The question
Whether individual Medicaid beneficiaries may sue state officials under 42 U.S.C. Section 1983 for a State's failure to comply with the any-qualified-provider provision of the Medicaid Act, 42 U.S.C. Section 1396a(a)(23)(A).
Medina v. Planned Parenthood South Atlantic
What the Court decided
The Court reversed. Medicaid beneficiaries cannot sue state officials under 42 U.S.C. Section 1983 to enforce the Medicaid Act's any-qualified-provider provision, 42 U.S.C. Section 1396a(a)(23)(A). The Court held that the provision does not clearly and unambiguously confer individual rights, and Section 1983 permits private enforcement only where a statute uses rights-creating terms with an unmistakable focus on individuals under a stringent and demanding test. The Court reasoned that spending-power statutes are especially unlikely to confer enforceable rights because Congress's spending authority rests on the Taxing Clause and grant conditions resemble contracts enforceable by the government rather than by private parties.
How the justices split
6-3The Court's opinion
Gorsuch, joined by Roberts, Thomas, Alito, Kavanaugh, Barrett
The any-qualified-provider provision does not clearly and unambiguously confer individual rights enforceable under Section 1983. Section 1983 permits private enforcement only where a statute uses rights-creating terms with an unmistakable focus on individuals, a stringent and demanding test. Spending-power statutes such as Medicaid are especially unlikely to confer enforceable rights because Congress's spending authority rests on the Taxing Clause and grant conditions resemble contracts, where enforcement generally belongs to the contracting government rather than to private parties.
Concurring
Thomas, writing alone
Thomas joined the opinion of the Court in full and filed a separate concurring opinion setting out his additional views.
Dissenting
Jackson, joined by Sotomayor, Kagan
Jackson dissented, arguing that the any-qualified-provider provision confers individual rights that Medicaid beneficiaries may enforce under Section 1983.
How we know · 5 sourced claims
The Court held that 42 U.S.C. Section 1396a(a)(23)(A) does not clearly and unambiguously confer individual rights enforceable under Section 1983.
Source: syllabus, Held
Statutes create individual rights enforceable under Section 1983 only where they use rights-creating terms with an unmistakable focus on individuals, a stringent and demanding test.
Source: syllabus, Held
Spending-power statutes are especially unlikely to confer enforceable rights because Congress's spending authority rests on the Taxing Clause rather than a power to regulate conduct or issue direct orders to States.
Source: syllabus, Held
Gorsuch delivered the opinion of the Court, joined by Roberts, Thomas, Alito, Kavanaugh, and Barrett.
Source: syllabus, lineup
Jackson filed a dissenting opinion, joined by Sotomayor and Kagan.
Source: syllabus, lineup