Medina v. Planned Parenthood South Atlantic, 606 U.S. 357

Background

Medicaid’s any-qualified-provider requirement (42 U.S.C. §1396a(a)(23)(A)) directs state Medicaid plans to "provide that . . . any individual eligible for medical assistance . . . may obtain such assistance from any . . . qualified [provider] who undertakes to provide him such services."
South Carolina excluded Planned Parenthood from Medicaid participation in 2018 because the clinics perform abortions; the State said alternative providers would remain available.
Planned Parenthood South Atlantic and patient Julie Edwards sued state officials under 42 U.S.C. §1983, alleging the exclusion violated beneficiaries’ right to choose providers under §1396a(a)(23)(A).
The district court entered summary judgment for plaintiffs and enjoined the exclusion; the Fourth Circuit affirmed. This Court granted certiorari, vacated and remanded after Talevski, the Fourth Circuit reaffirmed, and the case returned to the Court.
The Supreme Court held that §1396a(a)(23)(A) does not "clearly and unambiguously" create individual rights enforceable under §1983 and reversed the Fourth Circuit.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does §1396a(a)(23)(A) confer an individual right enforceable via §1983?	The provision’s language allows any eligible individual to obtain care from any qualified provider, so it creates an individual right to choose providers.	The text addresses state plan obligations to the Secretary and lacks the clear, rights‑creating language required for §1983 enforcement.	No—statute does not "clearly and unambiguously" create an individual §1983 right.
How should courts treat spending‑power statutes for §1983 purposes?	Spending statutes can create enforceable rights when they benefit individuals; this Medicaid provision is such a case.	Spending‑power conditions are contractual in nature; Pennhurst/Gonzaga/Talevski require unmistakable notice to States that private suits are a funding condition.	Spending statutes are especially unlikely to confer §1983 rights; courts must apply the stringent Gonzaga/Talevski test.
Do legislative history or similarity to Medicare (§1395a) show Congress intended private enforcement?	Legislative history and the Medicare "free choice" model show Congress intended a private right.	Legislative history cannot substitute for clear statutory text; the Medicaid provision omits the explicit "guarantee" language used in Medicare.	Rejected—legislative history and the Medicare analogy are insufficient without clear statutory rights‑creating language.
Are alternative remedies inadequate so §1983 is necessary (i.e., federal funding cutoffs, administrative/state review)?	Plaintiffs: only private suits can effectively enforce the provision because the federal government is unlikely to cut funds.	Typical remedy for spending‑power noncompliance is federal enforcement (funding termination); states provide administrative review; Congress can legislate other remedies.	Rejected—policy judgments about enforcement belong to Congress; funding cutoffs and administrative/state remedies remain available.

Key Cases Cited

Gonzaga Univ. v. Doe, 536 U.S. 273 (2002) (spending‑power statutes create §1983 rights only when Congress "clearly and unambiguously" manifests intent to confer individual rights)
Health & Hosp. Corp. of Marion Cty. v. Talevski, 599 U.S. 166 (2023) (reaffirmed Gonzaga test and applied it to FNHRA provisions that used explicit rights‑creating language)
Pennhurst State School & Hospital v. Halderman, 451 U.S. 1 (1981) (spending‑power statutes are "in the nature of a contract" and States must be clearly and unambiguously informed if private suits are a condition of funding)
Armstrong v. Exceptional Child Center, Inc., 575 U.S. 320 (2015) (funding termination is the typical remedy for state noncompliance with funding conditions)
Wilder v. Virginia Hosp. Assn., 496 U.S. 498 (1990) (pre‑Gonzaga case recognizing some Medicaid provisions as privately enforceable)
Blessing v. Freestone, 520 U.S. 329 (1997) (articulated multi‑factor test for statutory rights enforceability later refined by Gonzaga)
Maine v. Thiboutot, 448 U.S. 1 (1980) (§1983 can reach statutory claims in addition to constitutional claims)
O'Bannon v. Town Court Nursing Center, 447 U.S. 773 (1980) (described the Medicaid provision as giving recipients a "right to choose" among qualified providers while rejecting certain due‑process claims)
United States v. Butler, 297 U.S. 1 (1936) (discussion of limits on spending power and the "general welfare" debate)
Monroe v. Pape, 365 U.S. 167 (1961) (expansion of §1983 "under color of law" doctrine and historical shift in §1983 jurisprudence)