Medina v. Planned Parenthood South Atlantic
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Medina v. Planned Parenthood South Atlantic and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Medina v. Planned Parenthood South Atlantic.
The Supreme Court addressed whether individual Medicaid beneficiaries can sue state officials under 42 U.S.C. § 1983 for non-compliance with the any-qualified-provider provision. The Court examined the statutory language and concluded that the provision does not clearly confer enforceable rights under § 1983. The decision emphasizes the role of Congress in determining enforcement mechanisms for spending-power statutes.
Holding
The single most important “bottom line” of what the Court decided in Medina v. Planned Parenthood South Atlantic.
The Court held that Section 1396a(a)(23)(A) does not clearly and unambiguously confer individual rights enforceable under § 1983.
Constitutional Concepts
These are the Constitution-related themes that appear in Medina v. Planned Parenthood South Atlantic. Click a concept to see other cases that involve the same idea.
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Why Spending Power is relevant to Medina v. Planned Parenthood South Atlantic
The case primarily concerns Congress's authority to impose conditions on federal funding to states under Medicaid and whether these conditions create enforceable rights.
Syllabus excerpt (verbatim)Congress created Medicaid in 1965 to subsidize state healthcare... Medicaid offers States 'a bargain': federal funds in exchange for compliance with congressionally imposed conditions.
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Why Remedies and Relief is relevant to Medina v. Planned Parenthood South Atlantic
The Court examines whether private parties can seek remedies under § 1983 for violations of federal statutes like Medicaid, which typically rely on federal funding termination as a remedy.
Syllabus excerpt (verbatim)Spending-power statutes like Medicaid, where 'the typical remedy' for violations is federal funding termination, not private suits.
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Why State–Federal Power is relevant to Medina v. Planned Parenthood South Atlantic
The decision discusses the allocation of authority between state and federal governments, particularly in the context of Medicaid as a federal-state program.
Syllabus excerpt (verbatim)Federal-state agreements resemble treaties between 'two sovereignties.'
Key Quotes
Short excerpts from the syllabus in Medina v. Planned Parenthood South Atlantic that support the summary and concepts above.
Section 1396a(a)(23)(A) does not clearly and unambiguously confer individual rights enforceable under § 1983.
Congress knows how to create clear rights, as FNHRA shows by giving nursing-home residents 'the right to choose a personal attending physician.'
The statutory context supports this conclusion.
