gynecological and reproductive health care there, but required Medicaid coverage for these services.
Procedural Posture:
- Planned Parenthood South Atlantic and Julie Edwards sued the director of the South Carolina Department of Health and Human Services in federal district court, alleging a violation of the Medicaid Act’s any-qualified-provider provision, enforceable under 42 U. S. C. §1983.
- The district court granted summary judgment for the plaintiffs and issued a permanent injunction preventing the State from excluding Planned Parenthood from its Medicaid program.
- The Fourth Circuit Court of Appeals affirmed the district court’s decision.
- The Supreme Court granted certiorari, vacated the Fourth Circuit’s judgment, and remanded the case for reconsideration in light of Health and Hospital Corporation of Marion Cty. v. Talevski.
- On remand, the Fourth Circuit Court of Appeals reaffirmed its earlier decision.
- South Carolina filed another petition for certiorari to the Supreme Court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does 42 U. S. C. §1396a(a)(23)(A), the Medicaid Act's any-qualified-provider provision, clearly and unambiguously confer individual rights enforceable by beneficiaries under 42 U. S. C. §1983?
Opinions:
Majority - Gorsuch
No, 42 U. S. C. §1396a(a)(23)(A) does not clearly and unambiguously confer individual rights enforceable under §1983. The Court reaffirms that statutes create individual rights enforceable under §1983 only in "atypical cases" where there is clear and unambiguous rights-creating language with an unmistakable focus on individuals. This is a "stringent" and "demanding" test. Spending-power statutes like Medicaid are especially unlikely to confer such rights due to their contractual nature, where the typical remedy for noncompliance is federal funding termination, not private suits. The Court emphasizes that the less demanding standards suggested in Wilder v. Virginia Hospital Assn., Wright v. Roanoke Redevelopment and Housing Authority, and Blessing v. Freestone have been repudiated by Gonzaga v. Doe and Health and Hospital Corporation of Marion Cty. v. Talevski. Examining §1396a(a)(23)(A), the Court finds it lacks the explicit and unmistakable rights-creating language present in the Federal Nursing Home Reform Act (FNHRA) provisions deemed enforceable in Talevski. While the provision addresses state duties and may benefit patients and providers, it does not use terms like "right to choose." Furthermore, exceptions allowing states to exclude providers (e.g., those convicted of a felony) and define qualifying convictions suggest a focus on state duties to the federal government rather than individual rights. The Medicaid Act's requirement of "substantial compliance" also points to aggregate compliance rather than individual rights. The provision's placement within a list of state plan requirements directed to the Secretary, without discernible organizational principle, further distinguishes it from statutes designed to confer individual rights. The Court rejects arguments based on legislative history, comparison to Medicare provisions (which actually include stronger rights-creating language that the Medicaid provision lacks), the dissent's proposed reinterpretation of the test, and policy arguments about the inadequacy of federal enforcement, stating that balancing enforcement costs and benefits is a policy question for Congress, not courts.
Concurring - Thomas
Justice Thomas joins the majority opinion in full, agreeing that §1396a(a)(23)(A) does not confer individual rights enforceable under §1983. He writes separately to reexamine the Court's broader §1983 jurisprudence, which he argues bears little resemblance to the statute as originally understood. He reiterates his view, expressed in his Talevski dissent, that legislation enacted under Congress's spending power cannot "secure" rights as required by §1983. Conditional spending legislation, he argues, amounts to a contractual offer whose conditions are only obligatory if freely accepted by the recipient, and thus does not directly impose federal rights. Treating such conditions as mandatory obligations, particularly for states, would contradict the constitutional prohibition against federal commandeering of states. He also questions whether the current understanding of "rights, privileges, or immunities" under §1983 is overbroad, noting a historical distinction between rights and mere government benefits that has been eroded by modern jurisprudence (e.g., Goldberg v. Kelly).
Dissenting - Jackson
Yes, 42 U. S. C. §1396a(a)(23)(A), the Medicaid Act's free-choice-of-provider provision, clearly and unambiguously confers individual rights enforceable by beneficiaries under 42 U. S. C. §1983. The dissent argues that the majority's approach distorts the unambiguous-conferral test by effectively requiring statutes to imitate the FNHRA provisions from Talevski. The text of §1396a(a)(23)(A) is plainly "individual-centric" by stating that "any individual eligible for medical assistance... may obtain such assistance from any... qualified" provider. Congress also used rights-creating language in the original session law's heading: "FREE CHOICE BY INDIVIDUALS ELIGIBLE FOR MEDICAL ASSISTANCE," words that classically invoke rights. The provision's mandatory terms further reinforce a binding obligation. Legislative history confirms this intent, showing Congress enacted it to prevent states from steering beneficiaries, modeling it on a Medicare provision that guaranteed free choice. The Court's own decision in O'Bannon v. Town Court Nursing Center described the provision as giving recipients the "right to choose." The dissent contends that numerous lower courts, prior to recent shifts, consistently recognized this right, and that the "Suter fix" explicitly overturned any suggestion that state-plan requirements cannot be enforced under §1983. The concern that upholding this right would open floodgates for other Medicaid provisions is unfounded, as only a small number have been found to confer such rights. The dissent also briefly challenges Justice Thomas's historical account of §1983's scope, suggesting alternative explanations for the paucity of early lawsuits and the evolution of the term 'rights.'
Analysis:
This decision significantly reinforces the high bar established in Gonzaga and Talevski for finding privately enforceable rights under federal spending-power statutes. By emphasizing that few statutes meet the "clear and unambiguous" rights-creating language standard, and effectively limiting lower courts to Talevski's specific examples, the Court further restricts judicial inference of individual rights. This outcome shifts the primary enforcement mechanism for many federal funding conditions away from private litigation under §1983 and more towards administrative action by federal agencies, potentially limiting beneficiaries' direct access to judicial remedies against states.
