96 F.4th 750
5th Cir.2024Background
- Title X is a federal program providing grants for family planning services, including contraceptives, which requires grantees to encourage family participation "to the extent practical."
- Texas law (Tex. Fam. Code § 151.001(a)(6)) gives parents the right to consent to their children's medical care, including contraceptives.
- The federal government has a longstanding policy (codified at 42 C.F.R. § 59.10(b)) forbidding Title X providers from requiring parental consent or notifying parents when minors obtain contraceptives.
- Alexander Deanda, a Texas parent, sued federal officials, arguing the Title X policy violated his parental rights under Texas law and was unconstitutional.
- The district court found Deanda had standing, ruled Title X did not preempt the Texas law, and partially vacated the federal regulation. The government appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing | Deanda’s state-created parental right is invaded by Title X policy | No standing; Deanda’s injury is hypothetical or generalized | Plaintiff has standing based on invasion of state right |
| Preemption of Texas Law by Title X | Title X does not preempt Texas’s parental consent law | Title X preempts state parental consent requirements | No preemption; both laws can be complied with |
| Vacatur of 42 C.F.R. § 59.10(b) | District court may vacate regulation conflicting with substantive ruling | No APA claim pleaded; vacatur improper without proper challenge | District court abused discretion; vacatur reversed |
| Constitutional right to upbringing | Title X violates constitutional parental rights | Not addressed on appeal due to resolution on statutory grounds | Court did not reach constitutional question |
Key Cases Cited
- Spokeo, Inc. v. Robins, 578 U.S. 330 (Article III standing may be based on invasion of statutory rights)
- Warth v. Seldin, 422 U.S. 490 (Violation of a statutorily-created right can confer standing)
- Arizona v. United States, 567 U.S. 387 (Framework for preemption analysis under Supremacy Clause)
- Altria Grp., Inc. v. Good, 555 U.S. 70 (Presumption against pre-emption in areas of traditional state regulation)