Singleton v. Wulff

Supreme Court of United States
428 U.S. 106 (1976)

ELI5:

Rule of Law:

A physician who suffers a direct financial injury from a state law restricting abortion funding has Article III standing to challenge that law. Such a physician may also assert the constitutional rights of their patients due to the confidential nature of the doctor-patient relationship and the obstacles patients face in asserting their own rights.

Facts:

Missouri participated in the federal Medicaid program to provide medical assistance to needy persons.
A Missouri statute, § 208.152(12), specified that state Medicaid funds could not be used for abortions unless they were 'medically indicated'.
Dr. Wulff and Dr. Freiman, two Missouri-licensed physicians, provided abortions to welfare patients who were eligible for Medicaid.
The physicians performed abortions that were not 'medically indicated'.
The responsible state official, Singleton, acting under the authority of the Missouri statute, refused all Medicaid applications filed in connection with these non-medically indicated abortions.
The physicians stated that this refusal of payment deterred them from practicing medicine as they saw fit and chilled the doctor-patient relationship.

Procedural Posture:

Two Missouri physicians sued state official Singleton in the U.S. District Court for the Eastern District of Missouri, challenging the constitutionality of a state Medicaid statute.
A three-judge panel was convened in the District Court to hear the case.
The defendant, Singleton, filed a pre-answer motion to dismiss the complaint on several grounds, including that the physicians lacked standing.
The District Court granted the motion to dismiss for lack of standing.
The physicians, as appellants, appealed the dismissal to the U.S. Court of Appeals for the Eighth Circuit.
The Court of Appeals reversed, holding that the physicians did have standing, and then proceeded to decide the merits of the case, declaring the Missouri statute unconstitutional.
The state official, Singleton, as petitioner, sought and was granted a writ of certiorari by the U.S. Supreme Court.

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Issue:

Do physicians who are denied Medicaid reimbursement for performing non-medically indicated abortions have standing to challenge the constitutionality of the state statute by asserting the rights of their patients?

Opinions:

Majority - Justice Blackmun

Yes. A physician who is denied state reimbursement for performing abortions has standing to challenge the law and may also assert the rights of their patients. First, the physicians clearly allege an 'injury in fact' because the statute causes them a direct financial loss, creating a constitutional case or controversy. Second, as a prudential matter, the physicians can assert the rights of their patients (jus tertii). This exception to the general rule against third-party standing is justified by two factors: 1) the physician-patient relationship is confidential and the patient’s right to an abortion is 'inextricably bound up' with the physician's actions, and 2) women face 'genuine obstacles' to asserting their own rights, such as a desire for privacy and the risk of their claim becoming moot as the pregnancy progresses. However, the Court of Appeals erred by deciding the merits of the case without a lower court record, as the defendant never had the opportunity to file an answer or present evidence.

Concurring - Justice Stevens

Agreed with the judgment that the physicians have standing. Because the physicians have a direct financial stake in the outcome and claim the statute impairs their own constitutional rights to practice medicine, they clearly have standing to bring the action. It is therefore unnecessary to reach the more complex question of whether they can also assert the constitutional rights of their patients.

Concurring - Justice Powell

Agreed that physicians have their own Article III standing due to financial injury and that the case must be remanded, but dissented from allowing them to assert their patients' rights. Third-party standing should only be permitted when litigation by the rightholder is 'in all practicable terms impossible,' which is not the case here, as women can and do sue using pseudonyms and the 'capable of repetition, yet evading review' doctrine prevents mootness. Previous cases allowing physician standing involved direct state interference, like criminalization, not merely a refusal to provide public funding.

Analysis:

This case is significant for expanding the doctrine of third-party (jus tertii) standing, particularly for physicians in the abortion context. The plurality's two-part framework—considering the closeness of the relationship and the obstacles to the third party's own assertion of rights—became an influential test for standing in subsequent cases. The decision ensures that restrictive abortion funding laws can be effectively challenged in court by physicians, who have a direct financial incentive and are often better positioned to litigate than their patients. However, the fractured opinions demonstrate the Court's ongoing division over how broadly to apply exceptions to the prudential rule against third-party standing.

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