Medina v. Planned Parenthood South Atlantic (23-1275) 04/02/25

23-1275 MEDINA, DIRECTOR SC DEPT OF HEALTH V. PLANNED PARENTHOOD

DECISION BELOW: 95 F.4th 152

LOWER COURT CASE NUMBER: 21-1043

QUESTION PRESENTED:

More than 30 years ago, this Court first applied what would become known as the "Blessing factors," holding that a Medicaid Act provision created a privately enforceableright to certain reimbursement rates. Wilder v. Va. Hosp. Ass'n, 496 U.S. 498, 509-10 (1990). Later, the Court distilled from Wilder a multi-factor test for deciding whether a "statutory provision gives rise to a federal right" privately enforceable under Section 1983. Blessing v. Freestone, 520 U.S. 329, 340 (1997). Five years later, though, the Court disparaged Blessing's test while clarifying that only "an unambiguously conferredright is enforceable by § 1983." Gonzaga University v. Doe, 536 U.S. 273, 282 (2002). Then, in Health & Hospital Corp. of Marion County v. Talevski, 599 U.S. 166, 180 (2023), the Court doubled down on Gonzaga's "demanding bar."

The Court did not apply Blessing or Wilder in Talevski, but it did not overrule them either. After the Court GVR'd this case in light of Talevski, the Fourth Circuit applied Wilder and Blessing again and reaffirmed its prior opinions, maintaining a 5-2 circuit split over the first question presented and a 3-1 circuit split over the proper reading of O'Bannon v. Town Court Nursing Center, 447 U.S. 773 (1980), which frames the second question. Those questions are:

1. Whether the Medicaid Act's any-qualified-provider provision unambiguously confers a private right upon a Medicaid beneficiary to choose a specific provider.

2. What is the scope of a Medicaid beneficiary's alleged right to choose a provider that a state has deemed disqualified?

THE PETITION FOR CERTIORARI IS GRANTED LIMITED TO QUESTION 1 PRESENTED BY THE PETITION.

CERT. GRANTED 12/18/2024

You can read the transcript here: https://www.supremecourt.gov/oral_arguments/argument_transcripts/2024/23-1275_0pl1.pdf