Today, the U.S. Supreme Court, in a 6-3 decision, ruled that the Medicaid Act’s any-qualified-provider provision does not confer individual rights enforceable under 42 U.S.C. §1983. This decision reverses the Fourth Circuit’s judgment, which affirmed the right of Medicaid beneficiaries to sue state officials for excluding Planned Parenthood from South Carolina’s Medicaid program.
Background
Medicaid, established in 1965, provides federal funds to states to subsidize healthcare for individuals with insufficient income and resources. States must comply with various conditions to receive these funds, including the any-qualified-provider provision, which mandates that Medicaid beneficiaries can obtain services from any qualified provider. In 2018, South Carolina excluded Planned Parenthood from its Medicaid program, citing state law against public funding for abortion. Planned Parenthood and patient Julie Edwards sued, claiming this exclusion violated the any-qualified-provider provision.
The district court granted summary judgment in favor of Planned Parenthood and Julie Edwards, enjoining South Carolina from excluding Planned Parenthood from its Medicaid program. The court found that the exclusion violated the any-qualified-provider provision, which it held conferred enforceable rights under §1983. The Fourth Circuit affirmed the district court’s decision, emphasizing the provision’s clear intent to benefit Medicaid recipients by allowing them to choose their healthcare providers. The Supreme Court then granted certiorari.
Question Presented
Does the any-qualified-provider provision of the Medicaid Act confer individual rights enforceable under §1983, allowing Medicaid beneficiaries to sue state officials for non-compliance?
Holding
The Supreme Court found that § 1983 provides causes of action for deprivation of “‘rights,’ not mere ‘benefits’ or ‘interests'” and “to prove an enforceable right, plaintiffs must show the statute ‘clear[ly] and unambiguous[ly]’ uses ‘rights-creating terms’ with ‘an unmistakable focus’ on individuals.” Using this framework, the Supreme Court held that the any-qualified-provider provision does not clearly and unambiguously confer individual rights enforceable under §1983. The court emphasized that spending-power statutes like Medicaid typically do not create enforceable rights, as they are contractual agreements between federal and state governments.
Specifically, Justice Gorsuch, writing for the majority, stated: “Section 1396a(a)(23)(A) lacks the required clear rights-creating language” … “Spending-power statutes are especially unlikely to confer enforceable rights. Unlike Commerce Clause or other regulatory powers, Congress’s spending authority rests on the ‘Taxing Clause’ (Art. I, §8, cl. 1), which does not expressly authorize regulating conduct or issuing direct orders to States.”
Dissent
Justice Jackson, joined by Justices Sotomayor and Kagan, dissented, arguing that the free-choice-of-provider provision should be enforceable under §1983. The dissent criticized the majority for adopting a narrow interpretation that undermines the statute’s purpose and the rights of Medicaid recipients.
Congress enacted the Medicaid Act’s free-choice-of-provider provision to ensure that Medicaid recipients have the right to choose their own doctors. The Court’s decision to foreclose Medicaid recipients from using §1983 to enforce that provision thwarts Congress’s will twice over: once, in dulling the tool Congress created for enforcing all federal rights, and again in vitiating one of those rights altogether.