Douglas v. Independent Living Center of Southern California, Inc., 132 S. Ct. 1204

Medicaid is a cooperative federal‑state program requiring CMS approval of state plans and amendments to receive federal funds.
California enacted 2008–2009 statutes reducing rates and capping county wage/benefit contributions for home care.
California submitted plan amendments in 2008–2008 to implement reductions; CMS began review.
Providers/beneficiaries filed suits claiming the plan amendments violated 42 U.S.C. § 1396a(a)(30)(A) and were pre‑empted by federal law.
CMS initially disapproved the amendments in 2010, triggering ongoing agency reviews and court proceedings in the Ninth Circuit.
CMS later approved several amendments in Oct. 2011, with limited retroactive rate reductions, changing the posture of the cases.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Supremacy Clause actions can enforce § 1396a(a)(30)(A) after CMS approval	Respondents can pursue private Supremacy Clause relief against California.	CMS approval resolves the question; Supremacy Clause action is not appropriate post‑approval.	Cases remanded; Court declines to decide private Supremacy Clause viability after agency action.

Wilder v. Virginia Hospital Assn., 496 U.S. 498 (1990) (agency review and plan approval framework relevant to Medicaid)
Independent Living Center of Southern Cal., Inc. v. Maxwell-Jolly, 572 F.3d 644 (9th Cir. 2009) (Supremacy Clause authority challenged in Medicaid context)
Gonzaga Univ. v. Doe, 536 U.S. 273 (2002) (no private right of action absent statutory rights)
Astra USA, Inc. v. Santa Clara County, 563 U.S. 110 (2011) (private rights and enforcement limits when statutes confer enforcement via contracts)
National Cable & Telecommunications Assn. v. Brand X Internet Services, 545 U.S. 967 (2005) (standard deference to agency interpretations)
Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984) (administrative deference when reviewing agency action)