Supreme Court Decides Medina v. Planned Parenthood South Atlantic

On June 26, 2025, the Supreme Court of the United States decided Medina v. Planned Parenthood South Atlantic, No. 23-1275, holding that individual Medicaid beneficiaries may not sue state officials for failing to comply with the Medicaid funding condition in 42 U.S.C. § 1396a(a)(23)(A) — the any-qualified-provider provision — because it does not clearly and unambiguously confer an individual right that may be enforced by private individuals through Section 1983.

Medicaid’s any-qualified-provider provision requires that states ensure that “any individual eligible for medical assistance … may obtain such assistance from any [provider] qualified to perform the service … who undertakes to provide it.” 42 U.S.C. § 1396a(a)(23)(A). Medicaid also provides that, if a state fails “to comply substantially” with this or another condition set out by Congress, the Secretary of Health and Human Services may withhold some or all of the state’s federal funding. Section 1983 is a cause of action that allows private individuals to sue state actors who violate their “rights” under “the Constitution or laws” of the United States, 28 U.S.C. § 1983, but not all federal statutes provide “rights” that may be enforced by private individuals through Section 1983.

This case arose in 2018, when South Carolina announced that Planned Parenthood could no longer participate in the state’s Medicaid program. Planned Parenthood and one of its patients sued the director of South Carolina’s Department of Health and Human Services under Section 1983, arguing that the state’s exclusion of Planned Parenthood from its Medicaid program violated the any-qualified-provider provision. The district court granted summary judgment to the plaintiffs, and the Fourth Circuit affirmed. Following the Supreme Court’s decision in Health and Hospital Corporation v. Talevski, the Court granted South Carolina’s petition for certiorari, vacated the Fourth Circuit’s decision, and remanded for further proceedings. On remand, the Fourth Circuit reaffirmed its earlier decision.

The Supreme Court granted review to decide whether individual Medicaid beneficiaries may sue state officials for failing to comply with the funding condition set out in the any-qualified-provider provision, 42 U.S.C. § 1396a(a)(23)(A). The Court held that they may not.

The Court explained that Congress enacted Medicaid pursuant to its spending power, through which Congress can offer funds to states in exchange for the states’ agreement to follow certain conditions. The “typical remedy” for a violation of those conditions is an action by the federal government to terminate the funding to the state. Private enforcement through Section 1983 is permitted only where the provision clearly and unambiguously confers an individual right. The Court further clarified that, when determining whether a spending-power statute creates an enforceable individual right, courts should no longer consult the Court’s prior decisions in Wilder v. Virginia Hospital Association, Wright v. Roanoke Redevelopment and Housing Authority, and Blessing v. Freestone, which set forth an overly broad view of the Court’s authority to recognize implied rights of action in spending-power statutes.

Applying those principles to this case, the Court concluded that this is not one of the “atypical” situations in which private plaintiffs may sue for violations of federal spending-power statutes using Section 1983. In contrast to the clear individual rights-creating language in the Federal Nursing Home Reform Act that was at issue in Talevski, the any-qualified-provider provision lacks any clear and unambiguous rights-creating language. Therefore there is no private remedy available under Section 1983. The proper remedy in this case is to cut off federal funding, which is the typical remedy for a violation of spending-power conditions.

Justice Gorsuch delivered the opinion of the Court, in which Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh, and Barrett joined. Justice Thomas filed a concurring opinion. Justice Jackson filed a dissenting opinion, in which Justices Sotomayor and Kagan joined.